Professional Documents
Culture Documents
OUR CODE
OF CONDUCT
2
Chris Weston
April 2019
3
CONTENTS
04 Our values and behaviours 20 Our people and assets
05 What is the Code of Conduct? 20 Respect
21 Human Rights
06 Who is the Code of Conduct for? 22 Protecting Aggreko’s assets
07 Speaking up 23 Data privacy
08 Health, Safety and the Environment 24 Confidential information
08 Keeping Team Aggreko safe 25 Keeping our people and assets secure
09 The environment 26 IT systems
10 Ethics
10 Conflicts of interest
11 Fraud
12 Anti-bribery and corruption
13 Gifts, entertainment and hospitality
14 Charitable donations and sponsorship
15 Using third party sales representatives
16 Tax evasion
17 Fair competition
18 Sanctions and trade restrictions
19 Political activity
4
BE DYNAMIC BE EXPERT
OUR VALUES AND
BEHAVIOURS
Using our entrepreneurial Using our blend of experience,
passion to deliver and making expertise and planning to keep
great things happen. us ahead of the game.
We do We don’t We do We don’t
BE INNOVATIVE BE TOGETHER
Learning from the world for Asking the best of each other,
a better today and for great harnessing our scale and diverse
leaps tomorrow. skills to grow stronger together.
We do We don’t We do We don’t
The environment
We do: We love to use our expertise to take care
QW
hen re-fuelling a
– know the environmental requirements of the environment around us. We use
that apply to us generator the fuel pump
resources efficiently and work hard to breaks and spills diesel.
– report any potential environmental minimise the environmental impact of What should I do?
risks or incidents
the things we do. We always comply
– use the most efficient processes with the environmental standards and AY
ou should stop
and technologies to make the most work and immediately
of our resources.
procedures and any relevant laws and follow our fuel spill
regulations on our sites. response plan. Fuel
We don’t: spills can be dangerous
For further guidance read our
– work without the necessary and can have a lasting
Group Environmental Policy.
environmental authorisations detrimental impact on
or permits. the environment if not
dealt with appropriately.
For that reason it is
important that you stop
working and deal with it
immediately and report
the spill.
QH
ow can I do my
bit to protect the
environment?
AW
e can all make a
difference. Simple things
like turning off the lights,
minimising printing
and business travel can
all help to reduce our
environmental impact.
DO’S AND DONT’S ETHICS 10
Conflicts of interest
We do: We all have a duty to make decisions QC
an I help a friend
– act in Aggreko’s best interests that are in the best interests of Aggreko. to apply for a job
– make sure we are fair and impartial That means we should avoid situations in Aggreko?
in all business dealings where our personal interests could
– disclose any financial interests or potentially compromise our judgement AY
ou can advise your
connections we (or our family members) friend how to apply for a
or independence. This could arise if vacancy and direct them
have with any competitors, business
partners, customers or suppliers.
you or a family member has a personal to the right member of
relationship or financial interest with a Team Aggreko, but you
We don’t: can’t be involved in or
customer, supplier, business partner or have any influence on
– use our Aggreko contacts or positions competitor of Aggreko. If you believe any hiring decisions.
to advance our personal interests there’s a potential conflict of interest
– hide or fail to disclose any actual talk to your manager or the Head of
or potential conflict of interest.
Compliance right away. They’ll help Q My sister works at a
you protect yourself and the business. company currently
bidding for work with
Aggreko. Can I be
involved in this tender?
A Your personal
relationship with this
potential supplier could
compromise your
judgement. You should
speak to your manager
who will help you to
manage this conflict
of interest.
DO’S AND DONT’S ETHICS 11
Fraud
We do: Aggreko is committed to acting
Q I suspect that an invoice
– make sure our records are accurate, honestly, fairly and openly in our contains charges for
complete and not misleading business activities. We never take part services that weren’t
– we query any transactions which in dishonest or fraudulent activities. provided by the supplier.
don’t look right What should I do?
We expect every member of Team
– report any activities or transactions Aggreko to uphold these values.
we suspect may be fraudulent. AY
ou should always
speak to your manager,
We don’t: Head of Finance or the
– use Aggreko’s assets for our own use Head of Compliance if
an invoice doesn’t look
– falsify expense claims, invoices, inspection right, making sure
reports, financial statements or other you query any unusual
company records elements before making
– ignore something that we suspect any payments.
might involve fraud, theft or dishonesty.
