Ethics Policy

Ethics Policy

1. Purpose
   
   EPS’s Ethics Policy sets out the general framework for the professional behaviour expected from EPS’s employees.
   
   The purpose of this document is to set down guidelines as to how the general framework is to be applied.
   
   The document will describe the general ethical principles that all employees need to apply in their professional practices and in their behaviour towards all stakeholders – both internal and external.
   
   
2. Responsibilities
   
   All employees are expected to make EPS’s Ethical Policy an integral part of the way they undertake their jobs. To assist with this, the management system and this document clearly defines responsibilities at all levels.
   
   The Chief Executive Officer has primary responsibility for implementing this policy and for reporting any issues to our Board of Directors. All employees are required to avoid any activities which might lead to or suggest a conflict of interest with the business of EPS.
   
   Every employee and individual undertaking work for EPS has a personal responsibility for the implementation of the policy.
   
   It is the responsibility of the Senior Management Team to ensure that ethical standards are maintained. The Senior Management Team shall monitor this Policy and periodically review its suitability, adequacy and effectiveness and implement improvements as appropriate. This review will take place at the monthly business performance review meetings.
   
   
3. Definitions
   
   Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust.
   
   Fraud is any deliberate and concealed action or omission, committed with the intention of deceiving or bypassing existing laws or EPS’s rules or policies, in order to obtain unwarranted material or moral advantage for the perpetrator of the fraud or for a third party.
   
   Corruption is an illegal agreement between two or more people and is a form of fraud. There are two general categories of corruption:
   
   – Active corruption consists in offering some in offering someone an advantage in order to influence a decision-making process.
   
   – Passive corruption consists in accepting an advantage in return for using one’s influence to affect a decision. Passive corruption can happen without active solicitation but can include practices as serious as extortion.
   
   For EPS the appointed Ethics Officer shall be the Executive Chief Executive Officer. The Ethics Officer is responsible for implementing the Ethics Policy.
   
   
4. Reference Documents
   
   – QA-FO-033 Entertainment Form
   – QA-FO-034 Charitable Giving Yearly Nomination Form
   
   
5. Policy
   
   EPS prohibits all forms of bribery whether they take place directly or through third parties.
   
   EPS prohibits its employees from soliciting, arranging or accepting bribes intended for the employee’s benefit or that of the employee’s family, friends, associates or acquaintances.
   
   EPS employees or agents should not make direct or indirect contributions to political parties, organisations or individuals engaged in politics as a way of obtaining advantage in business transactions. Any political contributions must be publicly disclosed.
   
   EPS shall ensure that charitable contributions and sponsorships are not used as a subterfuge for bribery. All charitable contributions and sponsorships shall be disclosed.
   
   EPS recognises that facilitation payments are bribes and that it should work to identify and eliminate them.
   
   
6. Business Developments
   
   6.1 Joint Ventures and Consortia
   
   EPS will conduct due diligence before entering into any joint venture or consortium. Potential joint venture or consortium partners must have an anti-corruption policy consistent with this EPS Policy.
   
   EPS will monitor the anti-corruption policies and performance of joint venture and consortium partners and if it finds or suspects actions which are inconsistent with its own Policy it will take appropriate action to correct deficiencies, apply sanctions or terminate its participation in the joint venture or consortium. Where EPS is unable to ensure that a joint venture or consortium has an anti-corruption policy consistent with its own, it should have a plan to exit from the arrangement if bribery occurs or is reasonably thought to have occurred.
   
   6.2 Agents and Other Intermediaries
   
   EPS will not channel improper payments through agents or other intermediaries.
   
   EPS will conduct due diligence before appointing agents or other intermediaries.
   
   All agreements with agents or other intermediaries will require prior approval of senior management. 
   
   Compensation paid to agents and other intermediaries must be appropriate and justifiable remuneration for legitimate services rendered.
   
   Agents and other intermediaries must contractually agree to comply with this Policy and be provided with the appropriate advice and documentation explaining the obligation.
   
   EPS will contractually require its agents and other intermediaries to keep proper books and records available for inspection by EPS, its auditors or investigating authorities.
   
   The relationship must be clearly documented in writing.
   
   EPS will monitor the conduct of its agents and intermediaries and should have a right of termination in the event that they pay bribes or act in a manner inconsistent with this Policy.
   
