Tawa Ethical Policy
Introduction
At Tawa, we recognise the importance of trust and integrity in all our dealings with others. The Company therefore strives to attain the highest standards of ethical conduct. This ethical approach is based, in part, on our behaviour and actions. This means that we aim to
- Be open, honest, responsive and accountable
- Treat colleagues and third parties fairly and with respect
- Be committed to acting competently, responsibly and reliably
In addition to providing considerable expertise to issues, we aim to conduct our affairs within Tawa and with third parties with integrity, in a fair, proper and ethical manner and in compliance with applicable laws, regulations and professional standards. However, we recognise that certain ethical decisions may not be clear cut. We have therefore developed the following guidelines to offer practical guidance to Tawa employes on dealing with ethical issues.
Conflicts of Interest
Employees are not to undertake additional paid or unpaid employment outside the Company without consent. Consent is only given where the Company is satisfied that the outside interest or employment will not conflict in any way with the interests or independence of the Company or otherwise adversely affect employees' performance.
Employees must not introduce to any other person, firm, company or organisation, any kind of business that belongs to the Company without its consent. Employees that have any potential financial interests or benefits that arise or may arise from dealings between third parties and the Company must first disclose the interest or benefit and obtain written approval to continue.
Hospitality, Gifts and Gratuities
We expect our employees to exercise discretion and good judgment to ensure that business decisions are based solely on the best interests of Tawa, and are fair to its clients and other business partners. Any business courtesy extended or given to an employee or any member of his or her family must not influence, or appear to influence, the outcome of his or her decisions.
A good rule of thumb is that an employee should neither extend nor accept any business courtesy whose value is greater than what he or she would be willing to pay without reimbursement. Gifts of cash or securities can never be accepted.
If any employee is unsure whether hospitality or a gift is appropriate, he or she should seek advice from their manager or the CEO.
Improper Payments
Making or receiving improper payments of any kind, directly or indirectly, by any employee is strictly prohibited. An improper payment is a payment which a reasonable person would consider to be designed to influence, to be unethical or to be illegal.
Insider Dealing
Employees are encouraged to assist in tackling fraud, corruption and other malpractice within Tawa and in setting standards of ethical conduct. These are serious issues which can occur at all levels of the organisation and which the Company is committed to tackling. This Policy provides a mechanism for employees to report any alleged instances of malpractice to appropriate individuals within the Company.
If employees genuinely believe there is some form of malpractice occurring within the organisation and raise a concern in accordance with this policy in good faith and without malicious intent, the Company will ensure that they do not suffer any disadvantage in the workplace as a result of speaking out about their concerns, whatever the outcome of the investigation.
Money Laundering
The money laundering legislation makes it a criminal offence for persons working in the regulated sector to fail to report knowledge or suspicion of money laundering. Procedures require staff to report any suspicious transactions to their manager who will be responsible for briefing the Money Laundering Reporting Officer and taking any internal steps necessary to validate the information received. Guidance on the nature of transactions regarded as suspicious is set out in the anti-money laundering manual.
Confidential Information
Staff can use, copy and disclose confidential information as necessary to carry out the Company's business and, where applicable, as required or authorised under the terms of any of the Tawa's agreements. All staff have a duty to keep confidential information secure and take reasonable steps to do so.
Unless there is prior written consent from the Company, staff must not use for their own purpose, publish or disclose to any third party any confidential information, and should use their best endeavours to prevent such publication or disclosure.
Employee Responsibilities
Employees should be aware of and comply with the obligations imposed by this the Company's ethical policy. They should seek advice from their manager or HR if they have any questions. They must report any concerns regarding potentially illegal, unethical or improper conduct by other employees or third parties.
All reports of, or enquiries, into conduct that might be considered to be unethical, dishonest or illegal will be properly investigated and appropriate corrective actions taken.
Company Responsibilities
The Company will investigate all concerns that are raised, even if they are raised anonymously. However, issues raised anonymously means that is not may be possible to investigate fully the concerns. If there is genuine belief that there is some form of malpractice, the Company will act to ensure that there will be no disadvantage in the workplace from speaking out, irrespective of the outcome of the decision.
If malpractice has occurred, the Company will take the appropriate corrective action against the individual(s) responsible.
Insider Dealing Policy
Failure to observe the law on insider dealing would not only damage the individual's reputation but the reputation of Tawa. For these reasons, a breach of the Company's policy on insider dealing is deemed gross misconduct and normally justifies summary dismissal.
Whistle Blowing Policy
The aim of this policy is to encourage employees (and others working for the Company) to assist in tackling fraud, corruption and other malpractice and in setting standards of ethical conduct. These are serious issues which can occur at all levels of an organisation. The policy provides a mechanism for employees to report any alleged instances of malpractice to appropriate individuals within the Company.
Health and Safety Policy 2
Tawa complies with the Health and Safety at Work Act 1974 and endeavours to ensure the health, safety and welfare at work of all staff and visitors to its premises.
