Code of Conduct

Code Of Conduct

We believe that acceptable standards of behaviour are necessary to ensure orderly and efficient conduct of the Company’s business, to maintain good order and discipline and to ensure the safety of employees and Company property.

This Code of Conduct applies to all employees and/or contractors/sub-contractors who work for the Gough Group. A condition of employment and/or engagement is that you agree to abide by the Company's Code of Conduct.

ETHICAL COMPLIANCE

Our whole organisation will, at all times, operate in the most ethical manner. We will not operate in an illegal way, we will always honour our commitments and we will treat all stakeholders associated with our organisation with respect and honesty.

Our employees must maintain the highest ethical and legal standards in all their dealings. Only lawful, honest, accurate and ethical behaviour will safeguard the Company's interests, stated policies and reputation. An important basic principle is that the Company expects employees to be honest with their supervisor, customers, outside contacts and fellow employees. If you need any interpretation or clarification of legal or regulatory requirements, consult with senior management or, under direction, our legal advisors.

We will not undertake or condone any action which contravenes the law. No employee shall commit an illegal act or direct other employees to commit such an act and it will not be an acceptable argument of justification for such an action by alleging it was directed by management. No employee, manager or otherwise, has delegated authority to order or to condone any illegal activity.

No employee will make false, incomplete or misleading entries, nor will undisclosed or unrecorded funds be established for any purpose. No funds are to be placed in any personal or non-corporate accounts. Assets must be properly protected and asset records regularly compared to actual assets.

Stated policies, by themselves, will neither secure Goughs reputation nor guarantee integrity. What does make a difference is for all employees and others who represent us to adhere to the above philosophy on a continuous basis.

PERSONAL BEHAVIOUR

We operate in a competitive industry where business is won or lost on the basis of quality, service and efficiency. You are expected to behave in a socially acceptable manner while at work. This covers such things as:

Making sure you don't offend anyone by using bad language.

Being careful over personal hygiene.

Being generally pleasant.

You are expected to display appropriate levels of professionalism and competence when doing your work. Your personal behaviour should be in a manner that is compatible with the Company’s values. When dealing with suppliers or customers, respond to questions and concerns promptly and politely. We expect you to treat other Company employees as internal customers and behave in a way that supports the Company's public image.

As with our Ethical Compliance stance, we expect you to always act professionally with whom you come into contact. We expect you to treat with respect all individuals, including your fellow staff members and members of other organisations. You must not act in a manner that is threatening or offensive, or personally, culturally or sexually defaming.

We subscribe totally to being non-prejudiced across all society. We will not tolerate discrimination based on race, culture, gender, age, physical ability or sexuality.

We do not subscribe to, nor will we tolerate, sexual harassment of any kind. We have zero tolerance of any form or perceived form of sexual harassment. Material or conversation of any sexual nature in any form has no place in our organisation.

All employees have a right and a responsibility to speak up and bring it to the attention of their supervisor/manager if they feel that our code of behaviour is being contravened.

The personal behaviour of employees, on and off the job, should never draw adverse reaction or comment from the public. As a representative of the Company, you are personally responsible for maintaining the good reputation of The Gough Group.

HEALTH, SAFETY AND WELL BEING

We are committed to ensuring that employees, and those who work with us, do so in a safe environment, where their personal safety and health is not at risk. Working safely is a condition of employment. We strive to ensure through sound practices that the safety, health and well being of all staff is positive and we encourage you to be proactive at work and in your own lifestyle. Our specific Health and Safety policies are detailed in a separate Health and Safety Handbook. A more comprehensive Health and Safety Manual is held at each Branch.

ENVIRONMENT POLICY

The Gough Group is committed to minimising any negative effects and to maximising any positive effects on the environment. Our endeavour is to improve the long-term environment for future generations. If you become aware of any damage to, or potential damage that may affect, the environment, you must immediately report the matter to the Company.

CONFLICT OF INTEREST

While employed by the Company you are expected to devote all your energy to your position and to remain free of interests or relationships which are, or may appear to be, harmful or detrimental to the Company’s best interests.

