Code of Conduct

1. Introduction

As we continually strive to deliver high performance for our clients, our company, Centrebound is committed to upholding the highest ethical and professional standards consistent with our Values and our Code of Conduct.

2. Our People

Our success is a reflection of our people and those we work with.

2.1 Fair Treatment and Equal Opportunity

We want Centrebound to be a place of mutual trust and respect, which embraces diversity and values everyone for their merits. A place where people’s rights are honoured and they are treated fairly and consistently.

Centrebound ensures employment including hiring, payment, benefits, advancement, termination and retirement is based on ability and not on beliefs or any other personal characteristics. This includes discrimination based on sex, race, colour, national or ethnic origin, sexual orientation, gender identity or expression, religion, political beliefs, trade union activity, marital status, caring responsibilities, disability, age or citizenship.

Centrebound will ensure women workers receive equal treatment in all aspects of employment. Pregnancy tests will not be a condition of employment and pregnancy testing to the extent provided will be voluntary and the option of the worker. In addition, workers will not be forced to use contraception.

2.2 Respectful Workplace

Every Centrebound employee has the right to respect and freedom from harassment. Violence at work is unacceptable, regardless of the reason. We will not tolerate harassment or violence against an employee.

Centrebound will treat all workers with respect and dignity. No work shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse, nor is there to be the threat of any such treatment. In addition, Centrebound will not use monetary fines as a disciplinary practice.

2.3 Human Rights

Respect for human rights is a fundamental part of how Centrebound does business and our Values.

Our commitment to respecting human rights acknowledges all internationally recognised Human Rights as outlined in the International Bill of Rights, including the United Nations Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Convention on Economic, Social and Cultural Rights and the ILO Declaration on Fundamental Rights and Principles at Work. That means wherever we work in the world, we will seek to respect and uphold the fundamental Human Rights and freedoms of everyone who works for us or with us, and of the people and communities we work among.

Centrebound will identify, prevent or mitigate any adverse human rights impacts caused or contributed to by their operations to avoid any infringement on the rights of others and also identify impacts that are directly linked to their operations where they are acting for or in connection with our operations.

We expect to share this commitment and specifically meet the following:

2.3.1 Child Labour

Centrebound does not use child labour and it expects it’s to do the same. The minimum age for workers shall not be less than the age of completion of compulsory schooling, normally not less than 16 years where the local law of the country permits, deferring to the greatest age. In addition, Centrebound will comply with all legal requirements for the work of authorised young workers, particularly those pertaining to hours of work, wages and safe working conditions.

Additionally, all young workers will be protected from performing any work that is likely to be hazardous or to interfere with their education or that may be harmful to their health, physical, mental, social, spiritual or moral development.

We encourage our employees to participate in legitimate workplace apprenticeship programmes that comply with applicable laws and regulations.

2.3.2 Forced Labour

Centrebound will not use any type of involuntary or forced labour, including indentured, bonded, slave or human trafficked labour, and never engage in any form of procurement of commercial sex acts.

All work will be voluntary and workers will have the freedom to terminate their employment in accordance with established laws, regulations, and rules. Workers shall not be charged any fees or costs for recruitment, directly or indirectly, in whole or in part, including costs associated with travel, processing official documents and work visas in both home and host countries.

When the subcontracting of recruitment and hiring is necessary, we shall ensure that the labour agencies they engage operate legally, are certified or licensed by the competent authority, and do not engage in fraudulent behaviour that places workers at risk of forced labour or trafficking for labour exploitation.

Centrebound will also not mandate that workers hand over government-issued identification, passports or work permits as a condition of employment. The retention of personal documents shall not be used as a means to bind workers to employment or to restrict their freedom of movement.

Written contracts of employment shall be provided to workers in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours and other working and employment conditions. This will be provided prior to deployment. The use of supplemental agreements and the practice of contract substitution (the replacement of an original contract or any of its provisions with those that are less favourable) are strictly prohibited.

No worker shall be required to lodge deposits or security payments at any time. Centrebound will put in place adequate procedures to ensure that they are not directly or indirectly, through their supply chain, involved in any form of involuntary or forced labour.

The workplace shall be free of any form of harsh or inhumane treatment. Disciplinary policies and procedures shall be clearly defined and communicated to all workers, and shall not include any inhumane disciplinary measure, including any corporal punishment, mental or physical coercion, or verbal abuse of workers; nor shall they includes sanctions that result in wage deductions, reductions in benefits, or compulsory labour.

The use or threat of physical or sexual violence, harassment and intimidation against a worker, his or her family, or close associates, is strictly prohibited.

2.3.3 Wage and Benefits

Centrebound will pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers will be paid for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate.

2.3.4 Working hours

Centrebound will ensure that on a regularly scheduled basis, except in extraordinary business circumstances, workers are not required to work more than 50 hours a week, including overtime. will ensure that all overtime work is voluntary and compensated at the prevailing overtime rates. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off in every seven day period.

