Conflicts of interest
Honest and ethical conduct
Treating stakeholders fairly
Protection and proper use of assets
Compliance with laws, rules and regulations
Compliance with this code
Interpretation of this code
Policy class hierarchy
Ownership and maintenance
New policy - written 2008
All employed in the company must not only comply with the applicable laws, rules and regulations but should also promote honest and ethical conduct of the business. They must abide by the polices and procedures that govern the conduct of the company's business. Their responsibilities include helping to create and maintain a culture of high ethical standards and commitment to compliance, and to maintain a work environment that encourages stakeholders to raise concerns for the attention of management.
This code is indented to provide guidance and help in recognising and dealing with ethical issues, provide a mechanism to report unethical conduct and help foster a culture of honesty and accountability.
These can arise from:
- the receipt of improper personal benefits as a result of one's position in the company (including benefits for family members)
- an outside business activity that detracts from an individuals ability to devote appropriate time and attention to their responsibilities in the company.
- The receipt of non-nominal gifts or excessive entertainment from any person or company with which
has current or prospective business
- any significant ownership interest in in a supplier, customer, development partner or competitor of the company.
- any consulting or employment relationship with any suppler, customers, development partner or competitor.
All employed by the company should be scrupulous in avoiding conflicts of interest. Where there is likely to be a conflict of interest, the person concerned should make full disclosure of all the facts and circumstances to the board of directors or the the committee or officer nominated for this purpose and prior written approval be obtained.Honest and Ethical Conduct
The directors, officers and employees shall act in accordance with the highest standards of personal and professional integrity not only on the company's premises but also at company-sponsored business, social events and in their personal lives.
They shall be free from fraud and deception.
They shall always conform to the best standards of ethical conduct.
All have a duty to the company to advance its legitimate interests when the opportunity arises.
Directors, officers and employees are expressly prohibited from
- taking for themselves personally, opportunities that are discovered through the use of the company's property, information or position.
- competing directly with the current business of the company or its likely future business.
- using company property, information or position for personal gain.
If the company has made a final decision not to pursue an opportunity, an individual may follow it up only after disclosing the same to the board of directors or to the nominated committee or individual.
All shall respect confidential information on the company, any of its customers, suppliers or business associates. Disclosure of such information should only be made where authorised or required by law.
The use of confidential information for personal gain is strictly forbidden.
Treating stakeholders fairly
The company will not tolerate discrimination on any grounds whatsoever. All employees will be treated fairly and given the opportunity to grow and develop within the company. Promotion will be on merit. Bullying or harassment is regarded as a serious offence and will not be tolerated.
Everyone has a duty to protect the company's assets and ensure their proper use. Theft, carelessness and waste of the company assets damage profitability. These assets should only be used for legitimate business purposes.
All employed by the company shall comply with all relevant laws, rules and regulations. All employees at all levels are expected to know how these laws and rules apply to their area of decision-making. In the event of any uncertainty, the employee concerned should consult the company legal department before taking action.
If any person suspects or knows of a violation of this code, they must immediately report the same to the board of directors or the designated committee or person. The company has a "whistle blowing policy" or to give its formal title, Public Interest Disclosure Policy that will protect their anonymity. Details of the policy are available on the intranet via the preceding link.
Violations of this code will result in disciplinary action and, in some cases, dismissal. Full details of the disciplinary procedures and the appeal processes are included on the intranet.
Interpretation of this code is reserved for the board. The board may appoint a designated committee or designated person to act on its behalf in interpreting and clarifying this code.
Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.
This policy is owned by the Head of Information Security at