Code of Conduct Our mirror 2018
The Code of Conduct is our mirror The Code of Conduct is our mirror. It reflects the culture of integrity, respect for people, and transparency that we nurture at Adam Smith International. It is a code that underpins our culture as an impactdriven, ethical company. It is the Code that we all sign up to when we start working with ASI as staff, consultants or partners. And it’s the Code that helps us to live by the corporate values that drive our day-to-day life: partnership, resourcefulness and creativity. The Code of Conduct is our reference enabling us to make often difficult decisions. It is our guide to proper professional behaviour, and it is reassurance to our clients and beneficiaries that we are committed to ethical behaviour in all circumstances. It is consistent with our obligations as a member of the United Nations Global Compact and it is an important part of our move to becoming a triple bottom line company with accountability for financial, social and environmental performance. The Code is designed to be simple, but with references to policies and procedures that can be consulted for more detail. I hope that this will make it easy to use, remember, and make a part of our professional life.
Jonathan Pell Chief Executive Officer 2
Mirrors at a solar thermal power plant
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Contents Foreword 2 Our values
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Our Code of Conduct
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Acting with integrity 10 The information and tools you work with
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Sharing in ASI’s corporate commitments
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Our working environment
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ASI Whistleblowing hotline
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Our values
Partnership Bringing together people from diverse backgrounds and adopting an inclusive approach to work. Communicating effectively Sharing information Building relationships
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Resourcefulness
Creativity
Working in complex, challenging situations and using resources wisely to achieve high quality outcomes.
Finding new ways to create value through innovative thinking, technology and better ways of working.
Embracing responsibility
Challenge the status quo
Empowering others
Making it personal
Celebrating excellence
Learning from others
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Our Code of Co This is the Code of Conduct for all of us. As a company delivering sustainable development even in fragile environments, we uphold the highest standards of integrity, with exemplary ethics, professionalism, and efficiency in carrying out our work in strategic international development. We all share that corporate aspiration and do our part to respect our high standards. Everyone who works with Adam Smith International (ASI) agrees to respect the Code of Conduct at all times. It is up to all of us to uphold the Code of Conduct and to make sure that those around us do the same. It is your duty to report if you feel that the Code of Conduct is not being upheld, whether through your own manager or colleagues or by using the ASI Whistleblowing hotline.
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onduct
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Acting with integrity Fraud, bribery and corruption ASI has a zero tolerance approach to dealing with identified cases of fraud, bribery and corruption and will pursue company sanctions as well as legal charges if such instances are detected. ││ Fraud means acting to mislead in order to gain financial benefit. ││ Bribery is the offering, promising, giving, receiving or soliciting anything of value to improperly influence the actions of another party. ││ Corruption is the abuse of entrusted power for private gain.
đ&#x;‘?đ&#x;‘? Speak up and report any instances of fraud, bribery and corruption in line with the Whistleblowing Policy
đ&#x;‘?đ&#x;‘? Attend relevant face-to-face training and complete online modules related to counter-fraud and anti-bribery and corruption
đ&#x;‘?đ&#x;‘? Ensure that any grants or any other disbursement of client funds are safeguarded from fraud and bribery risks
đ&#x;‘Žđ&#x;‘Ž Do not offer or accept kickbacks in any circumstances đ&#x;‘Žđ&#x;‘Ž Do not give facilitation payments (e.g. paying a customs official a “fast-track feeâ€? to clear goods through customs)
Counter Fraud and Anti-Bribery and Corruption Policy Whistleblowing Policy
Legal, Ethics and Compliance Team
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Gifts and hospitality You must not offer or accept any money, gifts or hospitality that could, or could seem to, influence your professional relationship with a client, beneficiary or any other third party. If you do, you could be charged with gross misconduct. If you offer or accept any gifts or hospitality, you must get approval in advance and disclose it in line with the Gifts & Hospitality Policy – failure to disclose may be considered a disciplinary offence.