   6.3 Contractors and Suppliers
   
   EPS will conduct its procurement practices in a fair and transparent manner.
   
   EPS will avoid dealing with contractors and suppliers known or reasonably suspected to be paying bribes. It should undertake due diligence, as appropriate, in evaluating prospective contractors and suppliers to ensure that they have effective anti-corruption policies.
   
   This Policy will be made known to contractors and suppliers.
   
   EPS will monitor significant contractors and suppliers as part of its regular review of relationships with them and have a right of termination in the event that they pay bribes or act in a manner inconsistent with this Policy.
   
   EPS considers all forms of discrimination to be unacceptable in the workplace. EPS is committed to providing equal opportunities throughout all areas of employment, including recruitment, remuneration, training and promotion of staff.
   
   EPS is committed to ensuring that no job applicant or employee receives less favourable treatment or is unlawfully discriminated against on grounds of disability, gender, age, sex, sexual orientation, gender reassignment, race, spent convictions 2001, colour, religion, nationality or ethnic origin in accordance with Sex Discrimination Act 1975, the Race Relations Act 1976, Disability Discrimination Act 2005, Civil Partnership Act 2004.
   
   EPS will not ignore, or treat lightly, grievances or complaints from employees on the assumption that the individual is oversensitive about discrimination, discrimination can occur by action, omission, orally or in writing by gesture of innuendo.
   
   
7. Fraud
   
   For EPS, fraud, in all its forms, is unacceptable. Any fraudulent act is punishable by the penalties laid down in international or local law and by the Group’s internal rules.
   
   Fraud is considered to be any deliberate and concealed action or omission, committed with the intention of deceiving or bypassing existing laws or EPS’s rules, in order to obtain unwarranted material or moral advantage for the perpetrator of the fraud or for a third party.
   
   Fraud takes multiple forms: theft of money, goods or data, deliberate falsification, concealment or destruction of documents, false entries or declarations, the manipulation of accounts, counterfeiting, money-laundering, swindling, corruption, etc.
   
   Any worker’s employment or medical records (including test results) relating to this Procedure will remain confidential except in regard to section 8.
   
   Where EPS has agreed to assist an employee in overcoming drug or alcohol-related problems, the employee will consent to their doctor or other medical consultant providing information concerning treatment to EPS, if so requested.
   
   
8. Corruption
   
   EPS forbids corruption in all its forms, whatever the time, the place or the circumstances.
   
   Corruption is an illegal agreement between two or more people. It is a form of fraud. Corruption takes concrete form through actions of different kinds such as gratuities, commissions, gifts or payoffs, private use of public goods, misappropriation, unwarranted payment for a public service, etc.
   
   Acts of corruption are sometimes facilitated through the use of intermediaries such as business consultants in the attempt to mask or conceal the acts from prosecution. To prevent such arrangements, EPS has established an internal framework procedure for the engagement of business consultants that is compulsory in its application.
   
   
9. Extortion
   
   Extortion consists in making the award of a contract or license conditional on the provision of an unwarranted consideration in return, through the exercise of pressure that can extend from occasional or daily demands for money, to exaggerated administrative red tape, or even physical threats to individuals and their families.
   
   
10. Entertainment
    
    Entertainment in the normal course of business shall be the responsibility of the Board of Directors.
    
    The General Manager or Director shall ensure that all entertainment is conducted ethically and professionally at all times.
    
    Upon approval, the Ethics Officer, together with the responsible Business Manager/Director, shall manage the process ensuring that associated entertainment is monitored and records maintained, including completion of Entertainment Form QA-FO-033 and submission to EPS Ethics Officer.
    
11. Charitable Donations and Associations with Registered Charities
    
    The Chief Executive Officer together with the Business Development Department will put forward nominations for three charities, nominations to be from employee representatives. The nominations shall be recorded on Charitable Giving Yearly Form QA-FO-034, the completed form shall be forwarded to the Ethics Officer.
    
    
12. Recording of Applicable Business Dealings
    
    The Ethics Officer shall be responsible for the creation and updating of a formal register, recording all gifts, hospitality, travel, cultural gifts or sports events.
    
    The Ethics Officer shall report regularly to the Senior Management Team and shall compile and issue to the CEO annually a report on ethics.
    
