1. Purpose
    1. Posix Limited (“the Company”) is committed to the practice of responsible corporate behaviour.
    2. Through its business practices, the Company seeks to protect and promote
      1. The human rights and basic freedoms of all its employees and agents.
      2. The rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company. 
      3. The best interests of its clients.
    3. The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form. 
    4. This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.
  1. Principles
    1. The Company and its employees will at all times demonstrate the highest levels of integrity, truthfulness, and honesty in order to uphold both personal and corporate reputations and to inspire confidence and trust in their respective actions. The company will conduct its business in a competent, fair, impartial, and efficient manner.
    2. The essence of our business is protecting our clients’ data, facilitating their use of their data, and improving the efficiency of their operations.  Everything we do must respect and honour that.
  1. Human Rights
    1. The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion. 
    2. The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.
    3. The Company will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.
  1. Workers’ Rights
    1. The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.
    2. No worker should be discriminated against on the basis of age, gender, race, sexual orientation, religion or beliefs, national origin, gender reassignment, marital status or pregnancy. All workers should be treated equally.
    3. No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation.
    4. Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum.
    5. The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.
    6. The company is committed to providing a safe and healthy working environment for all of its employees both on and off its sites.
  1. Environmental Issues
    1. The Company is committed to keeping the environmental impact of its activities to the minimum necessary to conduct its business in accordance with its other policies.
    2. As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.
  1. Conflicts of Interest
    1. The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.
    2. Employees will neither seek nor accept for themselves or others any gifts, favours, or entertainment without a legitimate purpose from any person or business organisation that does or seeks to do business with, or is a competitor of Posix Limited. Gifts, favours, and entertainment may be given to others at the expense of the company as long as these are consistent with customary business practice and are not excessive in value.
    3. All officers, employees and representatives of the Company are expected to act honestly and within the law.
  1. Information and Confidentiality
    1. Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given. 
    2. The Company will process any personal data collected in accordance with the GDPR.
  1. Customers
    1. The company will take all reasonable care to avoid misleading statements, concealment, and overstatement in all of its client communications, advertising and public statements. It will seek to build long term partnerships with its customers by being honest and straightforward in its dealings at all times. It will respect the confidentiality of any information it may obtain in relation to its customers.
  1. Competitors
    1. The company will build its reputation on the basis of its performance alone. It will compete vigorously and lawfully and will not compete unfairly with others. It will not seek to damage the reputation of its competitors either directly or by implication.
  1. Suppliers and Partners
    1. Suppliers will be chosen on the basis of factors such as price, quality, delivery, service, and integrity. The company’s choice of suppliers will be made objectively. Honesty and openness will be paramount in the Company’s dealings with its suppliers.
    2. The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards.
    3. The Company will investigate the ethical record of potential new suppliers before entering into any agreement.
    4. The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy.
  1. Corporate Governance
    1. The Company will seek to comply with all international, national, and local legislation affecting its operations. It will strive to follow the best practice in corporate governance. It will meet its tax obligations. It will not make any financial contributions or offer support to any political party.
  1. Bribery and Corruption
    1. The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010.
    2. Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment. 
    3. All employees are encouraged to report any suspicion of corruption or bribery within the Company.
    4. In the event that an individual reports suspected instances of bribery, the Company will process any personal data collected in accordance with the GDPR. Data collected will be held securely and accessed by, and disclosed to, individuals only for the purposes of dealing with the report of bribery.
    5. Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must request guidance from management.
    6. The Company uses its reasonable endeavours to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010. 
    7. If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.
    8. Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.