Paul Bowler Training (herein after referred to as “the company”) has developed this Code of Business Ethics for all employees including directors, management, administrative and support staff and trainers.
General Policy
Paul Bowler Training is committed to supporting lawful and ethical behaviour in all of its activities. It requires directors, employees and trainers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. All directors, employees and trainers have a duty to practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. Duties extend to reporting of any activity which may represent a breach of ethical behaviour that relates to the company’s activities.
In many cases decisions as to what is ethical or fair are clear cut and will be obvious to any reasonable person. In some situations, however, there may be circumstances where an element of doubt or ambiguity arises. To help in those circumstances and to protect and guide individual employees and trainers, it is necessary to have a written Code of Business Ethics.
The overall purpose of the Code is to provide guidance to directors, employees and trainers in performing their duties.
It is not possible to provide for every situation in the Code of Business Ethics. If there is doubt about the probity of any particular situation, the Director of the Company must be consulted about that situation by the individual concerned.
In addition to the requirement for each staff member and trainer to behave in an ethical manner, there is also a requirement for staff and trainers to comply with the requirements of the Companies Acts and other relevant legislative requirements.
Objectives of the Code of Business Ethics
The objectives of the Code of Business Ethics are:
(a) to offer guidance to directors, employees and trainers in their business conduct with student and clients
(b) to set out an agreed set of ethical principles
(c) to promote and maintain confidence and trust in the company
(d) to promote the development and acceptance of ethical practices by the company
(e) to promote the highest legal, management and ethical standards in all the activities of the company.
(f) to promote compliance with best current management practice in all the activities of the company.
Principles of the Code of Business Ethics
The Code of Business Ethics applies to all directors, employees and trainers of the company. The guiding principles of the Code of Business Ethics can be summarised under seven headings:
• a. Integrity
• b. Confidentiality of Information
• c. Obligations & Legality
• d. Disclosure of interest
• e. Loyalty
• f. Fairness
• g. Consideration for Work/External Environment.
(a) Integrity
Each director, employee and trainer of Paul Bowler Training is expected to observe the highest standards of honesty and integrity in all his/her dealings with students, clients, fellow staff members and members of the general public.
To this end director, employees and trainers must:
• Director must ensure that the company’s accounts/reports accurately reflect its business performance and are not misleading or designed to be misleading,
• to the extent that employees have an input, ensure that the company’s accounts/reports accurately reflect its business performance and are not misleading or designed to be misleading
• refuse bribes, gifts, hospitality, benefits or offers of preferential treatment which may affect one’s ability to make independent judgment and in particular marking of assessment and to report any such approaches in writing to a Director of the company
• avoid misrepresenting one’s position or being ambiguous or misleading,
• reject any business practice which might reasonably be deemed to be improper,
• avoid the use of the company’s resources or time for personal gain, for the benefit of persons/organisations unconnected with the company or its activities or for the benefit of competitors,
• commit not to acquire information or business secrets by improper means,
• act in a manner which is appropriate to one’s position in the company
• not act in a manner which could bring the reputation of the company into disrepute.
(b) Confidentiality of Information
Paul Bowler Training is committed to providing general information in relation to it courses and services and is also cognisant of its duty of care regarding access to, storage and security of all information held by the company.
The director, employees and trainers should be mindful of the company’s obligations under the Data Protection Act, 1988 and the Data Protection (Amendment) 2003 (the Acts) and any requests for or regarding information held by the company which is subject to the provisions of these Acts should be referred to the Director.
Director, employees and trainers should support the provision of access to general information relating to the company’s activities in a way that is open and that enhances its accountability to the general public. In an effort to put this into effect, the company publishes information on its courses and services activities its web site which is regularly updated.
The director, employee and trainers owe a duty of confidentiality to the company in respect of sensitive information held by the company. Sensitive information would include, for example:
• personal information about employees, trainers and students
• information received in confidence by a director, employees or trainer
• any other material, release of which might constitute an unlawful or unethical act
• Discussions with students, particularly of a sensitive nature
• any information relating to the company which is not public information,
• commercially sensitive/business information (including information relating to business policies or practices),
• any information relating to the company which is designated by it to be confidential,
(c) Obligations and Legality
Paul Bowler Training will fully comply with all Irish and EU legislation and all obligations as agreed with accrediting bodies.