    
13. Confidentiality
    
    As a rule, any information that has not purposefully been made public by EPS or its entities shall be considered confidential and is not to be divulged to any third party without express prior authorisation by a Company Director.
    
    During execution of their tasks, employees will have access to information which relates to clients and stakeholders which will be sensitive and or confidential. Any employee who passes any information to a third party without prior authorisation will be subject to the EPS disciplinary process.
    
    Employees are required to maintain maximum discretion regarding information, of any kind, originating from or in relation to either EPS or any client organisation / personnel.
    
14. Conflict of Interest
    
    A conflict of interest is a situation in which the judgement of a person who is acting in a professional capacity may be excessively influenced by a secondary interest, distinct from that of EPS, e.g. when an employee might take a decision, not on the grounds of their company’s interests, but on their own or a relative or friend. Employees shall check with their line manager if any suspected conflict of interest occurs. This is particularly relevant if you or someone close to you has interests in a company or body that is a client, competitor or supplier of EPS.
    
    
15. Resources & Development
    
    EPS’s commitment to this Policy should be reflected in all Resources & Development practices including recruitment, promotion, training, performance evaluation, remuneration and recognition.
    
    No employee or individual undertaking work for EPS will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes, even if such refusal may result in EPS losing business.
    
    Compliance with this Policy is mandatory for all employees and individual undertaking work for EPS. Failure to comply with its provisions will be dealt with as misconduct under EPS’s disciplinary procedures.
    
    
16. Employment
    
    EPS will not unlawfully discriminate against an individual employee based on disability, gender, sexual orientation, sex, marital status, race, colour, religious conviction, age, nationality or ethnic origin.
    
    
17. Selection
    
    All job applicants will be treated equally. Applicants will be considered on their merits, skills and values for employment, career development and promotion without discrimination.
    
    
18. Raising Concerns and Seeking Guidance
    
    Any employee with concerns regarding the implementation of this Policy or possible violations of its provisions is encouraged to report those concerns to a member of the Senior Management Team of EPS or the Ethics Officer. Any such report will be treated in confidence and without risk of reprisal.
    
    
19. Recruitment and Promotion
    
    EPS will ensure that information about vacant posts will be circulated as widely as possible, so that it may reach as wide a group as possible regardless of race, religion, sex, colour, age, marital status, nationality, ethnic origin, disability or sexual orientation.
    
    No recruitment literature or advertisements will imply a preference for any one group of applicants unless there is a general occupational qualification, which limits the post to a group, in which case this must be clearly stated.
    
    Where a particular qualification is required, EPS will (as far as reasonably practical) state that a fully comparable qualification obtained is as acceptable as a UK qualification.
    
    EPS will recognise the Code of Practice of the Commission for Racial Equality and the Equal Opportunities Commission Code of Practice.
    
    EPS will take all reasonable steps to recruit, employ and promote employees based on ability, skill and qualification, without regard to any of the grounds referred to above.
    
    EPS will avoid making any requirements when recruiting employees, which would exclude a higher proportion of a particular sex or racial group.
    
20. Training, Facilities, and Benefits
    
    EPS will make no distinction based on grounds of race, sex, colour, age, religion, marital status, nationality, ethnic origin, disability or sexual orientation between the training, facilities, promotion, performance, appraisal, pay, terms and conditions, transfer, disciplinary procedures and dismissals and policies against harassment and benefits it provides its employees.
    
    The Annual Appraisal process has been designed to support this, since it focuses on the skills, knowledge, values and attributes required and demonstrated in employees’ roles. It therefore provides an objective framework to which development needs can be addressed.
    
    
21. Monitoring
    
    EPS will ensure that all aspects of the policy are kept under review to ensure the effectiveness of its Bullying and Harassment Procedure. From time to time, EPS will review its selection criteria for recruitment, training, and promotion to ensure that they do not constitute or could lead to unlawful discrimination.
    
    
22. Remedies
    
    Any employee who believes that he / she have been adversely affected by discrimination should raise the issue using the Disciplinary and Grievance Procedure (HP-PR-002).
    
    Employees shall not be victimised for doing so and penalties will be imposed on those who do victimise those complaining of discrimination.

Appendix 1 – Guidance and Authorisation with Regard to Employee and/ or Company Provided

Appendix 2 – Guidance and Authorisation with Regard to Employee Receipt of Gifts and Benefits