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Ethical business code of conduct – Policy Statement
Everything Managed Group is committed to doing business with a high degree of integrity and transparency dependent on a culture in which everyone feels comfortable and empowered to report instances of non-compliance including suspected illegal or unethical conduct.
• We will not tolerate illegal or corrupt activity
• We expect behaviours by individuals to demonstrate good practice and respect to others in all their actions
• We will report and properly deal with any instances of fraud, misconduct or wrongdoing by workers or officers of any Group business
• We are absolutely committed to preventing slavery and human trafficking in our corporate activities and to ensuring that our supply chains are free from slavery and human trafficking
• It is not acceptable to accept or offer gifts or hospitality in circumstances where it could influence, or be seen to influence, business actions or decisions
• We will encourage the raising of concerns about any behaviours or malpractice without fear of reprisal and will investigate as necessary
• We will take the appropriate steps to ensure that all personal data is processed fairly and lawfully with the appropriate systems and controls are in place to ensure the security of this data
Scope
All people employed within a Group business in any capacity and at any level of seniority.
All third parties and supply chain partners who perform services for and on behalf of Everything Managed Group. We expect those parties to abide by the provisions of this policy or alternatively have in place equivalent policies.
Group Business Obligations
Each Group business will:
• Have policies and procedures in place to operate the business within the parameters of the Everything Managed Group policy
• Provide suitable and sufficient resources to enable the policy to be implemented
• Provide employees with adequate training, information and instruction to ensure they can act within the policy parameters
• Be able to demonstrate compliance with this policy
• Notify the Board of any issues or complaints which may have an impact on the reputation or standing of the individual Group business or Everything Managed Group as a whole
Indicative Policies/Procedures/Codes of Conduct
EMG-POL-ETH-001 Anti-Bribery, Anti-Corruption and Corporate Criminal Offences Policy
EMG-POL-ETH-002 Ethical business code of conduct
Damon Smith – Chief Executive Officer, January 2023 (reviewed annually).
Modern Slavery & Human Trafficking Statement
INTRODUCTION
This statement sets out EverythingManaged Group actions to understand all potential modern slavery risks related to the Group and its operating businesses and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking within the Group and our supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 March 2024.
EverythingManaged Group recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Although we do not meet the requirement threshold of turnover (£36 million), the Group is absolutely committed to preventing slavery and human trafficking in all its activities and ensures that its supply chains are free from slavery and human trafficking.
ORGANISATIONAL STRUCTURE & SUPPLY CHAINS
This statement covers the activities of EverythingManaged Group.
The Group is privately owned and offers businesses waste services and payments processing. Our waste supply chain is based in the UK and provides waste collection services.
COUNTRIES OF OPERATION
The organisation currently operates in the United Kingdom.
The following is the process by which the Group assesses whether or not particular
activities or countries are high risk in relation to slavery or human trafficking:
• A review of our supply chain partners including their country source of labour in support of our business operations. As we are operating exclusively in the UK with all of our supply chain partners also based in the UK, we consider the overall risk of slavery and/or human trafficking to be very low.
• For all employees, we carry out Right to Work in the UK checks and pay minimum wages or above in accordance with published UK government legal guidelines in respect of National Minimum and National Living Wage.
RISK ACTIVITIES
As part of our supply chain evaluation process, we conduct risk assessments of our supply chain activities across the Group. On an ongoing basis we review the response of our supply chain evaluation process, to ensure that there is minimal risk of occurrence.
We run a vigorous supply chain process, which includes compliance checks,to ensure our partners meet or exceed our modern slavery and human trafficking policy requirements.
RESPONSIBILITY
Responsibility for the organisation’s anti-slavery initiatives is as follows:
• Policies: Procurement Director
• Risk Assessments: Procurement Director supported by the Head of Compliance will assess the risk of slavery or human trafficking within the supply chain.
• Investigations/due diligence: The Head of Compliance is responsible for carrying out investigations supported by the Procurement Director. The Procurement Manager is responsible for ensuring the Company’s policies are communicated to the supply chain partners and form part of the supplier assessment process.
RELEVANT POLICIES AND PRACTICES
The organisation operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
Ethical business code of conduct policy: The Group’s code makes clear to employees the actions and behaviours expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.
The Group is committed to ensuring that its supply chain partners adhere to the highest standards of ethics. Partners are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with the supply chain to ensure that they meet the standards of the code. Serious violations of the organisation’s code of conduct will lead to the termination of the business relationship.
As part of our supply chain evaluation, candidates are asked if they have a policy/statement that sets out the steps their organisation takes to ensure that slavery and human trafficking are not taking place in any of their supply chains or in any part of their own business. If any potential supply chain partner is unable to demonstrate that they have a robust policy in place, we ensure that they agree to act in accordance with our policy.
DUE DILIGENCE
The organisation undertakes due diligence when considering taking on supply chain partners, and regularly reviews its existing partners. The organisation’s due diligence and reviews include:
• Evaluating the modern slavery and human trafficking risks of each new partner.
• Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where material risks are identified.
• Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action appropriately.
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or which seriously violate our supplier code of conduct, including the termination of the business relationship.
BOARD APPROVAL
This statement has been approved by the organisation’s Operational Board who will review and update it at least annually.
Anti bribery, corruption and corporate criminal offences
V2 January 2023
Classification: public
Policy Statement
It is Everything Managed Group’s policy to conduct all of our business in an honest and ethical manner. We are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships, implementing and enforcing effective systems to counter bribery, corruption and tax evasion. We will uphold all laws relevant to countering bribery and corruption in the UK including the Bribery Act 2010 and Corporate Criminal Offences Act 2017. We will prohibit bribery, corruption and any form of tax evasion via:
• A top-level commitment to anti-corruption compliance
• A clear ethical approach to all work, which includes this policy, guidance on the provision/receipt of gifts and entertainment and also the Business Code of Conduct
• A training plan approach to cover all employees in relevant posts
• Monitoring and reviewing of the policies and procedures in place
• Escalation and whistle-blowing routes to encourage employees to report any suspicion of bribery, corruption or tax evasion
• A commitment that firm action will be taken against any individual(s) or company involved in bribery, corruption or tax evasion
Scope
All people employed within a Group business in any capacity and at any level of seniority.
All associated persons who work with Everything Managed Group including subcontractors, suppliers and clients. We expect those persons to abide by the provisions of this policy or alternatively have in place equivalent policies.
Group Business Obligations
Each Group business will:
• Operate in line with the Group Policy and Procedures
• Provide suitable and sufficient resources to enable the policy to be implemented
• Provide our people with adequate training, information and instruction to ensure they act within the policy parameters
• Be able to demonstrate compliance with this policy
• Notify relevant individuals of any issues or complaints which may have an impact on the reputation or standing of the individual Group Company or Everything Managed Group as a whole
Indicative Policies/Procedures/Codes of Conduct
EMG-POL-ETH-001 Anti-Bribery, Anti-Corruption and Corporate Criminal Offences Policy
EMG-POL-ETH-002 Ethical Business Code of Conduct