_ETHICS
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MODERN (ANTI) SLAVERY

This Modern (Anti) Slavery Notice and Statement is intended for business in all countries, especially the United Kingdom; and is brought to you by _SIEGUS®.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. _SIEGUS® has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is integrity in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. This notice applies to all persons working for us or on our 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. This notice does not form part of any employee’s contract of employment and we may amend it at any time.

COMMITMENTS

_SIEGUS® has overall responsibility for ensuring this notice complies with our legal and ethical obligations, and that all those under our control comply with it. _SIEGUS® has primary and day-to-day responsibility for implementing this notice, 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 modern slavery.

Supervision at all levels are responsible for ensuring those reporting to them understand and comply with this notice and are given adequate and regular training on it and the issue of modern slavery in supply chains. You are invited to comment on this notice and suggest ways in which it may be improved. Comments, suggestions and queries are encouraged and should be addressed to the Leadership Team.

COMPLIANCE

You must ensure that you read, understand and comply with this notice. The prevention, detection and reporting of modern slavery in any part of our business or supplychains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this notice. You must notify your line supervisor as soon as possible if you believe or suspect that a conflict with this notice has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this notice has occurred or that it may occur, you must notify your line supervisor or report it in accordance with our Complaints and Whistleblowing Guidelines as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line supervisor.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this notice, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

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 your line supervisor immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found here.

COMMUNICATION & AWARENESS OF THIS NOTICE

Training on this notice, and on the risk our organisation faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS NOTICE

Any employee who breaches this notice will face 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 notice.

CODE OF ETHICS
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Our professional code of ethics notice aims to give our employees guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgment, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act (e.g. in cases of conflict of interest). We will also use this notice to outline the consequences of violating our business code of ethics.

SCOPE

This notice applies to everyone we employ or have business relations with. This includes individual people such as employees, interns, volunteers, but also business entities, such as vendors, enterprise customers or venture capital companies. Note that our code of ethics is slightly different than our code of conduct. Code of conduct may include elements such as dress code and social media use, whilst our code of professional ethics refers to legally or morally charged issues. Still, these two codes do overlap.

DEFINITIONS

What is meant by a code of professional ethics? First, let’s define professional ethics: they are a set of principles that guide the behavior of people in a business context. They are essential to maintaining the legality of business and a healthy workplace.

So what is a code of ethics? Our code of ethics definition refers to the standards that apply to a specific setting — in this case, our own organisation.

What is the purpose of a professional code of ethics? Having our business ethics in writing doesn’t mean that we don’t trust our employees. We strive to hire ethical people who have their own personal standards, so we expect that a written code won’t be necessary most of the time. But, it can still be helpful. You may find yourself in a situation where you’re not sure how you should act. Life is full of grey areas where right and wrong aren’t so apparent. Some professional ethics also correspond to laws that you absolutely must know to do your job properly, so they will be mentioned in the organisation's code of ethics as well as other guidelines and notices.

Additionally, every organisation makes bad hires every once in a while. We also can’t predict how people are going to behave. When an employee behaves, or intents to behave, in a way that’s against our professional ethics, or applicable laws, we will have clear guidelines on what disciplinary actions we will consider. For these reasons, we advise you to read this document carefully and consult with your supervisor or HR, if you have doubts or questions. The components of our code of professional ethics:

We base our organisation's code of ethics on common principles of ethics:

● Respect for others. Treat people as you want to be treated.

● Integrity and honesty. Tell the truth and avoid any wrongdoing to the best of your ability.

● Justice. Make sure you’re objective and fair and don’t disadvantage others.

● Lawfulness. Know and follow the law — always.

● Competence and accountability. Work hard and be responsible for your work.

● Teamwork. Collaborate and ask for help.

Here’s a more detailed overview of each component:

RESPECT FOR OTHERS

It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence is strictly prohibited and will result in immediate termination. You’re also not allowed to harass or victimise others.

