Code of Ethics

WPL (UK) Limited is committed to ensuring that our business is conducted in all respects according to rigorous ethical, professional and legal standards. Adherence to applicable local laws and regulations, and the application of common sense, logic and the basic standards of behaviour expected in the society we participate in, should guide each employee in determining the correct course of action that supports these standards in their daily working lives.

The standards of business conduct for WPL (UK) Limited, set out below, provide employees with guidance on their personal conduct. While it is impractical to try to cover every potential circumstance, the following descriptions of the standards are intended to assist employees. A guiding principle should be that neither WPL (UK)’s overall integrity nor its local reputation would be damaged if full details of the business practice or transaction were publicly disclosed.

Standards
Conflicts of interest
All employees should avoid situations where personal interests could conflict, or appear to conflict, with the interests of WPL. Our reputation depends not only on our high quality services but also on the manner in which we conduct our relationship with suppliers, the Police, and other organisations. Each employee must ensure that his/her conduct does not provide, or give the appearance of providing, him/her with personal gain at the expense of the Company or external business contact.

Making or receiving of illegal payments or inducements, such as bribes, are contrary to the policy of WPL (UK) and the funds and resources of WPL (UK) shall not be used directly or indirectly for any such purpose.

Compliance with laws, rules and regulations WPL (UK)’s employees must observe the laws, rules and regulations of England. If there is any doubt guidance should be sought from the Managing Director who will decide whether to obtain specific legal advice.

Protection of confidential information
No employee shall without proper authority access, modify, disclose or make use of any trade secrets, confidential commercial WPL (UK) or personal information for any purpose other than legitimately carrying out his or her duties. The obligation of confidentiality extends after employees cease working for the WPL (UK) and covers disclosure to others.

Protection and proper use of company assets
Our assets provide us with the foundation to provide our services and products worldwide.

Each employee is responsible for the protection and wise stewardship of our assets. This includes being responsible for the establishment of, and adherence to, procedures that ensure our assets are not put in jeopardy or used wastefully. Whether it is responsibility for, for example, efficient plant and office maintenance, energy conservation, security, protection of information or effective control procedures (including personal expenses), every employee must seek to use all our resources with efficiency, honesty and the highest standards of care.

All employees are prohibited from taking for themselves business opportunities that arise through the use of corporate property, information or position. This includes obtaining personal gain or competing with the Company.

Relationships with customers and suppliers
Each employee has the responsibility to ensure there are no compromises in delivering the highest standard of services and products and that every aspect of our operations which impacts upon quality promotes and reflects these standards. No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information or misrepresentation of material facts.

The giving and receiving of gifts, entertainment and gratuities between employees and suppliers or other outside business acquaintances represents a source of potential conflict of interest. Any significant gift likely to be deemed as influential upon decision-making is unacceptable.

Our employees
As employees, we should treat each other with respect, courtesy and decency. Disparagement,harassment or negative comments regarding fellow employees or business contacts are inconsistent with these standards and every employee should refrain from, and should discourage, such behaviour.

WPL (UK) is committed to offering equal employment opportunity, including access to training, development and promotion opportunities, based upon the position and each employee’s abilities, performance and commitment to these standards. Specifically, it is contrary to these standards for there to be any discrimination that contradicts WPL (UK)’s Human Resources Policy.
Each employee is to ensure that his/her conduct does not place their personal safety or the safety of others in jeopardy. This requires an active participation in maintaining a safe working environment and includes observance of established safety procedures and making recommendations for changes where they are needed. In all circumstances, including when travelling on Company business, each employee is to conduct himself/herself in a professional, mature and responsible manner at all times.

Compliance with this code and reporting of any unethical behaviour
All employees are expected to comply with the WPL (UK) Standards of Business Conduct Policy, failure to do so will result in disciplinary action being taken which in the case of serious breaches could lead to dismissal.

WPL (UK) must be made aware of failure to adhere to the above standards. The details of any concern should be reported honestly, accurately and without malice. We will respect the wishes of staff raising concerns if they ask for confidentiality, but WPL (UK) may need to act to protect its employees, clients and business. In the first instance, any concerns should be raised with the Managing Director, or any other senior person within WPL (UK) with whom the employee feels comfortable. They will either act on the information or pass it to the relevant person who can deal with it.

Employees should be satisfied that, in making a disclosure, they are acting in good faith and genuinely believe that the information and allegations are substantially true. WPL (UK) will respect the wishes of employees raising concerns if they ask for confidentiality, but WPL (UK) may need to act to protect its employees, clients and businesses. Appropriate steps will be taken to ensure that the working environment and/or working relationship are not prejudiced as a result of the disclosure.

WPL (UK) may also take advantage of the full range of disciplinary sanctions against any employee who acts or attempts to act in a way prejudicial to an employee as a result of them making a qualifying disclosure, which may ultimately result in reporting their actions to the appropriate regulatory/enforcing body.

WPL (UK) reserves the right to treat malicious or false allegations under the appropriate local disciplinary procedure.

Scope
Every employee, director and officer of WPL (UK) is expected to comply with these standards and to behave in a mature, professional and responsible manner.

Responsibilities
Any amendments to the policy must be approved by the Managing Director and disclosed.