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.
For the purposes of this Code, "corruption" includes bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement, trading in influence and similar criminal activity.
Corruption inhibits economic growth, is damaging to business, and may result in criminal and civil liability and penalties for organisations and individuals.
Itacon Granito prohibits its directors, officers and employees, and those of its branch offices which it controls, from engaging in any form of corruption in relation to Itacon Granito business and affairs.
Specifically such directors, officers and employees should:
a) Act at all times honestly and without deception
b) Not knowingly or recklessly do any of the following, or participate in any activity which involves any of the following:
Offer, give, demand or accept any bribe or other improper advantage.
Participate in any dishonest or deceptive activity, including in relation to any selection, certification, approval or management process.
Provide, conceal, or approve work, materials, equipment or services which are not of the quality and quantity required under contract.
Provide false, inaccurate or misleading information.
Dishonestly withhold information.
Make or submit false, inaccurate, misleading or exaggerated records, invoices, claims, applications for variations or extensions of time, or requests for payment.
Dishonestly refuse or fail to approve, or delay in approving, work, materials, equipment, services, invoices, claims, applications for variations or extensions of time, or requests for payment.
Dishonestly refuse or fail to pay, or delay in paying, sums due.
c) Any director or officer or others having management responsibility within Itacon Granito should in addition to the above:
Not instruct, authorise or condone, expressly or impliedly any corrupt activity;
Make proper enquiries regarding any suspicion of corruption which becomes apparent;
Take reasonable preventative measures to stop corruption for which Itacon Granito may be liable;
Report any suspicion of corruption to the Board of Directors and to the officer responsible for compliance with Itacon Granito anti corruption programme
Itacon Granito will use all reasonable endeavours to conduct its business and affairs so as to ensure that it does not engage in or facilitate any form of corruption.
In order to minimise the opportunity for corruption a policy has been adopted for political and charitable donations and the provision of gifts or hospitality to any person or organisation a copy of which is below.
A facilitation payment is a payment made to encourage a person to carry out his duty. Even though facilitation payments are in many cases obtained by way of extortion, they are nevertheless a form of corruption and the making or receiving of a facilitation payment is a criminal offence in many jurisdictions. Itacon Granito prohibits the making of any facilitation payment unless permitted under local law, save in circumstances where the personal safety of any person is endangered.
Itacon Granito will adopt a corporate anti-corruption programme to enable it to comply with this Code. Itacon Granito will properly implement this programme within the next three months and ensure that it is reviewed on an annual basis to warrant that it is operating effectively.
The gift, donations and hospitality policy establishes the ethical standards of Itacon Granito and underpins the behaviour we expect of everyone engaged by us in conducting business on our behalf. It enables us to ensure we maintain the first class reputation that our customers, clients and employees expect from us.
The Company's aim is always to ensure customer and client satisfaction. Occasionally, satisfied customers, clients or other third parties may seek to reward employees with gifts. Whilst the Company has no desire to stop deserving employees receiving a small token of gratitude from a satisfied customer or client, there is the potential for abuse. In addition, certain suppliers or contractors may offer "reward schemes" which allow employees to obtain free gifts or discount vouchers in return for ordering services or products on behalf of the Company from that supplier or contractor.
The Company needs to be sure its suppliers and contractors are competitive and that its employees are acting in the best interests of the Company when using a particular supplier or contractor. The Company does not believe that it is appropriate for employees to accept anything of greater value than small tokens of appreciation from customers, clients, suppliers, contractors or from any other person or organisation with which the Company has, or might have, business connections. This is because it is important to ensure that no employee acts in any way that is inconsistent with the integrity of the business by accepting a gift in circumstances where it could influence, or be seen to influence, that employee's business decisions or actions.
For these purposes a "gift" is any payment or item given to an employee on an apparently ex-gratia basis by any party in connection with the employee's employment by the Company.
The company expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. The company expects the same approach to doing business from everyone acting on its behalf including agents and third parties, and from its suppliers and customers.
Itacon Granito does not permit any employee whether directly or indirectly, in a personal of professional capacity to:
1. Accept anything of greater value than small tokens of appreciation (up to £50) from customers, clients, suppliers, contractors or from any other person or organisation with which the company has, or might have business connections.
Any employee receiving a gift must report it to their line manager as soon as it is received and provide details of the nature of the gift and the identity of the sender. Failure to do so will constitutes a disciplinary offence and will be dealt with in accordance with the Company's disciplinary procedure. Depending on the gravity of the offence, this may be treated as gross misconduct in accordance with the Company's disciplinary procedure and could render the employee liable to summary dismissal.
If the gift is anything other than a small token of appreciation having no substantial financial value, the employee will be required to return the gift to the sender with a polite letter thanking them and explaining that it is the Company's policy that employees should not receive gifts.
If, in the opinion of the line manager, the gift might constitute a bribe or other inducement, it will be passed to a Director of the Company who will return it to the sender with a suitable letter explaining the Company's policy and asking the sender to comply with the policy in future.
In cases where the line manager determines that the gift constitutes a small token of appreciation as a personal reward, the employee may be permitted to retain the gift. However, unless the sender of the gift specifically states or makes clear that the gift is intended as a personal reward, all gifts are deemed to be the property of the Company and may be shared amongst members of staff, as appropriate.
Thus, small gifts that are genuinely given as a token of appreciation are acceptable, provided always that they are properly declared in line with this Policy and provided the sender of the gift is not subsequently treated more favourably than other clients, customers, suppliers or contractors.
If the Company discovers that a supplier has been used by an employee wholly or mainly because of the incentive of a free gift (and, as such, the employee has not acted in the best interests of the Company), this will also constitute a disciplinary offence and will be dealt with under the Company's disciplinary procedure. Depending on the seriousness of the offence, it may again be treated as gross misconduct and could render the employee liable to summary dismissal.
The receipt of all gifts will be closely monitored by the Company.
This Policy does not apply to promotional gifts, i.e. items such as pens, calendars or stationery that bear the company name or logo of another organisation, provided that these have no significant financial value.
2. Offer to or receive hospitality from any connected person unless pre-authorised by management or in the case of management the bribery officer.
3. To offer donations either political or charitable to any organisation where anyone in that organisation would constitute a "Connected Person", unless authorised by management or in the case of management, by the bribery officer.
For these purposes a "Connected Person" is any organisation or individual who has had, or currently has, or is likely to have in the future an influence over the Itacon Granito business.
To ensure compliance all employees will be provided with a copy of this policy and the company's Anti-Corruption policy, and will be asked to sign it as a condition of their employment. Employees will be required to submit details of all gifts, donations and hospitality to the bribery officer who will record all transactions in a Gifts and Entertaining Register for regular reviewing.
Itacon Granito gifts, donations and hospitality policy, anti-corruption policy and ethics policy will be published on the Itacon Granito website. The policies will be communicated to customers, suppliers, third parties and agents who will be asked to acknowledge that they have been made aware of the policies and that they will endeavour to adhere to the requirements within.