Code of Business Conduct

Ethical code of business practices

Bribery and corruption

The company is resolutely opposed to bribery and corruption in whatever form it may take.Any payments, gifts or inducements made by or on behalf of the company and which induce or areintended to induce someone to act improperly and payments, gifts or inducements to publicofficials to influence them in the performance of their duty (other than payments, fees etc.which they are entitled to demand by written law) are matters which will be investigated andmay result in disciplinary action, including summary dismissal, against employeesconcerned.

Gifts or entertainment may only be offered to a third party if they are consistent withcustomary business practice in the relevant territory, are modest in value and cannot beinterpreted as inducements to trade. Sales of the Group’s services and products and purchases of services and products fromsuppliers will be made solely on the basis of quality, performance, price, value and/or for thebenefit of the company, and never on the basis of giving or receiving inducements in the form ofpayments, gifts, entertainment or favours or in any other form.

Employees should not accept gifts, money or entertainment from third party organisations orindividuals where these might reasonably be considered likely to influence businesstransactions. Gifts, other than trivial ones with a low value, should be returned. Thisbecomes even more important when a procurement decision is pending. In a culture wheresuch an action might cause offence, the gift should be declared to the company and, ifpractical, donated to an appropriate charity.

The exchange of gifts and entertainment requires serious consideration inthe business world. Exchanging gifts and entertainment with our vendors,customers and prospective service providers can help to strengthen our businessrelationships. But, we must avoid accepting a gift or entertainment that mayseem to influence our decisions or create a sense of obligation.

Accept a gift only if it:

Follow the same guidelines when giving a gift or offering entertainment to othersoutside our company.

Potentially questionable gifts include:


Political contributions and activities

The company does not make contributions to political parties, political candidates or organisationswhich are politically active and this policy should be followed worldwide. The only exceptionsto this might be in countries where there is a legal requirement to do so. Any payment mustbe approved in advance by the board.Payments of any more than token amounts are unlikely to be permitted.Itis important to note that ‘contributions’ and ‘payments’ can include sponsorship of eventsand gifts in kind etc. not just cash donations.

Every individual has the right to participate in the politicalprocess as he or she sees fit.Guidelines for personally participating in the political process:

Treatment of customers

Mutual trust and confidence between the company and customers is vital. All employees shouldstrive to consistently deliver service excellence and value for money, meeting customers’expectations and anticipating their changing requirements.Accurate understanding of both the customer’s expectations and the company’s obligationsare vital and depend on open and clear communication with the customer.

Our goal is to understand the customer’s needs and work jointly to deliver them. If duringcontract discussions we consider that a customer’s interests are not well served in the longterm by our proposals, we will make this clear even if it impacts negatively on our business.Being open and honest with our customers also means that we will raise concerns with them. If we become aware of any businesses practices or processes in their business we believeare contrary to their values or mean we will compromise our own if we follow them.

Treatment of suppliers

Our suppliers are entitled to fair treatment. It is our policy to pay suppliers in accordance withagreed terms of trade. We set high standards for our suppliers in the context of our ownethical policy. 

Compliance with the law

The company will comply fully with all relevant national and international laws and regulations.It is the responsibility of all employees to ensure, by taking legal or other expert advice whereappropriate, that they are aware of all local laws and regulations which may affect the areaof the business in which they are engaged.

Policies and procedures

The company recognises that there are risks associated with carrying out any business activity. The Board of Directors is responsible for ensuring that policies and procedures are in place to managerisks and for complying with those policies and procedures. Employees should ensure thatthey are aware of the risks associated with their activities and that they comply with policiesand procedures in place to manage those risks. 

Accounting standards and records

All accounting documentation must clearly identify the true nature of business transactions,assets and liabilities in conformity with relevant regulatory, accounting and legalrequirements. No record or entry may be false, incomplete or suppressed.All reporting must be accurate and complete and in compliance in all materialrespects with accounting standards, policies and procedures. Employees must not materially misstate or knowingly misrepresentmanagement information for personal gain or for any other reason. Concerns that this mayhave or will occur should be reported via the whistleblowing facilities available.

Conflicts of interest

Every employee has a duty to avoid business, financial or other direct or indirect interests orrelationships which conflict with the interests of the Company, or which divides his or herloyalty to the Company. Any activity which even appears to present such a conflict must beavoided or terminated unless, after disclosure to the Board of Directors, it isconfirmed in writing that the activity does not constitute a conflict of interest and is notdetrimental to the reputation and standing of the Company.

Examples of conflicts of interest that could arise:

Even the appearance of a conflict of interest may adversely affect the company.Be alert to situations where your judgment could potentially be influencedby personal interests or the interest of someone else, including family membersor other individuals with whom you have a close relationship.  

External reporting

The company may be required to make statements or provide reports to regulatorybodies, government agencies or other government departments. Care should be taken toensure that such statements or reports are correct, timely and not misleading. The Boardof Directors must be made aware of any sensitive disclosure before it is made.

Care must also be taken when making statements to the media that information given iscorrect and not misleading. Information which, if made public would be likely to have materialeffect on the company or about certain transactions such as mergers, acquisitionsor disposals or transactions with related parties is subject to specific rules. Such mattersshould be referred to the relevant the Board of Directors. Enquiries from the mediashould be referred to the Board of Directors and statements should only be madeby designated individuals.Only authorisedmembers of the Board of Directors are permitted to represent the company in the media.

The Board of Directors will decide if they wish to publish on the corporate website the annualreport, accounts or any other statements, appropriate information to enable understanding of the public about the business. We will comply with applicable laws as to the disclosure of information about the company.


The company is committed to optimising individual and business performance through employing thebest people and creating an environment in which they want to and are able tocontribute fully to the company’s success. To achieve a working environment in which teamspirit and commitment to the goals and values of the company are maintained, we all have a duty toensure that individuals are treated fairly and with dignity and respect.Employment will be freely chosen with no use of forced or child labour,and we will not discriminate on the basis of:

and will abide by all anti-discrimination legislation in every jurisdictionwhere the company operates.

Harassmentis defined as any unwanted behaviour, which a person finds intimidating,upsetting, embarrassing, humiliating or offensive. Conduct involving the harassment (racial,sexual or of any other kind) of any employee is unacceptable. Should an employee believethat he or she has been harassed the matter should be raised with the relevant person who will arrange for it to be investigated impartially without delay.

The company values all its employees for their contribution. Equal opportunities applies foradvancement and will not be influenced by considerations other than theirperformance, ability and aptitude. Employees are provided with the opportunity todevelop their potential and to develop their careers further with the company should the opportunity arises.

Employees have a duty to promote the interests of the company.This policy cannot anticipate every eventuality where actions of employees may conflict with the company’s ethical standards. Employees are therefore expected to exercise good ethicaljudgement even when circumstances might not otherwise specifically violate this code ofconduct or where specific laws or regulations do not apply. If in any doubt, employeesshould consult legal counsel.

Confidential information

Employees must not make use of confidential information obtained through theiremployment for personal gain. The disclosure of confidential information to any third partyduring or after employment is not permitted unless the disclosure has been appropriatelyauthorised, is for a legitimate business reason and the information is being communicatedsecurely. ‘Confidential information’is either information that has been described specificallyas being confidential or is otherwise obviously confidential from the surroundingcircumstances.

The term ‘confidential information’does not include information in the public domain orinformation which the individual concerned is required by law to discloseanonymously if they so wish. To ensure that confidentiality is maintained, employees shouldnot discuss such concerns with colleagues or other third parties, unless specificallyauthorised or unless legally required to do so.