đ&#x;‘?đ&#x;‘? Always ask yourself if the gift or hospitality could be seen as a bribe đ&#x;‘?đ&#x;‘? Before offering or accepting any gift or hospitality you should make sure it is in line with the thresholds in the Gifts & Hospitality Policy, customary in a normal business relationship, and is unlikely to influence the other party’s or your own decision-making
đ&#x;‘?đ&#x;‘? Be extra-cautious when the gifts or hospitality involve governments or public officials đ&#x;‘?đ&#x;‘? Seek prior approval for any charitable donations or pro-bono activities from the Legal, Ethics and Compliance Team
Gifts and Hospitality Policy Counter Fraud and Anti-Bribery and Corruption Policy
Legal, Ethics and Compliance Team
Conflict of Interest ASI’s advice must always be objective and independent. You must report any personal or business relationships that could, or could be perceived to, interfere with your objectivity.
đ&#x;‘?đ&#x;‘? Avoid actual or perceived conflicts of interest đ&#x;‘?đ&#x;‘? Declare all conflicts of interest while you work for ASI to your Line Manager or Programme Manager, as appropriate
Conflict of interest policy
Legal, Ethics and Compliance team
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Partners & Suppliers We choose our partners and suppliers through competitive selection processes, and conduct thorough background checks and due diligence. We work respectfully and honestly with them. We adapt procurement policies and procedures to local context, laws and regulations. Our policies are designed to reduce the risk of ASI becoming associated - through our partners and suppliers - with fraud, bribery, corruption, sanctions, tax evasion, terrorism financing, modern slavery and human trafficking.
đ&#x;‘?đ&#x;‘? Follow the Procurement Manual when buying goods or services đ&#x;‘?đ&#x;‘? Always treat suppliers with respect, dignity and integrity đ&#x;‘?đ&#x;‘? Look out for potential warning signs that may affect us conducting our business with integrity, such as a third party’s adverse reputation or opaque ownership structure
đ&#x;‘?đ&#x;‘? Use the Third Party Screening Tool to check whether the third parties we engage appear
on any sanctions lists, are subject to adverse media, or involved in terrorism, bribery, fraud or money laundering Approvals Policy Background Checks Policy Procurement Policy Third Party Screening Policy
Legal, Ethics and Compliance Team
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Equality, diversity, dignity and human rights Our workplace provides an environment of respect for dignity and free from objectionable conduct. This specifically excludes all forms of harassment, which is a disciplinary offence and will normally be treated as gross misconduct. We respect the equality of all those with protected characteristics, including gender, age, race, religion, sexual orientation, marriage status and pregnancy/maternity. Concerns that these principles are not being respected can be pursued through the Grievance Policy. We must also ensure that any suppliers that provide goods or services to ASI and any other third parties we work with share our commitment to complying with labour laws and human rights.
đ&#x;‘?đ&#x;‘? Always show respect for colleagues and the communities we work in đ&#x;‘?đ&#x;‘? Speak up and raise any instances of harassment or discrimination Grievance Policy Equality, Diversity and Dignity at Work Policy
Legal, Ethics and Compliance Team Human Resources Diversity and Inclusion Committee
Human trafficking and modern slavery Beyond basic compliance, ASI is committed to working with donors and partners to apply best practice through our supply chains and to use our own expertise to help end human trafficking, modern slavery (sex trafficking and compelled labour) and all human rights abuses.
đ&#x;‘?đ&#x;‘? If you witness any human rights abuse in our operations, you must report it to the Legal, Ethics and Compliance Team or through the Whistleblowing Hotline
Human Trafficking and Modern Slavery Policy
Legal, Ethics and Compliance Team
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Safeguarding ASI has a safeguarding commitment to prevent and reduce harm to children and vulnerable adults who may be in contact with our staff and consultants. We have a specific Safeguarding Policy in place, as well as a Child Protection policy, which everyone at ASI must adhere to. A member of our Legal, Ethics and Compliance Team acts as Safeguarding Lead, creating a trusted point of contact for staff and consultants and the general public, or anyone outside the company, to raise concerns and ensure that any safeguarding matters are investigated and dealt with properly.
