Code of ethics and professional conduct Introduction Our values define who we are as a firm and who we aspire to be. They are the guiding principles that guide our actions and are essential to fulfilling our two-part mission: to help our clients achieve significant, lasting and substantial improvements in their performance and to build a great firm that attracts, develops, inspires and retains exceptional people. We expect all our colleagues to live our values every day. And when we are faced with a difficult situation, we expect everyone to challenge themselves and consult with colleagues to determine what course of action is most consistent with our values. While our values guide our behaviour and help us make the right choices, we also have firm policies. These policies set out our obligations as members of the firm and set out the rules for behaviour in a number of very specific, often complex situations. They apply to all members of the firm worldwide and we expect all colleagues to comply fully with these rules. We are held to the highest standards of integrity and conduct and therefore our rules often go far beyond what is required by law. Failure to comply with our policies may lead to disciplinary action, including dismissal from employment. Finally, we have a Code of Professional Conduct which sets out a set of expectations for the conduct of all members of the firm. The Code of Professional Conduct does not replace our policies. Rather, it serves as a guide to help colleagues understand the key elements of our policies and how those policies are enshrined in our values. The Code of Professional Conduct emphasises our personal responsibility for professional conduct. We expect all colleagues to comply with this Code of Professional Conduct and expect others working on our behalf, such as contractors, consultants and other suppliers, to act in accordance with our Code. Our code of professional conduct Our Code of Professional Conduct serves as a guide to our values and policies in action and defines the expectations we have of all firm members in the following areas: 1. to serve our clients with the highest professional standards 2. Creating a working environment that inspires and motivates our people 3. Fulfilling our responsibility to the community 4. Managing risks for the company 5. Seeking advice and raising concerns The Marrbery Code of Professional Conduct is supported by a full set of company policies. 1. serving our customers with the highest professional standards We are honored to enjoy the trust of clients who We have earned this trust by always acting with the highest integrity; providing objective and independent advice; putting our clients’ interests ahead of our own; and protecting confidential and sensitive information. We expect everyone from all colleagues to always act in a way that justifies and justifies and reinforces the trust that we enjoy. Impact on the client As a firm, we set our sights high in terms of the positive impact we have through our service to clients. We will take on work when we can be confident that the objectives of the work will have a significant, positive and lasting impact; that the impact of our work has the potential to far exceed our professional fees; that we will not be pressured to compromise our values; and that we will stick to our commitment to do work that attracts, develops, inspires and retains exceptional people. We are committed to maximum impact for all our clients and we hold our leaders accountable for that impact. We expect our leaders to oversee our work, make sure the conditions for making an impact are right, and bring our best capabilities to every situation. All colleagues have a responsibility to speak up if they feel that our ability to realise these impact aspirations is being compromised. Confidential customer informatio In the course of our work we are entrusted with client and third party confidential information and we treat it with the utmost care with the information that has been entrusted to us. Confidential client information is all non-public information (written or verbal), including business plans and trade secrets, client names, the nature of our services, our references, the nature of our client services, our recommendations or advice, client data, and information that we acquire at our clients’ expense. We only share client confidential information with colleagues who have a legitimate need to know, or with those we know have a right to access this information. When using social media, we expect colleagues to protect confidential customer information, including anything that might reveal a customer’s identity or our presence there. Colleagues must also ensure that our client data and the firm’s information environment are protected from unauthorised external access by complying with the cybersecurity standards described in the firm’s cyber policy. Professional independence We must avoid engaging in outside activities that may interfere with our responsibilities to our clients and the firm. Each of us has a responsibility to ensure that So that there can never be any doubt as to whether we are acting in our capacity as an employee of the firm, or in any other role. Members of the firm are therefore not permitted to hold outside employment, nor are they permitted to conduct or actively manage a business, run for political office or take an official part in a political campaign. In addition, members of the firm may not serve on the board of directors of any for-profit company, whether private, public or state-owned, and must obtain permission before serving on the boards of non-profit organizations to ensure that no conflicts with our clients arise. Temporary client roles are only permitted in very limited circumstances and only after approval by the firm’s Client Risk Committee. All firm employees all members of the firm have a duty to disclose any potential conflicts of interest, real or perceived, and to consult with their respective firm managers and governing bodies on how best to deal with
Category: Rule
Supplier Code of Business Conduct
