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This Ethics Policy sets out the standards of professionalism and integrity to be maintained by all individuals acting on behalf of the Company. It will be periodically reviewed to make sure that it remains relevant.
All employees, irrespective of level, and third parties acting on behalf of the Company must maintain the standards outlined in the Policy in all their decisions, actions and communications.
All agents, third parties, sub-contractors and suppliers will be supplied with a copy of the Policy and must confirm in writing that they have received the Policy and will adhere to it.
All employees and third parties acting on behalf of the Company are expected to behave honestly and fairly and comply with all legal and regulatory requirements when carrying out their duties on behalf of the Company. They must not use their position for personal gain, take unfair advantage of others through dishonest, unethical or illegal practices or purposefully make false or misleading statements.
This policy should be read alongside other relevant Company policy statements and the express provisions of service contracts and contracts of employment. Any infringements could result in disciplinary action being taken under formal procedures including in the most serious cases dismissal and police referral.
Any person suspected of any infringement of this policy will be given an opportunity to explain his or her actions before formal disciplinary procedures are implemented.
Any queries and concerns should be brought to the attention of senior management or the Bribery Officer immediately. Reports can be made anonymously. The Company will not tolerate reprisal or bullying of anyone who in good faith reports a serious breach of this or any other Company policy. All directors and senior managers are expected to co-operate fully in any internal investigation into illegal or unethical behaviour. |
All employees or third parties acting on behalf of the Company are obliged to avoid situations which may give rise to a conflict of interest, whereby the private interests or actions of an individual may interfere with the interests of the Company as a whole and make it difficult for the individual to perform his or her work objectively and effectively.
All directors and senior managers must disclose any direct or indirect interest in any competitor company, contractor, supplier, consultancy or any other person or body working with or providing goods or services to the Group.
In line with the Company's Gifts, Donations and Entertaining Policy all employees must disclose all corporate hospitality and/or gifts they have received in the course of their duties to the bribery officer for inclusion in the Company's Gifts and Hospitality register.
Corruption inhibits economic growth, is damaging to business, and may result in criminal and civil liability and penalties for the organisation and individuals. The Company's Anti-Corruption Policy outlines these matters in more detail.
Each director and senior manager is accountable and responsible for ensuring compliance with the Company's policies, and where applicable, ensuring that adequate records are maintained to demonstrate compliance.
Any questions about this policy and its application, or your conduct or the conduct of others in a particular circumstance please contact Senior Management or the Company appointed Bribery Officer.
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