Any interest which benefits you commercially either directly or indirectly outside of your employment, may be a conflict of interest. Situations which may give rise to a conflict of interest may include, but are not limited to:

Accepting payments, goods or services from suppliers, contractors or any other company or person with which or whom we do business, from which you will benefit.
Accepting gifts or gratuities from suppliers or contractors which may cause you to give them advantage over their competitors. Commercial processes must be adhered to.
Ownership of or an interest in any supplier or contractor to us or a similar business which would cause you to make less than sound commercial decisions for us.
The use of inside information which may disadvantage us in any way.

You are urged to discuss with your Manager any possible conflicts of interest or to declare in writing your conflict of interest as soon as you become aware of it. Failure to advise of any such situation may put your employment or engagement in jeopardy.

SECONDARY EMPLOYMENT / ENGAGEMENT

We prefer that while you are working with us you put your energy into carrying out your job in the most efficient manner. If you wish to work in secondary employment or undertake a secondary engagement, you must first discuss this with your Manager who will fairly review any request to undertake outside work and may require more senior approval.

Consent will not unreasonably be withheld, however we reserve the right to request your resignation from the secondary employment or termination from the secondary engagement.

RELATIONSHIPS AND COLLUSION

At all times we expect you to maintain professional relationships with other staff, key clients and suppliers.

You have a responsibility to advise your Manager if your partner or relative or person living at the same address is an employee of the Gough Group or any other Company where there is a risk of collusion or confidential information being shared, even by accident, to the detriment of either us or our customers or suppliers.

The Company may place any necessary and reasonable restrictions on your employment (including terminating your employment) if you are married to, living with or are a relative of a person who is employed by the Gough Group or a competitor. Restrictions or termination of your employment will only be imposed if there is a risk of collusion between you and the other person that may harm us or if there is a risk of disclosure of confidential information to that person, even by accident.

We consider it is in the best interests of the Company and yourself that you advise your Manager if you enter a relationship with another employee within the Group. In particular, relationships where a senior manager is involved can create problems.

We reserve the right not to employ a relative, spouse or partner within the group. We neither discourage nor encourage employment of relatives of existing employees, however we do encourage the selection of “best person” or “best skills match” for the job.

It is not possible to recruit a person into the same department and/or to report to the same supervisor or manager as a relative or partner of that person. It is the obligation of all employees to declare any relationships of this nature at the time an appointment is being made.

CONFIDENTIALITY

Protecting the Company’s proprietary information, technology, research, confidential data, brands and image against misuse, loss or theft is of vital importance. We also have an obligation to respect distributor/client information that is disclosed during the course of business.

It is the responsibility of all employees to ensure that information relating to

Customer transactions
The Gough Group of Companies’ business records and information
Our operations, the way we provide our goods and services, profits and projections
Staff numbers, salary information, terms of employment and information pertaining to other employees

is held in strict confidence and is not discussed or disclosed to any other party without the prior agreement of either the Senior Manager or Chief Executive Officer / Group Chief Financial Officer. The basic rule is information that is not clearly in the public domain should not be released without authorisation.

Being indiscreet is a serious matter. You will certainly face disciplinary action or even dismissal.

All employees have a responsibility to maintain confidentiality beyond their period of employment with us. You have a legal obligation not to disclose confidential information at any time after you have left your employment with the Gough Group.

Shredding or contracted secure disposal should be used to properly destroy obsolete or otherwise superseded documents which deal with confidential or sensitive information.

USE OF COMPANY PROPERTY

Company equipment is intended for use on the job and should not be used for personal purposes without approval. This includes office telephones, computers, technical equipment and other equipment and facilities. If you feel you have a need to use an item of company equipment for personal purposes, you must seek clear approval from your supervisor or manager prior to the use. This is especially important where there are safety factors to be considered.

All documents, business equipment, company software, manuals and other materials supplied to you or accessed by you during the course of your employment remain the property of the Company. They must be returned to us when you cease your employment with us.

You must protect the Company's property and revenues. This includes all kinds of property belonging to or leased to the Company, from telephones and other plant and equipment, to motor vehicles, tools, office supplies, cash, securities, taxi chits, intellectual property, data and software.

