CODE OF CONDUCT AND ETHICS
Approach
Our approach to all levels of contact is based on our values and is as follows.
Code of conduct
Our Code of Conduct exists to safeguard the relationship between us, our associates, clients and suppliers. The code underpins our aim to deliver best industry practices, whilst striving to achieve competitive excellence and being the best at what we do.
We respect the letter and the spirit of the law, as well as any regulatory, statutory or contractual obligation that may have a bearing on our relationships.
We work to the highest standards of professional competence and integrity.
We aim to protect colleagues from fraudulent or unethical practices.
We pay due regard to the interests of all parties and treat them fairly.
We do not enter into verbal contractual agreements, express or implied. All contractual agreements will be in writing and signed by authorised individuals.
We expect any personal interest which may be seen to be a conflict of interest to be declared.
We respect the confidentiality of information that is considered to be confidential.
We ensure that visitors to our premises are accompanied at all times and are provided with timely and appropriate information regarding their health and safety.
Core attributes and behaviours:
We expect all individuals within our relationships to adhere to the following:
Strong communication skills
Professionalism
Initiative
Confidentiality
Positive attitude
Patience and Understanding
Honesty
Loyalty
Listening and Comprehension
Integrity
Ethical standards
We aim for high ethical standards throughout our supply chain. These standards are based on nationally recognised best practices and we ask all our associates, clients and suppliers to commit to them and to promote them in their supply chains. These standards form part of our approach to corporate responsibility, the protection of the environment and ensuring that all parties are treated fairly.
General standards
Comply with all laws and regulations
We expect our associates, clients and suppliers to comply with all national and European Union laws and regulations that relate to ethical employment and trading. We also expect them to agree to:
The disclosure of contracts to our auditors, professional advisors and regulators.
Our right to check that they are complying with these standards and all contractual obligations that exist between us.
Co-operate fully and openly with any regulatory investigation that relates to our business relationship.
Don’t exploit child labour
We believe giving young people opportunities at work is crucial for their development. These opportunities must be managed in accordance with national laws on the employment of minors and should be handled in a responsible way. We expect our associates, clients and suppliers:
Not to employ anyone below the minimum legal age for employment.
Not employ any young people (under 18 years) at night or for any hazardous work.
To act in the best interests of any young person that they employ and to make sure the employment does not harm the young person’s education, health, physical, mental, spiritual, moral or social development.
To support and promote policies and programmes that allows any child to remain in education until at least the legal age for employment.
Commitment to anti-slavery
We have a zero-tolerance approach to modern slavery. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking.
We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015.
Therefore, we expect our associates, clients and suppliers:
Not to use forced, bonded, compulsory or trafficked labour and not to hold anyone in slavery or servitude, whether adults or children.
To allow individuals to leave their jobs after giving reasonable notice.
Not to make individuals pay to secure their jobs.
To apply these standards to their own organisation and supply chains.
Do not discriminate
Our associates, clients and suppliers should make sure:
All individuals are treated fairly and with dignity and respect and that no individual is treated less favourably at work on the grounds of race, gender, religion, belief, disability, marital status, national origin, sexual orientation, age or the fact that they work part-time or on a fixed term.
No individual is disadvantaged by conditions or requirements which the associates, clients and suppliers cannot show to be justifiable.
Provide healthy and safe working conditions
We expect our associates, clients and suppliers to:
Provide a healthy and safe working environment for all individuals in line with international standards and national laws.
Provide access to clean toilet facilities, drinkable water and, where applicable, somewhere to store food hygienically.
Identify potential hazards as early as they can and take immediate and effective action to address such hazards.
Provide appropriate health and safety information, instruction, training and supervision to all individuals as and when it is needed to minimise all risks.
Respect individuals
We expect our associates, clients and suppliers to treat all individuals with respect and dignity. Associates, clients and suppliers should prohibit physical or verbal abuse, bullying or harassment on the grounds of race, gender, religion, belief, disability, marital status, national origin, sexual orientation or age and any threats or other forms of intimidation.
Environmental standards
To comply with all environmental laws, we expect all our associates, clients and suppliers to comply with all national, European Union or International laws relating to the environment.
To be environmentally efficient, we are committed to proactively managing and reducing the impact of our business on both the local and global environment and to increasing environmental sustainability. We expect our associates, clients and suppliers to have, or be working towards, policies and processes to:
Reduce their business consumption of water, energy (gas, electricity, solid fuels), office materials (paper, toner cartridges, plastic cups and containers, drink cans, fluorescent tubes) and any other finite raw materials they use.
Minimise their business waste and seek to reduce, recover or recycle waste they create. Dispose of their waste in an environmentally sound way.
Customer standards
Comply with standards set by regulatory bodies.
For those associates, clients and suppliers providing products and services to our customers in the retail market, we expect them to comply with the FCA’s Treating Customers Fairly requirements. This means that we expect:
Treating Customers Fairly to be central to the corporate culture of associates, clients and suppliers.
Associates, clients and suppliers to design the products or services they market and sell to meet the needs of specific customer groups and to only target those groups with the products or services designed for them.
Associates, clients and suppliers to provide customers with clear information and keep them informed after the sale.
Any advice associates, clients and suppliers give to customers to be suitable and take account of the customer’s circumstances.
Associates, clients and suppliers to provide customers with products or services that meet their expectations and are of an acceptable standard.
Associates, clients and suppliers not to impose unreasonable post-sale barriers to customers wanting to change products or services, switch providers or make a claim or a complaint.
We expect our associates, clients and suppliers to:
Commit to our Sourcing Code of Conduct & Ethical Standards
Have processes in place to make sure the code and these standards are kept to.
When we ask, give us data to demonstrate that they are adhering to the code and these standards.
This Agreement is confidential. Details to do with Service Fees, Rates, expenses, client identity or other information relating to this Agreement are not to be disclosed to any third party without the express written permission of Parceman Hill.
From time to time, we may make assessments to ensure that our associates, clients and suppliers are upholding the code and these standards. If we find that associates, clients and suppliers are not, we will work with them to help them do this. However, if it is clear that associates, clients and suppliers will not be able to comply with the code and the standards, or repeatedly miss deadlines for making improvements, we will have no choice but to stop doing business with them.