2.1. Conduct the Company’s business with honesty and integrity and in a professional manner that protects the Company’s public image and reputation.
Employees should exercise care and good judgement when dealing with the receiving of entertainment, gifts or benefits and should remain scrupulously free from obligations to suppliers or customers. A good benchmark to enable you to judge whether any proposed action is appropriate, is to ask yourself whether the Company or the recipient would be embarrassed if the event should become public knowledge. The following are some guidelines on what is appropriate and what is not:
2.1.1. Gifts of cash, or cash equivalents, are never permissible regardless of the amounts.
2.1.2. Gifts, services, entertainment or benefits of any kind from the Company’s suppliers will be permitted only where they are considered normal in the course of carrying out your duties. Should something be offered which is out of the ordinary, or if you are in any doubt whatsoever, you must seek approval from a senior member of management before the gift, entertainment, etc. is accepted.
2.1.3. The Company will only fund gifts and entertainment where they are consistent with accepted business practice.
2.1.4. Bribery in any form is not acceptable.
2.2. Build relationships with customers, suppliers and fellow employees based on trust and treat every individual with respect and dignity in the conduct of Company business.
2.3. Become familiar with and comply with relevant legal requirements and Company policy and procedures, in particular the Bribery Act 2010.
All employees having dealings with suppliers or contact with competitors should be conversant with the principles set out in the Competition Act 1998 and the Enterprise Act 2002. This legislation outlaws anti-competitive agreements and conduct and is designed to establish a level playing field for all businesses engaged in a particular sphere of activity. Penalties for breaching the legislation are severe. Examples of practices which are prohibited include:
- price fixing;
- market sharing;
- the imposition of unfair terms and conditions;
- any practices which may be perceived to be an abuse of a dominant market position; and
- restricting a competitor’s source of supply.
No employee should agree on, or even discuss with competitors product pricing, market sharing or terms and conditions relating to products offered by the Company. The law in this area is complex; if in doubt, employees should seek advice from the Group Secretary before engaging in any discussions or meetings on matters which may be prohibited by the legislation.
2.4. Avoid actual or potential conflicts of interest with the Company, or the appearance thereof, in all transactions.
Any employee who has a personal interest in an organisation with which Northgate has or may have a business relationship is vulnerable to allegations of impropriety. If a personal interest or that of a member of one’s immediate family might influence the Company’s business relationship, it should be declared in writing to the Group Secretary. A copy of this should also be sent to the relevant member of the UK Senior Management team.
Examples of a personal interest that should be declared include a directorship, a significant shareholding, a promise of future employment or the employment of a close relative or friend in a position of influence in an organisation which may be given business or awarded contracts by our Company.
Similarly, the employment of a close relative or friend within the Company should be done in such a way that a conflict of interest does not arise.
The policy of the Company with respect to conflicts of interest requires that all employees avoid situations in which any conflict might arise between their personal interest and those of the Company in dealing with suppliers, customers and all other organisations or individuals, doing or seeking to do business with the Company.
If you are in any doubt as to whether a conflict of interest exists or may develop, you should raise this immediately with the Group Secretary or a senior member of management.
Safeguard the Company’s confidential information, and respect the confidential information of other parties with whom the Company has dealings.
All employees have a responsibility to safeguard the confidentiality of any information acquired during the course of their work, including information kept on computers, and a duty never to use it for personal advantage. Such information should not be disclosed outside the Company and should only be divulged to other staff who need to know the information in order to carry out their duties. This obligation applies not only during employment with the Company, but thereafter as well.
Promptly report to the Company any breaches of law or ethical principles or Company policies that come to the employee’s attention, and cooperate fully in any audit, enquiry, review or investigation by the Company. This includes improper use of Company assets, fraud and theft; such conduct will always be treated as gross misconduct, which can result in immediate termination of employment.
If appropriate, such reports can be made confidentially using the Group’s Expolink facility. The Expolink line is designed to supplement, rather than replace, existing reporting channels. Calls will not be recorded or traced and callers may remain anonymous. Expolink staff answer the calls and pass on the information to the Chief Executive and/or the Group Secretary.