Q I suspect a member of
my team is claiming
expenses for costs that
she has not incurred,
what should I do?
Tax evasion
We do: We comply with all local tax legislation in
Q What
should I do if
– manage our tax affairs ethically and in the countries where we operate and pay I have concerns that
accordance with our tax strategy the right amount of tax for those activities. a supplier might be
– report any suspicions that a third party We have a zero-tolerance approach to tax asking us to assist them
may be evading the payment of tax. to evade tax
evasion and always manage our tax affairs
by making a
We don’t: ethically. We also make sure we don’t payment offshore?
– help others to evade tax facilitate tax evasion by other parties,
– ignore any suspected tax evasion.
even accidentally. A If you have any suspicions
or concerns that a
For further guidance read our Guidelines supplier (or other third
on the Prevention of the Facilitation of Tax party) might be asking us
Evasion. to assist them to evade
tax, report it immediately
to the Group Legal
Director, the Group Tax
Director or the Head
of Compliance.
DO’S AND DONT’S ETHICS 17
Fair competition
We do: We believe in free and open
Q I’ve been contacted by
– take care when dealing with actual competition. We work hard to win a competitor’s sales
or potential competitors against the competition by providing rep. They suggested
– tell the Head of Legal or the Head better products and services, not by that rather than going
of Compliance if we receive any head-to-head on the
unethical or illegal business methods.
sensitive commercial information next round of tenders
about competitors We never do things which would restrict we should agree how to
bid, so we each win one.
– notify the Head of Legal or the Head free and fair competition, such as working What should I do?
of Compliance immediately if we’re asked with competitors to rig bids, exchange
by a competitor to work together in any way
sensitive commercial information, AY
ou should tell the sales
– clearly record the source of any fix prices or share markets. rep that you can’t take
information we get about actual part in any discussions
or potential competitors. Competition laws are complicated, like this and immediately
We don’t:
so if you’re thinking about any type tell the Head of Legal
and the Head of
of arrangement or engagement with
– take part in any discussion, correspondence, Compliance. This is
agreement or understanding with a a competitor or potential competitor serious anti-competitive
competitor (or potential competitor) talk to your Head of Legal or Head behaviour, which could
to fix prices, rig bids, share customers of Compliance first. lead to a criminal
or markets prosecution.
– discuss commercially sensitive information
(like pricing, costs or market strategy)
with competitors.
DO’S AND DONT’S ETHICS 18
Political activity
We do: Aggreko does not make payments or
QW
e’re having an election
– make it clear that any political views we other contributions to support political locally and a political
express or actions we take are ours and campaigns or political activities. candidate has asked us
not Aggreko’s
to provide a generator for
– make sure any political activity doesn’t Of course, we all have our own personal an event. Can we do it?
create a conflict of interest interests outside work and all employees
– talk to our manager before standing have the right to take part in lawful AW
e can supply equipment
for public office. political activity in their own time. But any if the candidate pays for
political views should be clearly expressed rental on our standard
We don’t: commercial terms.
as personal views, not those of Aggreko. Preferential discounts
– use charitable donations or expenses
to disguise political contributions should not be used to
disguise any political
– use any Aggreko funds or resources contributions. You
to support political activities. should also consider if
our reputation could be
damaged by association
with the candidate – ask
your manager for advice if
you’re unsure.
DO’S AND DONT’S OUR PEOPLE AND ASSETS 20
Respect
We do: Team Aggreko is made up of a rich
QW
hat should I do if I see
– value difference and treat everyone equally, mix of people from different cultures, someone being harassed
with respect and without discrimination religions and social backgrounds. through threatening
– make decisions about recruitment, We value difference and we’re proud remarks or gestures?
compensation or development based only
to Be Together, creating an inclusive
on ability, skills, experience, behaviour and A If you experience or see
performance culture where everyone is treated
any form of harassment
equally with respect and compassion or threatening behaviour,
– speak up if we see bullying, harassment
or discrimination in a welcoming work environment, speak up. Report it
free from fear or intimidation. immediately to your
– encourage and support people manager or your regional
who challenge or report any Head of Legal or HR.
inappropriate behaviour. You can also report this
through Expolink.
We don’t:
– intimidate or humiliate others
– m
ake disparaging or discriminatory
jokes or comments
– block promotion or development
based on any form of discrimination
– tolerate any behaviour that could be
viewed as bullying or harassment.
