AMB Engineering Ltd

Code of Conduct and Ethics Policy

CP-003 Rev A

 1. Scope

This policy is for the use of AMB Engineering Ltd and is applicable to all its practices and may be flowed down to its suppliers


 2. Introduction

Integrity, professionalism, honesty and respect whether personal or organisational are indispensable in the commercial environment and are essential requirements for any organisation in order to grow and ensure profitability and continuing business success. Accordingly, commercial and contract management requires a clear policy statement and a specific set of values relative to professional ethics in order to earn and maintain the confidence of both customers and the supply chain. To protect all persons involved with the AMB Engineering moral and social principles as they relate to our business, staff, customers and suppliers have been defined within this code of ethics and comply with social accountability standard SA8000. This document is made available as guidance for all personnel involved directly or indirectly in organisational activities.


3. Principles 

It is the responsibility of the Management and Senior representatives of AMB Engineering to ensure this document reflects the beliefs and requirements of the company, and that it is maintained throughout its business practices.


4. Labour standards

Forced bonded or indentured labour, or involuntary prison labour, slavery or labour trafficking is not to be used. All work will be voluntary, and employees should be free to leave upon reasonable notice. Employees shall not be required to hand over government-issued identification, passports or work permits as a condition of employment.


4.1 Child Labour Avoidance

No person below the age of 16 is employed by the company in any area of our operations. The company will allow under 16’s presence within the facility, in the support of educational ‘work experience’ schemes


4.2 Working hours

All working hours are in line with the Working Hours Directive and all employees are allowed to rest for at least one day per week minimum.


4.3 Wages and Benefits

All employees shall receive the minimum wage and benefits as a minimum requirement; however we pride ourselves on developing and rewarding our employees to a much higher level. A written account (pay slip) is given to the employee during each pay period clearly indicating the employee’s payments and indicating any deductions from the employee’s pay.


4.4 Humane Treatment

There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of srtaff: nor is there to be the threat of any such treatment.


 4.5 Non-discrimination

We do not engage in discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training.


 4.6 Freedom of Association

Open communication and direct engagement between employees and management are the most effective ways to resolve workplace and compensation issues. The Company respects the rights of employees to join or not join labour unions. As provided by law, employees who become worker representatives shall not be the subject of discrimination and shall have access to management and co-workers in order to carry out their representative functions. Employees shall be able to communicate openly with management without fear of reprisal, intimidation or harassment.


 5. Health and Safety

All members of the Company take the safety of our employees, visitors and the Public very seriously. We also believe that this should be flowed down to our supply chain and expect our suppliers to ensure that they are also maintaining the required levels of safety to meet today’s social and ethical requirements.


5.1 Occupational Safety

Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicle, and fall hazards) are controlled through proper design engineering and administrative controls, preventative maintenance and safe work procedures. Where hazards cannot be adequately controlled by these means, employees are provided with appropriate personal protective equipment. Employees shall not be disciplined for raising safety concerns.


5.2 Emergency preparedness

Emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.


 5.3 Industrial Hygiene

Any possible exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, employees are to be provided with appropriate personal protective equipment.


 5.4 Machine Safeguarding

Physical guards, interlocks and barriers are to be provided and properly maintained for machinery used by any personnel.


5.5 Sanitary and Welfare Facilities

Employees are to be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities.


6. Ethics

It is the responsibility of all employees to ensure compliance and enforcement of this policy.

No one with a personal or organisational conflict of interest may participate in any way in the formation or administration of a contract.

All companies seeking procurement work from the organisation shall be treated fairly and equitably and their intellectual property shall be protected and used only for the purposes intended by its owner.

All personnel involved in any way in the contracting process shall comply with all applicable laws, regulations and directives as well as their specific contractual obligations.

The integrity of the commercial processes shall never be tainted by any real or perceived improper activities.


 6.1 Bribery and Corruption

In accordance with the legislation terms of the UK Bribery Act no individual(s) will offer, promise or give a financial or other advantage to another person(s) with a view to inducing a person(s) to perform improperly a relevant function or activity or reward a person(s) for the improper performance of their activity.


