FASTLEANSMART UK LTD.
ETHICAL CONDUCT POLICY
In line with our transparent business operations, we provide the following extracts from our Ethical Conduct Policy. This is in addition to our ISO certifications. Please contact us for the full policy document.
CONTENTS
INTRODUCTION
At FASTLEANSMART UK LTD. we are committed to doing the right thing in all aspects of our business. This requires that every day everyone working for us needs to have an unwavering dedication to the highest ethical standards. It is fundamental that every employee and worker carries a share of the responsibility for our conduct and contributes to our success.
Our culture is built on four key values. These shape our behaviour toward customers and toward one another. Together, they drive our organisation forward. The values are:
INTEGRITY
We demand of each other and ourselves the highest standards of individual and corporate integrity. We do the right thing, because it is the right thing to do. It is every employee’s responsibility to safeguard organisation assets and foster an environment of trust with our -workers, customers, communities, and suppliers. We should always comply with all our organisation policies, meet legal requirements, and create an environment of transparency in which all reporting requirements are met.
EXCELLENCE
We routinely challenge ourselves to improve our products, services, and processes. We strive always to understand our customers’ businesses and help them achieve their goals. We serve our customers by anticipating and responding to their needs. We are dedicated to diversity, fair treatment, mutual respect, and trust. We are committed to producing products and serving our customers with zero harm to people and the environment.
TEAMWORK
We foster an environment that encourages innovation and creativity and delivers results through collaboration. We practice leadership that teaches, inspires, and promotes full participation and career development. We encourage open and effective communications and interaction with all workers and stakeholders, actively working together to keep each other safe and in good health. We believe that none of us is as capable or effective as all of us – and together, there's no limit to what we can achieve.
ACCOUNTABILITY
We honour the commitments we make and take personal responsibility for all actions and results. Our actions match our words, and we demand responsibility – from ourselves and others – in everything we do. We operate on the basis that continuous improvement is an integral part of our culture.
Regardless of our position within the organisation, we share equal accountability for:
Our culture is built on four key values. These shape our behaviour toward customers and toward one another. Together, they drive our organisation forward. The values are:
INTEGRITY
We demand of each other and ourselves the highest standards of individual and corporate integrity. We do the right thing, because it is the right thing to do. It is every employee’s responsibility to safeguard organisation assets and foster an environment of trust with our -workers, customers, communities, and suppliers. We should always comply with all our organisation policies, meet legal requirements, and create an environment of transparency in which all reporting requirements are met.
EXCELLENCE
We routinely challenge ourselves to improve our products, services, and processes. We strive always to understand our customers’ businesses and help them achieve their goals. We serve our customers by anticipating and responding to their needs. We are dedicated to diversity, fair treatment, mutual respect, and trust. We are committed to producing products and serving our customers with zero harm to people and the environment.
TEAMWORK
We foster an environment that encourages innovation and creativity and delivers results through collaboration. We practice leadership that teaches, inspires, and promotes full participation and career development. We encourage open and effective communications and interaction with all workers and stakeholders, actively working together to keep each other safe and in good health. We believe that none of us is as capable or effective as all of us – and together, there's no limit to what we can achieve.
ACCOUNTABILITY
We honour the commitments we make and take personal responsibility for all actions and results. Our actions match our words, and we demand responsibility – from ourselves and others – in everything we do. We operate on the basis that continuous improvement is an integral part of our culture.
Regardless of our position within the organisation, we share equal accountability for:
- Conducting business with integrity, preserving our strong reputation and expanding our position in the marketplace.
- Fostering an inclusive culture in which we all feel respected and can reach our full potential.
- Providing a healthy and safe work environment and complying with applicable environmental laws and regulations wherever we operate around the world contributing to the sustainability of the communities in which we live and work.
MODERN SLAVERY STATEMENT
ORGANISATION
This statement applies to FASTLEANSMART UK LTD. (referred to in this statement as 'the Organisation'). The information included in the statement refers to the financial year 2021.
ORGANISATIONAL STRUCTURE
The organisation Head Office is based in Theale with a secondary location in Warrington in United Kingdom. Both locations are virtual offices and used by the business on an as and when required basis. All employees are home based, working across 3 departments, Sales & Marketing, Projects, and Support. The main activity of the organisation is the sale and delivery of software and services direct to customers or via our partner network. The demand for the product is consistent through the year and is therefore not seasonal. The labour supplied to the Organisation in pursuance of its operation is carried out in primarily the United Kingdom, although depending on the requirements of the customers project work may be required in other countries.
