Ethics & Business Conduct Policy

Summary

This policy standard is to be applied in relation to Qualter Hall covering all business divisions, operating companies, unless local legal requirements are in place, internationally, which then should be followed.

Qualter Hall is committed to the highest standards of integrity, honesty, openness and professionalism in all its activities wherever they are undertaken.

This Policy Standard outlines the principles that must be adhered to, to enable Qualter Hall to meet this commitment.

Specifically these cover:

1 Introduction

This policy sets out the expected standards for individual and corporate behaviour to ensure that we meet the expectations of our customers, suppliers, employees and the wider community in relation to business conducted on the Company's behalf. It also sets out the standards required in light of the Bribery Act 2010. Bribery in this context is defined as the giving or taking of a reward in return for acting dishonestly and/or in breach of the law.

2 Commitment and Objectives

Qualter Hall's relationships with its customers, business partners, sub-contractors, suppliers, associates, employees, workers and the wider community will be conducted in accordance with the highest standards of integrity, honesty, openness and professionalism.

Equivalent standards of conduct are expected from our business partners, suppliers, associates and all others acting on behalf of Qualter Hall.


3 Principles

The following principles apply to all business activities undertaken by Qualter Hall:

4 Requirements

4.1 Legal and regulatory compliance and influence

Qualter Hall employees must comply with this policy and, where it is clear, the spirit of all laws and regulations relating to their business conduct. This includes understanding the laws and regulations relevant to their work and complying with the legal requirements of the country in which they are working.

Recognising the competitive environment in which Qualter Hall operates, collusive conduct will not be tolerated and all laws which promote competition in business and protect the interests of consumers in the countries where Qualter Hall operates will be adhered to.

Qualter Hall respects the authority of governments.

Wherever it conducts business Qualter Hall will maintain honest relationships with these governments and their agencies, officials and personnel.

If at any time, attendance at events hosted by a political party is required for briefing purposes employees should not attend if it might compromise Qualter Hall's impartiality.

Qualter Hall maintains a position of impartiality with respect to party politics. Accordingly, Qualter Hall does not contribute funds to any political party, politician, or candidate for public office in any country.

Ignorance of the law does not excuse Qualter Hall or its employees from their obligation to comply. If in doubt legal advice should be taken.

4.2 Human Rights and Dignity of the individual

Qualter Hall recognises the United Nations Declaration of Human Rights, the principles of which are considered in all appropriate policies and procedures and applied to all Qualter Hall's business activities.

The working environment created within these business activities will:

4.3 Cultural sensitivity

Wherever Qualter Hall operates it will support and contribute to the social and economic well being of those communities within which we work and encourage individuals to participate in projects that strengthen these communities.

How we do business and the behaviour of employees we will respect the local norms, laws and customs of the countries in which we work. All employees, and particularly those accepting an international assignment, should familiarise themselves, understand and respect the local culture, customs and commercial practices of where they are working.

4.4 Business Integrity

Wherever Qualter Hall operates, business will be conducted in accordance with the highest standards of integrity, honesty and openness. We select the customers for whom we are prepared to work on the basis of their values and ethics as well as their financial standing. Equally we will never knowingly use sub contractors or suppliers whose values or business ethics do not reflect our own.

4.4.1 Financial inducements

Under no circumstances will Qualter Hall approve any irregular payment or payment in kind (gifts, favours, etc.) to win business, induce others improperly to grant permits or services to which Qualter Hall would not generally be entitled or to influence a business decision in the Company's favour. Corporate hospitality is permissible as long as it is proportionate and reasonable given the sort of business we do but should be authorised in advance by The Managing Director.

In international business, in particular, employees may sometimes come under pressure to make such payments, sometimes called facilitation payments. No such payments are to be made by the company or its agents and third parties who are employed by the Company to represent its interests.

This meets obligations under the Bribery Act 2010.

4.4.2 Use of Third Parties and Agents

Qualter Hall recognises that in certain countries, business practices or other conditions require the use of agents or third parties to represent Qualter Hall's interests. These representatives must be carefully chosen because improper conduct could damage Qualter Hall's reputation and expose the Company and individual employees to legal or other sanctions. Local procedures are to be implemented in relation to the appointment of representatives which as a minimum will:

4.4.3 Gifts

The utmost care should be taken in relation to the giving or receiving of business-related gifts. This applies to direct payments and payments in kind, including the provision of goods or services, personal favours, and entertainment (e.g. meals, travel, etc.). Accepting or offering gifts of moderate value is acceptable in situations where it is legal and in accordance with local business practice (i.e. where the exchange of gifts is customary and the gifts are appropriate for the occasion). A limit of £100 per year per individual regarding the receiving of gifts is permissible but these should be logged with the Company Secretary in the first instance who will maintain a central register and advise on what is and what is not allowed.

However, gifts of any kind should not be given or accepted if this action could be reasonably regarded as unduly influencing the recipient or creating business obligation on the part of the recipient.

Particular caution should be exercised if any offers of value, including hospitality, entertainment and gifts are offered when the Company is negotiating or considering contracts and they are in a position to influence, directly or indirectly, the outcome of a decision.

The monetary value of the gift, local customs, and legal requirements should be considered when determining whether a gift should be retained by an employee, handed to the Company, or returned.

The following items must not be given or accepted under any circumstances, regardless of their value: cash, personal cheques, payments or loans to be used toward the purchase of personal property; drugs or other controlled substances and product or service discounts that are not available to all employees.

Under no circumstances should an employee or worker request a gift of any kind from a supplier, customer or other party with whom Qualter Hall conducts business. Normal promotional material is acceptable such as pens, diaries.

4.4.4 Whistleblowing

Qualter Hall takes malpractice and impropriety extremely seriously and will deal with legitimate concerns and/or complaints in a responsible and effective manner. Where an individual discovers information that they believe shows serious malpractice or wrongdoing anywhere within our organisation, then this information should be disclosed internally without fear of reprisal and where appropriate, done independently of line management.

4.5 Individual Behaviour

The following behaviour is required of all employees and workers of the Company within the scope of their duties and responsibilities:

5 Responsibilities and Authority

This Policy standard supports the Qualter Hall Management System and is issued under the authority of the Managing Director, Qualter Hall.

Qualter Hall and each business division will operate systems and procedures that are consistent with our governing principles and this Policy standard.

Qualter Hall expects each employee and division to conform to this Ethics Policy Standard at all times. Failure to do so could lead to disciplinary action being taken that may result in dismissal.

Qualter Hall expects and encourages existing, potential and former employees to report malpractice or impropriety and will investigate all such reports. It will not take any direct or indirect action against employees making a report in good faith.

6 Evidence of Compliance

To demonstrate compliance with this Policy Standard, an annual audit should be undertaken with the following documentation available for inclusion within the audit:

Qualter Hall

7 Guidance

The following other Company policy standards are relevant: