A) INTRODUCTION AND OBJECTIVES
- This Ethics Policy is supported by the Directors of WEC Alarms Limited and shall be reviewed from time to time. The policy sets out standards of professionalism and integrity to be maintained by individuals in all the Company’s operations.
- Every employee of WEC Alarms Ltd has a right to expect the Company to maintain proper standards and in turn all employees have a duty to maintain these standards through their decisions, actions and communications. A heavier responsibility is borne by those who hold positions of authority. They must openly demonstrate leadership in applying the business practices outlined in this policy.
- This policy provides guidance on the way all staff are expected to conduct themselves operating with integrity, fairness and in compliance with the law and regulatory requirements.
- Whilst the policy applies primarily to directors it is also intended to apply to all employees of the business insofar as it is appropriate to their role.
- All agents, joint venture and other partners, sub-contractors and suppliers are expected to adhere to the principles of this policy in their dealings with the Company. It must therefore be brought to their attention in your dealings with them. They must write to confirm receipt of the Policy and adherence to it and agree to confirm on an annual basis that this Policy has in fact been followed in their dealings with us and on our behalf by 1st September each year.
B) POLICY STATEMENT
- The Company expects all of its staff to operate with integrity and to high standards of ethical conduct when carrying out their duties on behalf of the Company.
- In particular they are expected to:-
- Behave honestly and fairly.
- Comply with all legal and regulatory requirements.
- Conduct themselves in a manner that will enhance the reputation of the Company.
- Treat others with respect.
- Safeguard the assets and property of the Company.
- Follow the WEC Alarms Ltd Vision & Philosophies.
- Staff must not:-
- Use their authority or office for personal gain
- Recruit or promote employees other than on their ability.
- Take unfair advantage of others through dishonest, unethical or illegal practices.
- Knowingly make any false or misleading statements.
- Mis-appropriate the assets or property of the Company.
- Seek to comply only with the letter of the law, rule or Company policy whilst ignoring the spirit, where such actions are not in accordance with this Ethics Policy.
- Vary from this Ethics Policy or any Company policy simply on the basis of “commercial necessity”.
- If in doubt as to your responsibilities please ask (see section L below).
- This policy provides general guidance on business ethics to all staff but should be read alongside other relevant Company policy statements and the express provisions of service contracts and contracts of employment.
- The provisions of the policy will be rigorously enforced and any infringements could result in disciplinary action being taken under formal procedures including in the most serious cases dismissal from the Company, a police referral for criminal prosecution and a claim for recovery of loss or damage.
- Any person suspected of any infringement of this policy will be afforded an opportunity to explain his or her actions before formal disciplinary procedures are implemented.
D) COMPLIANCE WITH LAWS, RULES AND REGULATIONS
- All directors should ensure that they are aware of the laws and regulatory requirements affecting their areas of operation. In particular all directors should be aware of their responsibilities under the UKLA Listing Rules and the regulatory requirements and Group guidance relating to our core operations such as: Health and Safety, Competition Compliance, Mis-description, Anti-Bribery regulations, CML Disclosure of Incentives and Consumer Protection.
- Directors are responsible for ensuring their staff are familiarised with the contents of this Policy and other Company policies such as these detailed above.
E) REPORTING ANY ILLEGAL OR UNETHICAL BEHAVIOUR.
- An 'open door' policy is encouraged throughout the Company so that, if necessary, any queries and concerns can be brought to the attention of management.
- Directors should promptly action any illegal or unethical behaviour of which they become aware. All matters of suspected fraud, theft or mis-appropriation of Company property must be reported to the Company Managing Director.
- Whilst the Company would consider any director to have a responsibility to disclose serious breaches of this policy, the Whistleblowing Policy provides access to an independent confidential helpline managed by Safecall for any employee who would prefer to report matters on a confidential basis. Their confidential helpline is available on 0800 915 1571. 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 are expected to co-operate fully in any internal investigation into illegal or unethical behaviour.
Directors must maintain the privacy of non-public confidential information entrusted to them by the Company, its customers or any other party with whom the Company conducts business. Specific categories of confidential information that should never be disclosed to persons outside the Company, except where disclosure is authorised or legally required would include:-
- Business operating information, business and marketing plans, volume data, pricing policies, contract terms, production technologies, customer and supplier data as well as personal data under the Data Protection Act.