DEFINITIONS
The Organisation considers that modern slavery encompasses:
- Human trafficking
- Forced work, through mental or physical threat
- Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
- Being dehumanised, treated as a commodity, or being bought or sold as property
- Being physically constrained or to have restriction placed on freedom of movement
COMMITMENT
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains. The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in United Kingdom, and in many cases exceeds those minimums in relation to its employees
SUPPLY CHAINS
To fulfil its activities, the Organisation’s main supply chains include those related to the supply of software and services from Germany, the developers of the software.
POTENTIAL EXPOSURE
The Organisation considers its only exposure to the risk of slavery and human trafficking to exist in Germany. In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
STEPS
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers. The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
- measures in place to identify and assess the potential risks in its supply chains
- any actions taken to embed a zero-tolerance policy towards modern slavery
KEY PERFORMANCE INDICATORS
We have introduced the following key performance indicators (KPIs) in response to the introduction of the Modern Slavery Act 2015. The indicators and activities are reviewed at least annually.
- Supplier engagement:
- 100% of our suppliers to have agreed to the supplier code of conduct.
- 100% of new suppliers have undergone a sustainability assessment during the on boarding process.
- Modern Slavery Training:
- Ensure that 100% of all inductions introduce employees to the topic of modern slavery.
POLICIES
Our Ethical code of Practice includes further references to our stance on Modern Slavery.
TRAINING
The Organisation provides training to staff on induction to effectively implement its stance on modern slavery.
SLAVERY COMPLIANCE OFFICER
The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action regarding the Organisation obligations in this regard. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
CHILD LABOUR
The Company will ensure that all relevant legislation and restrictions are adhered to regarding the use of young workers. We will ensure that the necessary checks are carried out to verify an individual’s age and right to work, and that relevant Health and Safety codes are adhered to. Where required, the Company will ensure that the relevant employment permit is received from the education department of the local council. We will also carry out spot checks when required and will retain copies of age records within the place of work.
ANTI-BRIBERY POLICY
INTRODUCTION
Bribery is, in the conduct of the organisation's business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust. Bribery is a criminal offence.
The Organisation prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by FASTLEANSMART UK LTD. employees or by third parties acting for or on behalf of FASTLEANSMART UK LTD.
OFFENCES
It is a criminal offence to:
- offer a bribe
- accept a bribe
- bribe a foreign official
- as a commercial organisation, to fail to prevent a bribe
You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Organisation could also face prosecution and be liable to pay a fine.
PURPOSE
The purpose of this policy is to convey to all employees and interested parties of FastLeanSmart UK Ltd the rules of the Organisation in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that FastLeanSmart UK Ltd conducts its business in a fair, professional and legal manner.
DEFINITIONS OF BRIBERY AND CORRUPTION
Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business:
- Giving or receiving money, gifts, meals, entertainment, or anything else of value.
- As an inducement to a person to do something which is dishonest or illegal.
SCOPE
This policy applies to all employees of FastLeanSmart UK Ltd, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement. We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers; contractors.
POLICY
It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or organisation in order to gain commercial, contractual or regulatory advantage for the Organisation, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
It is also prohibited to act in the above manner to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official. If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact a member of the Senior Management Team so that action can be taken if considered necessary. You may be asked to give a written account of events. If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to a member of the Management Team . You may be asked to give a written account of events.
Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules. The Organisation will ensure that all its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately. FASTLEANSMART UK LTD. takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.
We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc. Staff are reminded of the Organisation’s Whistleblowing policy, which is included in this code of practice.
GIFTS AND HOSPITALITY
We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.
- Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.
- Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.
No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a member of the Management Team. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from a member of the Management Team. A record will be made of every instance in which gifts or hospitality are given or received. As the law is constantly changing, this policy is subject to review and the Organisation reserves the right to amend this policy without prior notice.
ANTI-TAX EVASION POLICY
INTRODUCTION
Tax evasion is a criminal offence. The Organisation prohibits any form of tax evasion. Involvement in the criminal facilitation of tax evasion exposes the Organisation and the person facilitating the evasion to a criminal offence. It will also damage our reputation and the confidence of our customers, suppliers, and business partners.
