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Ethics Policy
At Xeros Technology Group PLC we wish to do the right things in the right way which means, at a minimum, complying with the laws in the jurisdictions where we operate. Laws to prevent bribery and corruption are important for our world as they seek to ensure that amounts paid for goods and services flow to those who truly deserve them as opposed to those that do not.
Below is our policy on Anti-Bribery and Corruption and each team member’s responsibilities thereunder.
Xeros Technology Group PLC is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings wherever we operate, implementing and enforcing effective systems to counter bribery and corruption. We will uphold all laws in all territories relevant to countering bribery and corruption, including the Bribery Act 2010. This policy applies strictly to all employees, partners, agents, consultants and contractors. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
The purpose of this policy is to:
− Set out our responsibilities and those working for us, in observing and upholding our zero-tolerance position on bribery and corruption; and
− Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues
It is a criminal offence to offer, promise, give, request or accept a bribe. Individuals found guilty by a court can be punished with up to ten years’ imprisonment, a fine or both. As an employer, if Xeros Technology Group PLC fails to prevent bribery, we can face an unlimited fine, exclusion from tendering for contracts, and damage to our reputation. We, therefore, take our legal responsibilities very seriously. In this policy, “third-party” means any individual or organisation you come into contact with during the course of your work for Xeros Technology Group PLC, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all persons working for Xeros Technology Group PLC or on the company’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located in the world.
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The policy approver is the Chief Executive Officer. The policy owner is the Commercial Director. The Compliance Manager is the HR Business Partner. The Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. If you are offered a bribe or are asked to make one, or if you believe or suspect that any bribery, corruption or other breaches of this policy has occurred or may occur, you must notify your manager as soon as possible. If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your manager or the Compliance Manager.
Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure (see Employee Handbook).
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
Any employee who breaches this policy may be subject to disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