What constitutes harassment or victimisation?

To answer this, we have a notice on harassment and a more specific notice on sexual harassment you can take a look at. As a general rule, try to put yourself in someone else’s place. How would you feel if someone behaved a specific way to you? If the answer is “I wouldn’t like it much” or “I would never let them behave like that to me”, then we don’t tolerate this behavior no matter the person it comes from.

If someone, be it customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to HR or your supervisor. You can also report rudeness and dismissiveness if they become excessive or frequent.

INTEGRITY AND HONESTY

First, always keep in mind our organisation’s mission. We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organisational. Be honest when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags and, if you’re discovered, you may face progressive discipline or immediate termination depending on the damage you did. Stealing from the organisation or other people is illegal. If you’re caught, you will face repercussions depending on the severity of your actions. The decision is at HR’s discretion on a case-by-case basis.

CONFLICT OF INTEREST

Conflict of interest may occur whenever your interest in a particular subject leads you to actions, activities or relationships that may undermine our organisation. If it turns out you have created a conflict of interest for yourself, your contract may be terminated. If the conflict of interest was involuntary (e.g. buying stocks from a company without knowing they’re a competitor), we will take actions to rectify the situation. If you repeat the offence, your contract may be terminated.

JUSTICE

Don’t act in a way that exploits others, their hard work or their mistakes. Give everyone equal opportunity and speak up when someone else doesn’t. Be objective when making decisions that can affect other people, including when you’re deciding to hire, promote or fire someone. Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example, when interviewing candidates, ask the same interview questions to all of them and avoid judging non-job-related criteria, like dress, appearance, etc. Also, don’t discriminate against people with protected characteristics, as this is forbidden by [laws under the purview of the EEOC]. If you suspect you may have an unconscious bias that influences your decisions (taking Harvard’s Implicit Association Test could help you determine this), ask for help from HR. When exercising authority, be fair. Don’t show favouritism toward specific employees and be honest when you decide to praise or reward an employee. You’re also obliged to follow our employment of relatives notice, which forbids you from having a reporting relationship with a relative. If you need to discipline an employee, be sure to have prepared a case that you can present to HR. You must not retaliate against employees or applicants (such as in cases when they’ve filed complaints) as this is forbidden by law. Be just toward customers or vendors, too. If you think our organisation was in the wrong in a specific instance, don’t try to cover it up or accuse the other side. Discuss with your supervisor to find objective solutions for all sides/parties involved.

LAWFULNESS

You are obliged to follow all laws which apply to our organisation. Depending on your role and profession, there might be various laws you need to observe. For example, accountants and medical professionals have their own legal restrictions and they must be fully aware of them. When you’re preparing contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), seek verification from [our legal counsel] before finalising anything. You’re also covered by our confidentiality and data protection notice. You must not expose, disclose or endanger information of customers, employees, stakeholders or our business. Always follow our cybersecurity notice, too. Following laws regarding fraud, bribery, corruption and any kind of assault is a given. You are also obliged to follow laws on child labour and avoid doing business with unlawful organisations. If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.

COMPETENCE AND ACCOUNTABILITY

We all need to put a healthy amount of effort in our work. Not just because we’re all responsible for the organisation’s success, but also because slacking off affects our colleagues. Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles. We also expect you to take up opportunities for learning and development, either on-the-job or via educational material or training. If you are unsure how you can achieve this, have an open discussion with your supervisor. Also, take responsibility for your actions. We all make mistakes or need to make tough decisions and it’s important we own up to them. Failing to be accountable on a regular basis or in important situations (e.g. a crucial mistake in our financial records) will result in termination. If you take responsibility and come up with ways to fix your mistakes where possible, you will be in a far better position.

TEAMWORK

Working well with others is a virtue, rather than an obligation. You will certainly get to work autonomously and be focused on your own projects and responsibilities. But, you should also be ready to collaborate with and help others. Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.

SIEGUS®