đ&#x;‘Žđ&#x;‘Ž You must not engage in any form of sexual abuse or exploitation of any persons of any age
đ&#x;‘Žđ&#x;‘Ž You must not have sexual relations with children (defined as under 18 years old) or with
beneficiaries (in exchange for assistance or payment or any other reason) recognising the inherent unequal power dynamics involved
đ&#x;‘Žđ&#x;‘Ž You must not exchange money, offers of employment, goods or services for sex or sexual
favours, nor any other forms of humiliating, degrading or exploitative behaviour within the course of your engagement with ASI
đ&#x;‘?đ&#x;‘? If you witness any safeguarding breaches in our operations, you must report them to the
Safeguarding Lead, the Legal, Ethics and Compliance Team or through the Whistleblowing Hotline Safeguarding Policy Child Protection Policy
Legal, Ethics and Compliance Team Safeguarding Human Resources
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The information and tools you work with Data protection and use of IT resources We must protect the sensitive information we hold, and obtain authorisation to process or disclose it. ASI is subject to strict data rules to protect privacy including the General Data Protection Regulation (GDPR) - that all companies collecting data in the European Union must comply with. We are responsible for using IT resources in an appropriate and professional manner at all times.
đ&#x;‘?đ&#x;‘? Always exercise the highest standards when dealing with personal data đ&#x;‘?đ&#x;‘? Report any data breaches immediately to IT đ&#x;‘Žđ&#x;‘Ž Do not keep data longer than necessary đ&#x;‘Žđ&#x;‘Ž Never use our IT systems to engage in illegal or inappropriate behaviour Data Protection Policy IT Conditions of Use Policy IT Acceptable Use Policy Email Acceptable Use Policy
IT & Cyber Security Team
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Confidential and sensitive information As part of our work, we frequently have access to confidential third party information. We must never disclose, discuss or copy such information without written authorisation from the third party.
đ&#x;‘Žđ&#x;‘Ž You should never seek to obtain confidential information from clients or competitors -
for example, documents marked ‘official’, or ‘sensitive’, internal strategies or business plans, bids or bid evaluations, or internal information on pricing and commercial costing information.
đ&#x;‘?đ&#x;‘? If you should receive this kind of information, even inadvertently, you must immediately alert the Legal, Ethics and Compliance Team.
Data Breach Management Policy Ethical Walls Policy
Legal, Ethics and Compliance Team IT Team
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Sharing in ASI’s corporate commitments Environment ASI is committed to minimising our environmental footprint by preventing pollution and encouraging practices to promote sustainability. This is part of our triple bottom line commitment to account for financial, social and environmental performance. We are working to measure, monitor, and minimise our corporate environmental footprint, and to support improvements to the environment through our projects.
đ&#x;‘?đ&#x;‘? Only buy supplies when necessary and minimise the amount of materials i.e. stationery, office equipment, furniture consumed
đ&#x;‘?đ&#x;‘? Buy products, when available, that are made from recycled material and/or are recyclable, and have minimal packaging
đ&#x;‘?đ&#x;‘? Buy energy efficient appliances and equipment Environmental Policy
Executive Team
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Accounting and reporting ASI is incorporated in the UK, with subsidiaries and affiliates in several other countries. We publish group annual financial statements consolidating ASI, its holding companies and UK and foreign subsidiaries. Our financial statements are audited by an independent accounting firm and approved by the Audit Committee of the Board. The accuracy of the financial statements and reputation of ASI depend on all time and expenses being recorded according to our rules; and information on activities and performance being recorded in a timely and transparent way without misrepresentation or falsification. ASI is a signatory to the International Aid Transparency Initiative (IATI) and has a framework in place to publish relevant financial information to IATI.