 6.2 Personal Conflict of Interest

All personnel involved in a procurement transaction must disclose any actual or potential conflict of interest which could exist or perceive to exist to their relevant management.

Interest which might create personal conflict of interest includes but is not limited to the following:

·        Ownership of shares in a potential competitor, actual competitor, or contractor.

·        Marriage to or cohabitation with a Director or senior employee of a potential competitor, actual competitor or contractor.

·        Indebtedness to a potential competitor, actual competitor or a contractor.

·        Receipt of compensation from a potential competitor, actual competitor or contractor.


If a conflict of interest is determined, the disclosing person will be directed to remove themselves from any further involvement in the specific process.

All commercial and contract management personnel with the potential for influencing a procurement transaction in any way shall inform their relevant management. A view will be determined as to whether the activities should be re-directed.

Disclosure of potential personnel conflict of interest shall not result in any adverse action against the individual(s).


6.3 Equity & Fairness in Conduct of Competition

No preference or advantage shall be afforded to any contractor or potential contractor. Similarly no prejudice against any contractor or potential contractor shall be tolerated. Examination of documented contractor performance information is not considered preference or prejudice.

Specifications or requirements must not be biased in favour of any particular contractor or potential contractor.

Implying large quantities to influence price, when knowing that the actual order will be smaller is not permitted.

Wording of invitations for tenders, other solicitations or specifications or statements of work in a vague way to intentionally induce misinterpretation or errors in proposals are unethical and prohibited.

Solicitation of proposals from suppliers known to be unqualified for the award with intent to create the illusion of competition is considered dishonest and is not permitted.

Bid or proposal information from one proposal may never be shared with another contractor or potential contractor even if either of the competitors has been eliminated from the competition.

No criticism of one potential source should be communicated to another contractor or potential contractor nor should the strengths or weaknesses of a contractor or potential contractor to be disclosed to any organisation whether competing or not.


6.4 Confidentiality and Protection of Intellectual Property

Information submitted by competitors or proposers is the property of the entity that submits the information and must be protected from disclosure to personnel or firms not authorised to be involved in the evaluation of proposals.

All such property submitted shall be controlled as dictated within the non disclosure agreements,   copyrighted or patented information shall never be reproduced without the express written authorisation of the owner.


6.5 Hospitality & Gratuities

In order to avoid being misconstrued as consideration for special treatments or as an attempt to positively influence their attitudes or decision making personnel should not give or accept hospitality which contravenes the UK Bribery Act.

It is recognised that the giving and receiving of tokens of appreciation is a fundamental part of building good business relationships and maintaining understanding and goodwill.

No individual(s) shall request, agree to receive, anticipate or accept a financial or other advantage with the specific intention of performing a function or business activity improperly either directly or via a 3rd party.

No individual(s) will offer, promise or give financial or other advantage to another person(s) where that individual(s) believes that the acceptance of the advantage would itself result in an improper performance of a relevant function or activity.


 6.6 Facilitation Payments

A facilitating payment is a certain type of payment to foreign officials which is not considered to be bribery according to legislations of some states but may be construed as bribery within the UK and as such is in opposition to the UK Bribery Act. It is therefore against company policy to authorise such payments without the seeking legal advice.


 6.7 Government Employees

No gift or hospitality whatsoever is to be offered to any government or local government official without the express approval of the Managing Director who will take steps to ensure that no governmental or statutory practise is being breached.


 6.8 Sub-Contractors, Consultants & Agents

Any sub-contractor, consultant or agent operating on behalf of the company will be expected to fully comply with this policy.


6.9 Whistle blowing

Whistle blowing is when an individual reports suspected wrongdoing at work. Officially this is called ‘making a disclosure in the public interest’.

Individuals can report issues to senior management that aren’t right, are illegal or if anyone at work is neglecting their duties, including:

·        someone’s health and safety is in danger

·        damage to the environment

·        a criminal offence

·        the company isn’t obeying the law (like not having the right insurance)

·        covering up wrongdoing


Confidentiality is paramount and individuals will be treated with the utmost discretion.

All issues will be investigated.


Date: 28th August 2015

 Anne Marie Gauld


CP-003 Rev A