Business Ethics Policy
Effective 4 February 2008
Policy Summary:
The Phillips Ormonde & Fitzpatrick Group (PO&F Group) encourages Staff Members to participate in activities outside the Group that are consistent with the best interests of both the Staff Member and the Group. However, Staff Members are required as a condition of employment to avoid any personal situation that does or may involve a conflict with the business interests of the PO&F Group.
Policy Detail:
Those personal outside activities, interests or relationships that affect or appear to affect the impartiality, judgment or effectiveness of Staff Members in the performance of their work are considered to be in conflict with the PO&F Group’s business interests. Examples may include but are not limited to the following:
- Outside work by a Staff Member for a client or supplier of the PO&F Group.
· The acceptance of gifts, entertainment or other favours by Staff Member or a member of a staff member’s family from present or prospective clients, or suppliers of the PO&F Group, except for the customary minor amenities, and meals and entertainment arising from business discussions or dealing on behalf of the PO&F Group.
· A financial interest held by a Staff Member or a member of a Staff Member’s family in a present or prospective client or supplier of the PO&F Group. Generally, this does not include insignificant amount of stock or securities held in a publicly-owned company.
- Borrowing by a Staff Member or members of a Staff Member’s family from present or prospective client or suppliers of the PO&F Group. Generally, this does not include borrowing from banks or other recognised financial institutions with whom the PO&F Group does business.
Staff Member Responsibilities:
Staff Members are responsible for disclosing to the PO&F Managing Partner, any contemplated or existing activity, interest, or relationship that could impair their objectivity, judgment or effectiveness as Staff Members of the PO&F Group. Staff Members are to take the initiative in disclosing activities whenever they have a potential or actual conflict and should not rely on prompting by Management. Through this action, Staff Members protect their own interests as well as those of the PO&F Group.
Disciplinary Action:
Staff Members will be subject to disciplinary action up to and including immediate termination, in line with the PO&F Group’s Disciplinary procedures, for any one or more of the following violations:
- Engaging in a personal activity that poses a potential or actual conflict with the business interests of the PO&F Group.
- Failing to promptly disclose such a potential or actual conflict to the Managing Partner.
- Failing to promptly correct a situation involving such a potential or actual conflict if so directed by Management.
Management Committee
4 February 2008