Staff Handbook

• they are given or received in the Company’s name, and not in the name of any employee; • they do not include cash or a cash equivalent (such as vouchers); • it is appropriate in the circumstances. For example, it may be customary to give a small gift at Christmas; • taking into account the reason for the gift or hospitality, it is of an appropriate type and value, and given at an appropriate time; • they are given openly, not secretly; and • they are not offered or given to government officials or representatives, or politicians or political parties. 30.Code of Conduct The Company has a strong customer service ethos and its aim is to always make customers feel valued. You must keep this ethos in mind at all times in the course of your employment and conduct yourself in a manner consistent with it. You must always behave in a professional manner whilst at work. You should ensure that you are polite to colleagues and customers at all times. It is the policy of the Company that all employees, management and directors (collectively “Employees”) are required to conduct their financial and business affairs in such a manner as to avoid any conflicts of interest between themselves and the Company. The objective of this policy is to establish guidelines concerning conflicts of interest for all Employees to minimize the possibility of such conflicts arising and to provide a means of resolution for such conflicts should they arise. Failure to comply with this policy is considered an act of misconduct and may lead to disciplinary action, up to and including termination of employment. All Employees are expected to avoid engaging, directly or indirectly, in any business or financial transactions or activities which are in conflict with the interests, or appear to be in conflict with the interests, of the Company. The following list, which is illustrative and not exhaustive, will serve as a guide to the types of transactions and activities that give rise to actual and potential conflicts of interest with the Company and are therefore to be avoided: • Investing or holding an ownership interest or outside directorship in suppliers or competing companies without the Director of Sales, Retail & International’s knowledge and written consent, in which, in the 31.Conflicts Policy Overview


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