Indicators of tax evasion are:
- request for payment by cash
- overly complex payment mechanisms
- services/goods provided to jurisdictions that do not subscribe to Common Reporting Standards
- transactions involving overly complex supply chains
- transactions involving private banking facilities and/or
- records are incomplete or missing.
Our position is simple: we conduct our business to the highest legal and ethical standards. We will not be party to tax evasion or the facilitation of tax evasion of any form. Such acts would damage our reputation and expose us, and our staff and representatives, to the risk of fines and imprisonment.
We take a zero-tolerance approach to tax evasion facilitation by our people and our third-party representatives.
We are committed to:
- rejecting the facilitation of tax evasion; and
- not recommending the services of others who do not have reasonable prevention procedures in place.
We require compliance regarding this from everyone connected with our business. Integrity and transparency are of utmost importance to us.
DEFINITIONS OF TAX EVASION
Tax evasion is the practice of using illegal methods to avoid paying tax. It frequently involves contrived; artificial transactions that serve no purpose other than to reduce tax liability.
POLICY
It is prohibited, directly or indirectly, for any employee or person working on our behalf to take part in any activity relating to tax evasion. If we suspect that you have taken part in such activity, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against you which may result in your dismissal, or the cessation of our business arrangement with you.
If you, as an employee or person working on our behalf, suspect any activity related to tax evasion or attempted tax evasion has taken place, even if you are not personally involved, you are expected to report this to a member of the Management Team. You may be asked to give a written account of events.
TRAINING/MONITORING/REVIEW
The Organisation will ensure that it gives all relevant training for staff in relation to financial crime detection and prevention, it will ensure it monitors and enforces compliance with the prevention procedures and regularly review the effectiveness of prevention procedures, refining them where necessary.
CONCERNS
Staff are reminded of the Organisation's Whistleblowing policy, which is included in the full code of practice.
CORPORATE RESPONSIBILITY POLICY
DEFINITION
Corporate Social Responsibility (CSR) is a concept whereby an organisation recognises that its business operations and processes may have an impact on social, economic, and environmental issues outside of the workplace. It also represents a commitment to ensuring and maintaining socially responsible behaviour in an organisation.
OBJECTIVE
We seek to sustain a business that is successful and respected in its ethical standing by our stakeholders. These include customers, clients, investors, regulators, suppliers, and the community. We embrace the role our business plays on a day to day basis in contributing to a better society.
POLICY
We are aware that the running of our business will, in many ways, affect our place of work, the community and the wider environment in which we operate. We believe that the way we run our business can and should make a positive difference in these areas and we aim to ensure that continued efforts are made to achieve that.
Our corporate social responsibilities are identifiable in the following areas:
Environment
Regarding the business' impact upon the environment, we are committed, amongst other initiatives, to:
- efficient printing
- reducing the amount of waste produced by the business
- ensuring that water/electricity is used responsibly by our staff
- recycling materials as extensively as possible
- using technology to lessen the need for travel
- using public transport wherever possible when travelling is unavoidable
Charitable/community work
Our organisation is keen to support and become involved in community initiatives and charitable work. We do this in the form of sponsorship, donations to national and local charities which may be suggested by our staff, and the funding of community projects. Every suggestion is given due consideration.
Education
We recognise the importance of education in our community and supporting individuals during this process is key to advancement. We actively encourage our employees to take up training courses, often funded by ourselves.
Our employees
Involvement: We keep our staff fully informed of our policies and procedures and we encourage them to share their ideas with us on both internal processes affecting them, and the way our service is provided to customers/clients. We maintain an open and honest approach to all our communications.
Equal Opportunities
We are committed to providing an environment of equal opportunities for all members of our workforce. No account of any of the protected characteristics set out in the Equality Act 2010 shall be taken to a detrimental effect in any decision involving recruitment, promotion, provision of facilities etc. See our Equality and Diversity Policy for more detail in this regard.
Business partnerships
We will strive to engage with local suppliers and businesses where possible to meet the business’ operational needs, supporting businesses within our area and decrease our carbon footprint. In respect of our entire CSR initiative, we expect no lesser standards from our suppliers and business partners.
ONGOING COMMITMENT
We are fully committed to the principle of CSR and aim to ensure that no relevant policy decisions are made within the business, without first evaluating the potential CSR impact.
This policy is reviewed on an annual basis.