Purpose
| The Warehouse Group Limited (TWG)
is committed to the highest degree of integrity and honestly in the conduct of
its business affairs.
This
policy reinforces TWG’s position that any conduct that may raise questions as
to the Company's honesty, integrity, impartiality, or reputation, or activities
that could cause embarrassment to the Company or damage to its reputation, are
prohibited. Any activity, conduct or transaction that could create an
appearance of unethical, illegal, or improper business conduct must also be
avoided.
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Policy/Procedure
| The
highest possible standards of ethical and business conduct are required of TWG
team members and directors in the performance of their responsibilities and
duties. It is the responsibility of every team member and director to encourage
other team members and directors to ask questions, seek guidance, report
suspected violations, or express their concerns regarding compliance with this
standard of conduct.
You
must conduct the Company’s business affairs with the highest personal
integrity. In every business transaction and negotiation, you are expected to
respect the rights of competitors, customers, suppliers and other team members.
You must comply with any laws governing price fixing and other trade practices.
Team Member Responsibilities
- You are responsible for conducting yourself in a manner that upholds TWG's standards, values and policies.
- You are
accountable for TWG’s business conduct, must obey the laws which apply to the
business, and must live up to the standards and values expressed in this
policy. Your actions will be reviewed under this policy, applicable TWG
policies and the laws of the relevant country that you are based in or the laws
of New Zealand.
- If
you do not act in accordance with this policy and applicable policies and laws,
you may be subject to disciplinary action. TWG cannot and will not compromise
compliance with this policy or applicable policies or other laws to meet
financial plans or maximize profits.
- In
addition to company disciplinary actions, violations of many provisions of this
Code are against the law and may subject a violator and/or TWG to severe penalties,
fines or other consequences.
- You
have a responsibility to promptly notify immediate Managers or Department Heads
of any violations of this policy whether by suppliers or other team members.
You will not be subject to reprisals for reporting, in good faith; actions you
feel violate this policy. We further expect you to fully cooperate in any
investigation of an alleged violation or other business conduct.
- Where
TWG reasonably believes that any team member or director has been involved in
any criminal conduct, TWG will co-operate fully with any police or other
governmental agency investigation and the criminal proceeding of any charges
laid.
Standards for Buyers
TWG’s
Buyers are engaged in activities that are continually scrutinized by suppliers,
team members and the general public. In recognition of that the following
standards have been established:
- Purchase
without prejudice for the overall benefit of TWG.
- Conduct
business in a highly ethical manner; be honest, courteous and professional in
our business affairs.
- Strive
to obtain the maximum value for each dollar of expenditure.
- Purchasing
requirements should routinely be subjected to competitive evaluation.
- Conflicts
of interest with the business of TWG must be avoided.
- Conduct
business with potential and current suppliers in an atmosphere of good faith,
devoid of intentional misrepresentation.
- Demand
honesty in sale representation whether offered thorough the medium of verbal or
written statement, an advertisement or sample of product.
- Maintain
confidentially regarding quotations, price or other confidential information
involving TWG’s suppliers and competitor dealings.
- Gifts
or rewards from supplier or potential suppliers must be given to the manager
for redistribution regardless of the type of gift or its value. All gifts or
rewards are regarded as TWG’s property and must be reported to your Manager and
entered on the Gift Register. There may be occasions where TWG solicits certain
items from other persons or organizations in support of special
company-sponsored events. In these circumstances, solicitations may only be
made in furtherance of the event and for no other reason. All solicitations
must be coordinated with the person or persons designated by senior management
to be responsible for coordinating the special events.
- Supplier
sponsored trips are generally discouraged. Where such trips are requested, they
require departmental manager prior approval in writing.
- Buyers
must not take for themselves, or divert to another person or company, a
business or financial opportunity which they know, or could reasonably
anticipate, TWG would have an interest in pursuing.
- Buying
team members are expected to comply with both the letter and spirit of this
policy.
- When
making sourcing decisions buyers must remain mindful of the Social Policy
Section of TWG’s Terms of Trade (Section 6) concerning a supplier’s obligation
to comply with the laws and standards of the countries in which the suppliers
are doing business, including the labour and employment laws of those countries
and any applicable New Zealand laws.
Buyers must as a minimum refer suppliers to these Terms of Trade so as
to ensure suppliers are aware of them.
Buyer’s sourcing decisions must show clear preference for those
suppliers who are accredited (Accredited Suppliers), or working towards
accreditation (Probationary Suppliers) as to their compliance with said Social
Policy. In the case of a decision to
shift business from a known Accredited or Probationary Supplier, buyers must
require that the prospective new supplier undergo The Warehouse Supplier
Factory CSR Assessment prior to the placement of any purchase order. Details of existing Accredited and
Probationary suppliers are available from the compliance manager based in The
Warehouse Corporate Affairs Department or from the Warehouse Direct Sourcing
Office.
- Dependent Suppliers. Buyers,
when working with suppliers who, by virtue of the majority share of business
they have with TWG, are vulnerable to sudden changes or discontinuity or
cessation of business with the TWG, must subject any decision to cease or dramatically reduce purchasing, to review and approval by their Merchandise Manager and a representative from Corporate Affairs.
Please note: the general standards set out in the Standards for Buyers section above apply to all team members.
Conflicts of Interest
- You
are required to conduct yourself in a manner and with such ethics and integrity
so as to avoid a conflict of interest, either real or apparent.
- A
conflict of interest is any circumstance where an individual's personal
interest interferes or even appears to interfere with the interests of TWG. You
have a duty to avoid financial, business or other relationships that might be
opposed to the interests of TWG or might cause a conflict with the performance
of their duties.
- A
conflict can arise when you take actions or have interests that may make it
difficult to perform your work for TWG objectively and effectively. Conflicts
also may arise when you or a member of your family, receives improper personal
benefits as a result of your position in TWG.
- Some
of the areas where a conflict could arise include:
4.1. Employment
by a competitor, regardless of the nature of the employment, while employed by
TWG.
4.2. Placement
of business with any company in which a team member, or any member of the team
member’s family, or any person with whom the team member has a close personal
relationship who has a substantial ownership interest (1% or more) or
management responsibility.
4.3. All
relevant information relating to a real or apparent conflict of interest must
be disclosed on a Warehouse Ethical Business Code of Conduct Acknowledgment and
Disclosure Statement ("Disclosure Statement"), which you may be
periodically asked to complete.
Commercial Bribery
- Giving
or accepting gifts that equal more than the amount that would be considered
customary courtesies may be deemed a bribe. Bribes are strictly prohibited by
law and are against TWG policy. A bribe can expose you to criminal penalties.
Company payments (regardless of amount), or gifts or entertainment of any value
to officials and other personnel of any governmental of Council agency or
department are not permitted. cf. 9 above.
- If
confronted with a demand for a payment, gift, entertainment or the like, you
must inform your Manager and Department Head.
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