- Unpublished financial results, sales details, budgets, bonusable targets and business initiatives under consideration falling within the normal definition of inside information.
- Confidential information should not be improperly collected, stored or distributed, lost or destroyed.
G) CONFLICTS OF INTEREST
- Each director owes a duty of care to the Company to avoid situations which may give rise to a conflict of interest. A conflict of interest occurs when the private interests or actions of an individual may interfere with the interests of the Group as a whole and make it difficult for an individual to perform his or her work objectively and effectively. Conflicts of interest may also arise where a director or a member of his or her family received improper benefits or personal advantage as a result of his or her position in the Company.
- All directors must disclose any direct or indirect interest including shareholdings and family relationships in any competitor company, contractor, supplier, consultancy, Joint Venture or other partner or any other person or body working with or providing goods or services to the Company.
- It is particularly important that any director engaged in purchasing activities or responsible for placing orders for work and services makes an annual declaration of any material interests that they, their spouses or dependents have in suppliers, contractors, consultants or other third parties engaged by the Company. They should also disclose all corporate hospitality and/or gifts they received in the course of their duties having regard to the separate Company Policy on such matters.
H) FINANCIAL COMPLIANCE AND FINANCIAL RECORDS
The Company’s financial records should be complete and accurate so that they reflect the true state of the business and disclose the true nature of disbursements and transactions. All the Company’s books, records, accounts and financial statements must be maintained in reasonable detail using standard Company systems; must appropriately reflect the Company’s transactions; must conform both to applicable legal requirements and generally accepted accounting principles and to existing systems of internal control. In particular it is prohibited to undertake transactions that contravene tax laws, legal regulations and/or policy or procedural requirements of the Company including.
- Making or approving any payment with the understanding that any part of such payment is to be used for any purpose other than that recorded in the Company’s books of account and by the documents supporting the payment.
- Establish undisclosed funds or assets or to make false or mis-leading entries in any books of accounts or accounting documents or to destroy accounting records and supporting documents within required statutory retention periods.
- Use Company fund or assets for any unlawful purpose.
- Knowingly make false or inaccurate statements in the Company control risk self-assessment return.
- Knowingly make any false or inaccurate statements to any of the Auditors carrying out periodic reviews of the Companies accounting records and internal controls.
- Corruption causes loss and damage, inhibits business growth, is harmful to the reputation of the business, and may result in criminal and civil liability and penalties for the Company and individuals.
- The Company and every related business prohibits its directors, managers, officers and employees , from engaging in any form of corruption in relation to its business and affairs.
- Anti-corruption action by individual organisations is unlikely on its own to reduce corruption in our sector to any significant extent. There must, in addition, be concerted and collaborative action by all stakeholders and the Company will support all national initiatives and will work with other stakeholders to reduce corruption in the sector.
- The Company’s Anti-Bribery Policy will deal on its issue with these matters in more detail.
J) ACCOUNTABILITY AND SUPPORT
Each director is accountable and responsible for ensuring compliance with Company financial and other policies, including this Ethics Policy, and where applicable, ensuring that adequate records are maintained to demonstrate compliance. Support is also provided at Company Board level through:-
- The use of external auditors who audit Company financial statements to ensure that they give a true and fair view of performance and to comment fully on financial control weaknesses identified in their management letters.
- The use of internal auditors who will undertake a programme of internal reviews and comment on the standard of internal control and compliance with Company policies and procedures within any given area of the Company.
- The control risk self assessment process.
K) LINKS TO OTHER POLICIES
- 1. All other Company Policies should be read in the light of and in conjunction with this Ethics Policy and Code of Conduct.
L) QUESTIONS ABOUT THIS POLICY
- If you have any questions about this policy apparent conflicts between the application of this policy and legal requirements and procedures, or your conduct or the conduct of others in a particular circumstance please contact a director. Alternatively should you prefer to do so then refer your concerns to the Group’s confidential Whistleblowing Helpline (provided by Safecall – see paragraph E above).
Stephen Beal, Managing Director, WEC Alarms Limited