In order to ensure through one’s business dealings are compliant the director, employees and trainers are required, to the extent that it is within their power and remit, to:
• fulfil all regulatory and supervisory obligations imposed on the company
• co-operate with relevant regulatory and supervisory bodies,
• avoid false, inaccurate or misleading entries in records
• ensure that taxation and welfare legislation is upheld
• ensure that the company does not engage in “offensive” tax avoidance transactions
• ensure one’s actions comply with relevant contractual obligations
• encourage effective and fair competition at all times
• comply with the company’s purchasing and tendering procedures
• personally avoid engaging in any illegal or criminal activities (inside or outside working hours)
• comply with controls to prevent fraud including adequate controls to ensure compliance with prescribed procedures in relation to claiming expenses for business travel
• comply with the company’s policies on discrimination, harassment, sexual harassment and bullying.
(d) Disclosure of Interests
All employees and trainers of the company must disclose to a Director of the company details of any conflict of interest which might affect their impartiality in carrying out their duties as soon as they become apparent, including:
• any interest, shareholding or possible conflict of interest an employee has with any firm or organisation from which the company purchases supplies, works or services, or through whom the company proposes to sell services
• any outside employment or business interests in conflict or potentially in conflict with the company’s business
• any interest of an employee’s or trainer’s immediate family which could result in such a conflict of interest
Where a conflict of interest situation could arise for an employee or trainer, he/she must desist from dealing with the contract or situation giving rise to the conflict or potential conflict of interest, and may not attempt in any way to influence decisions on the matter.
(e) Loyalty
Employees and trainers must:
• acknowledge the responsibility to be loyal to the company and fully committed in all its business activities while mindful that the organisation itself must at all times take into account the interests of its shareholder, i.e. students, client companies, accrediting bodies, etc.
• acknowledge the duty of all to conform to highest standards of business ethics.
(f) Fairness
Director, employees and trainers must:
• comply with employment equality and equal status legislation
• commit to fairness in all dealings with students, client companies and all stakeholders
• value their fellow employees and trainers
• value its students, staff, suppliers and clients and treat all students, staff, suppliers and clients equally.
(g) Consideration for Work/External Environment
Director, employees and trainers must:
• place highest priority on promoting and preserving their own health and safety as well as that of fellow employees, students, trainers, clients and other third parties with whom they come in contact in the course of their work day
• ensure that community concerns are fully considered in its activities and operations
• minimise any detrimental impact of the company’s operations on the environment.
Responsibility
This Code of Business Ethics which incorporates the policy on disclosure of interests will be circulated to all management, employees and trainers.
Acting in Good Faith
Anyone reporting a complaint concerning a breach or suspected breach of this policy must do so in good faith with reasonable grounds for believing the information disclosed indicates a breach of the code. Any allegations that cannot be substantiated and which prove to have been made maliciously or knowingly false will be viewed as a serious disciplinary offense.
Confidentiality
Under this policy those who report illegal or improper activity will be protected. Any breach or suspected breach of this policy may be submitted on a confidential basis by the complainant. The company will make efforts to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action.
No Retaliation
No individual who in good faith makes a report shall suffer harassment, retaliation or any adverse consequences.
Guidelines regarding Gifts or Hospitality
It is customary for some suppliers to offer gifts, hospitality or entertainment to named employees and trainers with whom they have contact as a result of business dealings. However employees and trainers should, subject to the procedures outlined below, avoid the giving or receiving of corporate gifts, hospitality, preferential treatment or benefits which might affect or appear to affect the ability of the donor or the recipient to make an independent judgment on business transactions, assessments or in their dealing with students. .
Hospitality
Modest hospitality (including sporting events and golf outings) may be accepted, provided:
• the frequency and scale of hospitality is not more than the company might be expected to give in return,
• invitations do not include the provision of travel or overnight accommodation and availing of the hospitality does not identify the company in a public way with any particular supplier or contractor. Details of hospitality offered in this context that has been turned down must be notified at once to a Director of the company.
Breaches of this Code of Business Ethics
Breaches of this Code of Business Ethics will be regarded as a breach of discipline and will be dealt with in accordance with the company’s disciplinary code by the Directors of the company.
Review
This Code of Business Ethics will be reviewed as appropriate.