If equipment has to be left at a work site, it is important to ensure that precautions are taken to render any material and equipment safe from theft and damage. Equipment and supplies are not to be borrowed or (no matter how old or in what condition) given away, loaned, sold, abandoned or destroyed without specific authorisation from management.

If you fail to take reasonable care of Company property the Company reserves the right to recover damages, including from your personal resources.

Items of equipment and supplies that are the property of the Company may be loaned to employees for their personal use outside of the premises. Such equipment loans must have the prior approval of your manager and will be recorded and made subject to certain conditions to comply with tax and other regulations.

The taking of equipment and supplies without prior approval may result in disciplinary action.

ELECTRONIC COMMUNICATION (See also Computer Policies)

The Company provides internal and external email, facsimile, phone and internet facilities as part of its operational environment. These facilities are provided to assist employees in carrying out their business functions. All Company policies and procedures concerning work-related activities apply equally to the use of electronic means of communication. In particular you should not assume that your email communications will be confidential.

We have an obligation to ensure that the work place is free from sexual and other harassment, offensive material, improper communications and other unlawful behaviour. If we become aware that electronic communications are being used for unlawful, offensive or improper activities, we may take appropriate action to deal with this. For avoidance of doubt, improper activities extend to the sending of texts and images on cellphones.

Occasional personal use of electronic communications is permitted as long as this does not interfere with normal business use or the performance of your job. It should be noted however that all information transmitted through or stored within our computer systems is deemed to be the property of the Company and is subject to management control and review. Data stored on the network should be for business use only. We have a policy of monitoring your emails and internet site access and we reserve the right to restrict or deny access to internet sites.

EXTERNAL RELATIONSHIPS

The Company is committed to the establishment of a continuing ethical business relationship with its customers, suppliers and agents/representatives. The reliability of the Company and its employees will be judged by how people conduct themselves within these relationships, both on and off the job.

During the conduct of business you are expected to:

Never make promises the Company cannot or does not intend to keep.
Never make commitments on behalf of the Company which you are not authorised to make.
Limit entertainment to that which is deemed reasonable, customary and necessary to facilitate business discussions.
Never make false, misleading or disparaging remarks to customers, suppliers and agents/representatives or prospective customers.
Respect the confidentiality of any sensitive information given in confidence.
Not, directly or indirectly, offer benefits or rewards in violation of laws, regulations or responsible and ethical business practice.
Provide small gifts to customers only when this is in line with generally accepted business practice and does not give rise to conflicts of interest.
Not accept gratuities such as gifts, favours, money, loans, vacations, travel or hotel accommodation from suppliers or potential suppliers, except promotional items of a nominal value or moderately-scaled entertainment within the limits of prudence and ethical conduct.
Negotiate supply contracts to meet the Company's technical and financial requirements and not accept inferior substitute material or equipment which may be commercially or administratively expedient.
Not allow personal bias to influence the selection or rejection of a particular supplier, product or service.
Carefully select agents and representatives and ensure that the relationship is formalised by written contract. Thereafter, their activities are to be monitored as closely as possible to ensure that all such activities are in accordance with relevant laws and regulations.

WORKING ON CUSTOMER PREMISES

The Company’s activities will often involve visits to a customer's place of business. We wish to establish and maintain an enviable reputation for honesty, integrity, courtesy and respect for the property of others and, in the process, establish lasting goodwill.

Nothing should be removed, used or borrowed without the customer's permission. The customer's premises should be left as they were found, with no after-service debris remaining.

You should, when working on a customer's premises, take all reasonable care to ensure that no loss or damage occurs because the Company may incur liability in a civil proceeding if it can be established that there was gross negligence or fault causing damage. If damage does occur, you should notify your manager and the customer and repair or pay for repairs to restore to a reasonable condition.

We ask that you make yourself familiar with the customer’s Health and Safety Policies and Procedures and comply with these.

It is the duty of all employees to respect a customer's privacy and to treat as strictly confidential any personal or business information about a customer that may come to your attention. This applies to both oral and written information belonging to a customer, whether it is obtained on our premises or on a customer's premises.

