Draft Code of Ethics

The Organisation operates under high quality standards - both of products and of service, and requires these to be adhered to at all times in all its dealings.

No-one working for, or employed by or providing services for, the [Organisation] is to make, or encourage another to make, any personal gain out of its activities in any way whatsoever. Any person becoming aware of a personal gain being made in defiance of this policy is required to notify [name]. Provided there are reasonable grounds for such suspicion, the position and identity of the person reporting the matter will be protected. Anyone placed in a position where they feel that they could make a personal gain should notify [name].

Other than properly authorised trade and retail promotions, no inducement may be given to any customer or outlet to encourage them to place an order for, or take any product or service offered by, the Organisation.

Customers may be entertained whilst discussing terms at places and to the limits laid down in the entertainment and gifts guide (see below). The limits and guidelines included in that guide must not be broken.

If a person considers he/she needs to entertain a customer and that the limits are inappropriate (for example, should the event be related to the smoothing over or rectification of a serious problem connected with supply, quality etc.,) the written authority of [a Board member] should be obtained and referred to in the subsequent expense claim.

Employees are allowed to accept hospitality from major customers and suppliers in terms of lunches OR other similar value entertainment, to a maximum of [three or four such items] a year. In the event that the value obtained is in excess of that laid down in the [company] entertainment guide, this fact must be made known to a [Board member] immediately. If the entertainment provided is considered to be in excess of that warranted by the circumstances, the director responsible may need to contact the third party to explain the [company's] policy on accepting entertainment.

Other than at Christmas, employees are not allowed to accept or retain gifts made by any customer or supplier or other third party, generated because of the business relationship. In the event that such gifts are delivered and it seems potentially offensive to return them, then, subject to the approval of the [Director] the gifts may be retained by the [company] and used as raffle prizes or donated to charity. In this instance the [Director] will contact the sender, thank him/her for the gift, and explain what has happened to it and the reason for this (that is, the [company] policy).

At Christmas, employees are allowed to accept normal gifts to a maximum value of [sum] per sender's Organisation. If gifts above this level are received then, subject to the approval of the [Director], they may be retained on the basis as set out in 7 above.

If multiple gifts are received from a supplier or customer to mark the good service he/she has received from a number of employees, these may be retained provided the value per employee sharing in the gift does not exceed the guidance laid down in the entertainment policy.

The attention of all employees is drawn to the danger of a customer or third party using the gifts as a bribe, exerting pressure to obtain better terms, or using the threat of, or actual publicity concerning the acceptance of, a gift as pressure to obtain better terms or other advantage. In all circumstances the immediate response should be 'I cannot comment further - I must contact [the director] to discuss this matter'.

Any suggestion of using facilities owned, occupied or available to the third party (for example, a holiday villa, concessionary or free travel, etc.) either on a free basis or for any consideration which seems or is less than the market price, should be communicated to the [director].

The Organisation wishes to comply with all laws, regulations and codes of practice etc. wherever it trades. It seeks to trade legally, fairly and honestly with all third parties and to give value for money in all its dealings. It requires and expects its employees to carry out their work and responsibilities and to conduct their relationships and dealings with third parties in accordance with these precepts. All dealings must be conducted openly and fairly and in such a way that should every aspect of the transaction become widely known (for example, in the national media) this would not cause injury or damage to the reputation of the [company].

All employees, at whatever level, are encouraged to report any activities which seem to be a breach of this policy. Such reports will be treated as confidential and provided they are made in good faith and not for personal gain, persons making the reports should not fear any reprisals or detriment. (See WHISTLEBLOWING.)

All employees are required to act responsibly, decently and with regard for the dignity and rights of others in both business and personal dealings. In many instances personnel (particularly senior personnel) will be seen as acting on behalf of, or by virtue of their position in the Organisation, the reputation of which must be protected at all times.