DO’S AND DONT’S OUR PEOPLE AND ASSETS 21
Human rights
We do: We’re an international business and we
Q I think one of our
– prohibit the use of child or forced labour, recognise we have a responsibility for suppliers isn’t paying
human trafficking and any activities upholding and protecting human rights. their workforce in line
associated with modern slavery
We have a zero-tolerance approach to with the local legal
– use fair labour practices and comply requirements. What
forced labour practices, modern slavery
with any applicable wage and working should I do?
time regulations and child labour. We expect our suppliers
to adopt similar approaches – our Supplier AO
ne of the requirements
– immediately report any concerns regarding
suspected labour or human rights abuse to Code of Conduct sets out the minimum of our Supplier Code of
the Head of Compliance. standards we expect from them. Conduct is that suppliers
must pay workers in line
We don’t: For further guidance read our with local laws. If you
Supplier Code of Conduct. have concerns that a
– work with suppliers who refuse to adopt supplier may not be
the standards set out in our Supplier complying with this,
Code of Conduct tell your Head of
– ignore human rights abuses by our Procurement or
suppliers, customers or business partners. Head of Compliance
straight away.
DO’S AND DONT’S OUR PEOPLE AND ASSETS 22
Data privacy
We do: We collect, process and keep personal
QW
e have a new system
– keep information safe and secure – information about employees, suppliers which will hold some
we keep paper copies locked in a secure and customers to help us run our personal employee
room or filing cabinet and we apply access
restrictions and password protection to business effectively. We must keep and information like
names, addresses
electronic information use data securely and properly, following
and photographs. The
– tell individuals how we’ll use their data, our Data Privacy Policy. supplier has asked for
and only ever use it that way a copy of this data so
For further guidance read our Data Privacy Policy. they can upload it to
– complete data privacy training if we regularly the system. What
access personal information should I do?
– immediately report any loss of personal
data to the Head of Data Privacy. AC
ontact the Head of
We don’t: Data Privacy, who will
help you to review
– transfer or provide copies of personal the system to assess
information to any third party without whether we can share
approval from the Head of Data Privacy the personal information
– keep personal information for longer and to check that there
than it’s required are appropriate controls
to keep the information
– leave personal information where it can safe.
be accessed by an unauthorised person.
DO’S AND DONT’S OUR PEOPLE AND ASSETS 24
Confidential information
We do: Throughout our business we collect and
Q Should
I join a
– consider whether information is develop confidential information. This conference call whilst
confidential before we share it includes marketing plans and strategies, travelling on a train?
– encrypt and label confidential customer lists, trade secrets, proposed
information and put appropriate A If your conversation
mergers and acquisitions or intellectual
confidentiality agreements in place could be overheard,
before we share it with a third party property. We all need to love the you shouldn’t discuss
– refer to Aggreko’s Share Dealing Code
discipline and protect the confidentiality confidential information
before buying or selling any shares of any information we have access to. in public places like
in Aggreko. trains. If you need to
Those members of Team Aggreko who talk about confidential
We don’t: have access to Price Sensitive information information, schedule the
call for a time or place
– have conversations about confidential should not use inside information to buy
where you can speak
information where we could be overheard or sell Aggreko shares for their own or privately.
– leave confidential information unattended anyone else’s benefit.
– use unsecure internet networks to For further guidance read Aggreko’s
access or share confidential information Share Dealing Code. QW
hat should I do if I lose
– share confidential information with a file or device containing
people who aren’t authorised to access confidential information?
the information
– share confidential information AR
eport the loss of any
for personal gain. confidential information
immediately to your
manager and to the
ATS ServiceDesk.
DO’S AND DONT’S OUR PEOPLE AND ASSETS 25
IT systems
We do: We provide IT systems and devices
Q I have received an email
– comply with our IT security requirements so our people can do their jobs. Our IT with an attachment from
– keep log-in details and passwords systems and devices can’t be used for an unknown sender.
confidential any improper purpose, or ways which What should I do?
– protect Aggreko’s IT systems from loss, could affect their operation or integrity.
damage or theft. AY
ou should always be
We allow reasonable, appropriate cautious about opening
We don’t: personal use of our IT systems and attachments from
unknown senders as they
– use Aggreko’s IT systems or devices to access, devices. This may be monitored. may contain viruses. Use
obtain, create or distribute any illegal or
For further guidance read our IT the ‘Report Phishing’
offensive material
and Communications Policy. button in your email or
– use Aggreko’s IT systems or devices notify ATS ServiceDesk
excessively for personal use. if you have any security
concerns, and they’ll run
a security check.