Code of Conduct
Published: 15th June 2024
Principle 1: Honesty, Integrity and Fair Play
Four Thirty Two Ltd (trading as Four32) and all its staff are fully committed to honesty, integrity and fair play in the delivery of services and goods to the public. All staff must ensure that business operations, applications for services, procurement, and staff recruitment are dealt with in an open, fair and impartial manner.
This Code of Conduct sets out the basic standards expected of all staff, including policies on acceptance of advantages and conflicts of interest in connection with official duties. This Code also applies to temporary and part-time staff.
Principle 2: Equal Opportunity for All Employees
The Company is an equal employment opportunity employer. Employment opportunities are provided regardless of race, colour, sex, religion, national origin, age, disability, gender, or any other legally protected status.
This principle applies to all aspects of employment, including recruitment, hiring, training, work assignment, promotion, transfer, termination, and compensation.
Principle 3: Health and Safety
The Company is committed to providing an injury-free and illness-free workplace, operated in an environmentally responsible manner and in compliance with all relevant health, safety, and environmental laws. Employees must perform their work safely at all times.
Principle 4: Fair Competition
The Company prohibits any anti-competitive or unfair competition practices. Employees must not agree with competitors (formally or informally) to:
- Fix prices or trading conditions;
- Limit or control production, commercialisation, technical development, or investment;
- Manipulate or divide markets or sources of supply;
- Submit fake or collusive bids in tenders;
- Restrict market access or freedom of competition for other enterprises;
- Apply unequal conditions to equivalent transactions;
- Condition contracts on unrelated supplementary obligations.
Employees must not engage in unfair competition, including misappropriating clients, poaching employees to disrupt competitors, or otherwise harming the legitimate interests of customers or competitors in breach of competition law.
Principle 5: Governance and Anti-Corruption
The Company has zero tolerance for corruption. Employees must never offer, promise, or provide anything of value directly or indirectly to government officials or business partners to secure an undue advantage.
Third parties may only be engaged where fees are reasonable, arrangements are documented, and all actions comply with Company policies.
Principle 6: Financial Reporting
All Company transactions must be accurately recorded to allow preparation of clear financial statements in accordance with generally accepted accounting principles.
No false or misleading entries may be made, no undisclosed funds may exist, and no payment may be made without appropriate documentation or for undisclosed purposes.
Principle 7: Restrictive Agreements with Third Parties
No employee may violate valid restrictive agreements with third parties or use or disclose confidential information or trade secrets obtained through prior employment or association.
Principle 8: Government Contracts and Services
The Company complies with all laws governing public procurement and government contracts. All reports, certifications, and declarations to public authorities must be accurate and complete.
Principle 9: Acceptance of Advantages
Staff must not solicit or accept advantages from persons with business dealings with the Company. Gifts offered in an official capacity are considered gifts to the Company.
Gifts below £50 may be accepted only where refusal would be impractical or impolite. Other gifts require written approval from the Founding Partners within five days.
All permissions will be properly recorded, signed, and dated.
Principle 10: Conflict of Interest
A conflict of interest arises where personal interests conflict with Company interests. Employees must avoid real or perceived conflicts and must declare them in writing to the ethics officer.
Staff involved in procurement must declare any interest in potential suppliers and abstain from decision-making where conflicts exist.
Principle 11: Misuse of Official Position
Misuse of official position for personal gain or to benefit associates may result in disciplinary action or prosecution.
Principle 12: Handling of Classified or Proprietary Information
Confidential or proprietary information must not be disclosed without authorisation. Unauthorised disclosure of personal data may result in legal breaches.
Principle 13: Property of the Company
Company property must be used only for legitimate business purposes. Misappropriation is strictly prohibited.
Principle 14: Outside Employment
Employees must obtain written permission from the Founding Partners before undertaking paid outside work. Approval will be refused where conflicts of interest exist.
Principle 15: Compliance with the Code
All staff are responsible for understanding and complying with this Code. Violations may result in disciplinary action or referral to authorities.
Principle 16: Sanctions
Sanctions may include warnings, reprimands, reassignment, suspension, or termination. Serious breaches may be reported to authorities.
Principle 17: Reporting
Employees must promptly report violations. Reports may be made confidentially and without fear of retaliation.
Principle 18: Ethics Officer
The Founding Partners act as the ethics officer and are responsible for compliance, guidance, investigations, and reporting to the Board.
Appendix 1: Definition of Advantage
“Advantage” includes gifts, loans, fees, employment, payments, services, favours, protection from penalties, or any promise of such benefits.
Appendix 2: Disposal of Gifts
- Perishable gifts shared within the Company
- Useful items donated to charity
- Items of interest donated to libraries or museums
- Display items retained on Company premises
- Personal items under £50 retained by the recipient
Appendix 3: Conflict of Interest Examples
- Financial interest in a supplier under consideration
- Frequent gifts from suppliers or contractors