MISCONDUCT AND SERIOUS MISCONDUCT

Misconduct

The following will be considered misconduct which may, after appropriate investigation, result in the appropriate warning procedure being followed. Misconduct may include, but is not limited to:

Failure to comply with the Company’s Policies, Procedures and Practices.
Falsification of company records, including the completion of time-keeping or payroll records.
Failure to advise as soon as practicable of any absence for which prior permission has not been obtained.
Refusal to perform a reasonable request to work or to follow lawful instructions or leaving an assigned work place without good reason.
Abusive or unacceptable behaviour causing offence to other people while on Company premises or while you are on Company business or at a function representing the Company.
Putting offensive notices within Company premises, on notice boards or defacing Company notices or instructions, wilful waste of time or materials, lack of application to an assigned task, interfering with or preventing another employee from carrying out their work function.
Boisterous play, disorderly conduct.
Misuse, abuse or unauthorised use of Company property.
Misuse of Company purchase schemes.

Serious Misconduct

The following constitute a breach of the house rules and may, after appropriate investigation, be considered serious misconduct liable to instant dismissal. Serious Misconduct may include, but is not limited to:

Conviction of a crime or indictable offence.
Failure to comply with the Company’s health and safety rules and procedures including notification of hazards, and the wearing of and use of safety protection equipment or protective clothing or failing to follow lawful instructions in regard to health and safety.
Failure to report accidents, personal injury or damage to Company property or damage caused while on Company business.
Failure to comply with Operating Procedures to the detriment of the Company.
Misleading, reckless or negligent conduct in the performance of duties, including withholding or misreporting of critical information.
Victimisation or harassment in the workplace.
The possession or consumption of illegal drugs and/or alcohol on Company premises during working hours or whilst on Company business or being under the influence of illegal drugs and/or alcohol to the extent that the individual is unable to properly or safely perform his/her duties.
Using abusive or obscene language during the course of business, including direct verbal/written abuse of a supervisor/manager.
Dishonesty including theft, unauthorised possession of, use, lending of, removal of or deliberate damage to the property/vehicles of the Company or other employees, contractor or customer or negligence in the use of property, falsification of Company records, supplying false information, cheating or lying.
Falsification of or inappropriate use of expense privileges, including misuse of Company credit cards or purchase cards.
Falsification of pre-employment information used in the hiring decision.
Fighting or physical assault while on Company premises/property or during working hours or in connection with matters arising out of your employment, (including Company social occasions). This includes any conduct, which could jeopardise safety or health (including horseplay).
Failure to comply with the Company’s computer and cellphone policies, including unauthorised or inappropriate use of email, internet and text messaging.
Leaving an assigned work place without authority or due cause where safety or security is then put at risk.
Misuse of Confidential information.
Engaging in other activities that create a conflict of interest.
Release of Cash Sales/Liens without following proper procedure.
Misrepresenting the Company for personal gain or profit.
Personal behaviour outside of work which adversely affects the organisation in its business dealings.
Failure to comply with the Company’s Code of Conduct policies. This includes failure to notify possible Conflict of Interest, Collusion and breaches of confidentiality.
Unauthorised or unreasonable use of a company vehicle.
Illegal gambling during working hours.
Unauthorised carriage or possession of firearms on Company premises or property.
Any serious breach of normally accepted rules and standards of behaviour, whether defined in writing or not.
Any false assertion against the Company or any employee, particularly in regard to compliance with legislation.

DELEGATED AUTHORITY

The Company has policies and practices which define the authority levels within which managers and staff may operate. They cover who can act on the Company’s behalf in certain circumstances and will cover areas such as Employment, Termination, Capital Expenditure, Contracts, Purchasing, Credit Authorisation, Payment of Suppliers, Expenses, Media and Press Releases and Sponsorship.

You should be clear on your delegated authority. If you are not sure of your level of authority, please talk to your manager.

CONCLUSION

Any deviation from the code of conduct may result in disciplinary action varying from reprimand to dismissal depending on the magnitude of the offence and the impact, actual or assessed, on the Company’s activities.