Supplier Code of Business Conduct Intro Marrbery maintains the highest standards of integrity and social responsibility. Marrbery suppliers who provide products and services to Marrbery (“Suppliers”) are expected to adhere to the same standards. The Marrbery Supplier Code of Conduct (the “Code”) sets out Marrbery expectations for the way in which its Suppliers conduct business. Marrbery expects its Suppliers to act in accordance with the Code and requires all Suppliers to comply with applicable laws and regulations in the regions in which they operate and to cooperate openly with regulatory authorities that monitor compliance with those laws. In cases where the expectations outlined in the Code differ from the requirements of local laws, Suppliers shall comply with these expectations without going beyond the scope of applicable local laws. General information about The Code reflects Marrbery values and sets out its expectations of its Suppliers in the following areas: 1. Ethics and integrity 2. Confidentiality and data security 3. Inclusiveness and diversity 4. Recruitment and working conditions 5. Well-being, health and safety 6. Environmental protection Ethics and integrity Marrbery maintains the highest ethical standards and complies with all applicable laws, rules and regulations. In particular, Marrbery requires Suppliers to comply with the following standards: Fight against bribery Suppliers are required to fully comply with all applicable anti-bribery and corruption laws (such as the Ukrainian Foreign Corrupt Practices Act, the UK Bribery Act). Gifts and representative events Suppliers must not offer or accept any gifts to obtain an undue advantage or influence for themselves, Marrbery (e.g. Marrbery employees and their relatives and associates) or third parties. Gifts include benefits, fees, commissions, dividends, cash, gifts of money, services and any inducement. Protection from persecution for reporting problems Marrbery requires Suppliers to have a policy and procedure for reporting workplace concerns. The policy and procedure must be open and clear, and must protect the whistleblower and those involved from retaliation. Data privacy and security Marrbery requires its Suppliers to protect the privacy of individuals as well as the security of confidential assets and information. Confidential assets and information Suppliers are required to protect the confidential assets and information of Marrbery and its customers. Suppliers shall develop and maintain processes to ensure that such information is adequately protected. Personal information and privacy Marrbery suppliers are required to protect personal information in accordance with all applicable local laws. The use, disclosure and access to personal information provided by or on behalf of Marrbery shall be in accordance with the agreement with the Supplier. Inclusiveness and diversity Marrbery promotes a culture of inclusion, encourages diversity and does not tolerate any form of discrimination. Non-discrimination and diversity in the workplace Marrbery requires that Suppliers’ facilities are free from discrimination, harassment, victimization, and any other form of harassment on any basis, including but not limited to age, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, family status, pregnancy, political opinion, religious belief, trade union membership, or military service. Diversity among Suppliers As part of Marrbery long-standing commitment to promoting diversity and inclusion, Marrbery actively encourages engagement with diverse and lesser-known companies as part of its strategic sourcing process. Marrbery Suppliers are required to: (i) use objective and open sourcing and evaluation processes; (ii) ensure that their procurement departments proactively provide diverse companies with fair access to tenders; and (iii) where possible, actively seek and provide diverse suppliers with the opportunity to participate in business projects. Recruitment and working conditions As a UN Global Compact Company, Marrbery supports the Universal Declaration of Human Rights and the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization. Marrbery strives to uphold the principles set out in these declarations and expects its Suppliers to do the same. Modern slavery/human trafficking Marrbery does not tolerate any form of slavery, forced labor or human trafficking. Marrbery requires Suppliers to fully comply with applicable anti-slavery, forced labour and human trafficking laws (such as the Law of Ukraine No. 2222-IV of 08.12.2004 and the UK Modern Slavery Act 2015) and expects Suppliers to have processes in place to ensure compliance with such laws. Child labour Marrbery does not tolerate any form of child labor. Suppliers are required to operate in accordance with laws that set the minimum working age for each position, including laws relating to the hiring, work experience and internships of young people and students. Welfare, health and safety Marrbery expects Suppliers to implement sound health and safety practices throughout their operations. Human rights Marrbery does not tolerate any form of human rights abuse. Marrbery expects Suppliers to have processes in place to maintain a respectful and safe workplace environment. Marrbery expects that Suppliers will not tolerate any form of physical violence, threats, corporal punishment, psychological pressure, verbal abuse, disrespectful behavior, harassment or bullying. Labour legislation Suppliers are required to comply with all applicable local wage and labor laws. Marrbery expects Suppliers to provide employees with timely and understandable payslips containing sufficient information to confirm accurate compensation for work. Any use of temporary, piece-rate or freelance labor must comply with local law. Health and safety Suppliers are required to comply with all applicable health and safety laws and regulations. Marrbery expects Suppliers to implement measures to reduce health and safety risks, prevent accidents and provide a safe workplace for all employees. The environment Marrbery does its best to reduce the environmental impact of its operations and expects its Suppliers to do the same. Impact on the environment Suppliers are required to comply with all applicable environmental laws and regulations. Marrbery expects Suppliers to monitor the risk and impact of their activities on the environment. Marrbery Suppliers shall measure, monitor and reduce energy consumption and greenhouse gas (GHG) emissions. Where possible, Marrbery suppliers shall measure, monitor and reduce water consumption and waste as part of their operations. Compliance with the Code Violations Suppliers shall promptly notify