đ&#x;‘?đ&#x;‘? Ensure you and your teams keep accurate financial records đ&#x;‘?đ&#x;‘? Ensure timely and accurate submission of timesheets đ&#x;‘?đ&#x;‘? Support all expense submissions with receipts đ&#x;‘Žđ&#x;‘Ž Do not alter, delete or falsify financial records International Aid Transparency Initiative reporting requirement
Finance Team
Tax Tax evasion, or facilitating tax evasion by staff or associated people or companies, is not tolerated. ASI pays tax in the UK and remits tax in other jurisdictions, where we work in accordance with local law and international tax treaties.
đ&#x;‘?đ&#x;‘? Raise any concerns of tax compliance issues with the CFO Prevention of Facilitation of Tax Evasion Policy
Human Resources Legal, Ethics and Compliance Team
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Our working environment Healthy, safe workplace We have a moral and legal duty of care for the health, safety and welfare of our employees and the families and others associated with our staff who are in locations where we work around the world. Many of our operations are in fragile countries with violent or hostile environments. There, as in all our working environments, we are committed to ensuring that staff are in healthy, safe conditions.
đ&#x;‘?đ&#x;‘? Raise concerns if you identify a potential hazard or feel that certain behaviours or practices may cause harm
Health, Safety and Well-being Policy
Human Resources
Learning and development ASI provides opportunities for formal and informal learning, including an induction process, as well as online, classroom and webinar-based opportunities for training and discussion. Learning and Development Policy
Human Resources
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How do I raise a concern? ASI promotes a culture of openness, accountability, and high ethical standards. As part of your duty under the Code of Conduct, you must report suspected or actual violations of our policies, such as fraud, bribery, corruption and human trafficking, modern slavery and safeguarding. You can report your concern to your manager, to Human Resources or to the Legal, Ethics and Compliance Team. Or you – and other staff, consultants, suppliers, clients or other stakeholders – can report anonymously through the ASI Whistleblowing Hotline. All reports are investigated, as appropriate, and handled confidentially. The Whistleblowing Hotline can be used to report suspected misconduct, possible breaches of company policies and procedures, and suspected violations of laws and regulations, including fraud, bribery and corruption, safeguarding, conflicts of interest, financial malpractice and significant environmental and health and safety concerns. Whistleblowing Policy
Legal, Ethics and Compliance Team
Non-Retaliation Retaliation against any colleague who in good faith seeks advice, raises a concern or reports misconduct is strictly prohibited. The fact that an individual has raised a concern in good faith, or has provided information in an investigation, cannot be a basis for denial of benefits, termination, demotion, suspension, threats, harassment or discrimination. If any individual, regardless of their role in Adam Smith International, retaliates against a colleague who has truthfully and in good faith reported a potential violation, Adam Smith International will take appropriate action - even if it later turns out that the colleague was mistaken in reporting the matter originally. However, if an individual has intentionally made a false report, ASI will take appropriate action.
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ASI Whistleblowing hotline operated by SafeCall Email: adamsmith@safecall.co.uk Report online: www.safecall.co.uk/report Call: +44 191 516 7749 from anywhere in the world.
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UK Adam Smith International 240 Blackfriars Road London SE1 8NW United Kingdom +44 20 7735 6660
Africa Adam Smith International 2nd Floor, Cavendish 14 Riverside PO Box 26721-00100 Nairobi Kenya +254 20 444 4388
North America
Asia Pacific
+1 (202) 873-7626
Adam Smith International Suite 103 80 William Street Woolloomooloo NSW 2011 Australia +61 2 8265 0000
EU
Adam Smith International 1712 N Street NW, Suite 400 Washington, DC 20036 United States of America
Adam Smith Europe B.V. Keizersgracht 62, 1015 CS Amsterdam, Netherlands +31 (0)20 520 7400
www.adamsmithinternational.com