2.3.5 Freedom of Movement and Personal Freedom

Workers freedom of movement shall not be unreasonably restricted. Workers shall not be physically confined to the workplace or related premises, such as employer- or recruiter operated residences; nor shall any other coercive means be used to restrict workers freedom of movement or personal freedom. Mandatory residence in employer-operated facilities shall not be made a condition of employment.

2.3.6 Freedom of Association and Collective Bargaining

Centrebound recognises the importance of open communication and direct engagement between workers and management. Centrebound respects the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal. We also recognise and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing. Centrebound will respect any legal right of workers to bargain collectively.

3. Our Values

Centrebound is committed to the highest standards of integrity, honesty, openness and professionalism in all its activities wherever they are undertaken, we respect local laws and do not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum.

Centrebound supports the aims of global bodies such as the Organisation for Economic Cooperation and Development (OECD) to combat bribery and corruption.

3.1 Bribery, Corruption and Facilitation Payments

Bribery is offering, providing or receiving something of value ? including cash, gifts, hospitality or entertainment ? as an inducement or reward for something improper. Usually, but not always, it’s to obtain or retain business or some other illegitimate advantage. Bribes are against the law and against our code.

A facilitation payment refers to the practice of paying a small sum of money to (usually) an official as a way of ensuring they perform their duty. UK legislation forbids facilitation payments anywhere in the world.

Corruption involves any of these activities: bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement and money laundering.

Engaging in bribery and corruption and making facilitation payments can seriously damage our reputation and business relationships.

We never offer, give or receive bribes or improper payments, or participate in any kind of corrupt activity, either directly or through any third party.

3.2 Gifts and Hospitality

Centrebound develops long-term business relationships based on trust and respect. Exchanging gifts and hospitality can build goodwill, but may, or may appear to, create improper influence. Any gift or hospitality we accept or give in connection with business will always be customary and reasonable in terms of value and frequency.

Centrebound will not provide any gift, meal or entertainment to a company employee in any situation in which it might influence or appear to influence any employee decision in relation to the supplier. In other situations, may provide modest gifts, meals or entertainment to company if they are:

• not cash or cash equivalent
• consistent with customary business practice and supplier company policy
• not frequent or expensive
• do not violate any law.

Equally we do not want our employees to be influenced or pressurised in turn through the acceptance of inappropriate gifts or hospitality. If someone tries to do this to you, always report this to management.

We require our staff to record gifts and hospitality given or received by them.

3.3 Conflicts of Interest

Conflicts of interest run counter to the fair treatment we expect. They can also break the law and seriously damage our integrity and reputation.

A conflict of interest occurs when your private interests interfere, or appear to interfere, with the best interest of Centrebound or its clients

3.4 Competition and Anti-Trust

Competition and anti-trust laws prohibit a variety of business practices that restrict free and fair competition, such as bid rigging, price fixing, cover pricing or market sharing. Violations of such laws are very serious, and can result in significant fines and other penalties, including debarment. Individuals can face prison.

We are committed to free and open competition in our markets. We compete fairly and ethically, and support laws that promote and protect competition. The decisions we make about pricing, customers, bids and markets are taken by us alone.

We expect that when we are preparing proposals, bids or undertaking contract negotiations for Centrebound and our clients we are certain that all statements, communications and representations are accurate and truthful.

Our employees, suppliers or clients will not share with us information they receive from or about our competitors or their bids, or the bids they are making to our competitors.

Our employees, suppliers or clients will always report anti-competitive behaviour if you see it or suspect it. Our? will inspire trust by taking responsibility, acting ethically and encouraging honest and open debate.

4. Our World

We recognise Centrebound’s impact on society, the economy and the planet, and aim to make a positive difference. This is embedded in the way we do business. We are committed to maintaining a safe, healthy and sustainable working environment, with a vision of zero harm. Everyone in Centrebound is responsible for making this a reality and we look to our to help us deliver this commitment.

4.1 Health and Safety

Our vision is zero harm. Our work is never so urgent that we cannot take time to do it safely. We aim to provide workers a clean, safe and healthy work environment in compliance with all legally mandated standards for workplace health and safety in the countries in which we operate.

We require everyone who works for or with us to understand the health and safety risks of their activities and apply good health and safety management systems, training and practices in all they do. They will also take the necessary precautions to protect everyone from workplace injuries and occupational disease.

4.2 Environment

We work with our stakeholders to continuously assess and reduce our environmental impact. We aim to prevent environmental damage and minimise our use of energy and resources.

Centrebound will comply with all local environmental laws applicable to the workplace, the products produced, and the methods of manufacture. Additionally, Centrebound will not use materials that are considered harmful to the environment, but will encourage the use of processes and materials that support sustainability of the environment throughout their supply chain

Our vision is zero harm.

4.3 Community Engagement

Being a good corporate citizen is central to the way we do business. Supporting the community brings real benefits to our customers, our shareholders and our people.

We support and contribute to the social and economic wellbeing of the communities we work in. We listen to the concerns of local communities and wherever we can act to mitigate them to the very best of our powers. We respect the traditions, cultures and laws of the countries in which we operate and seek to employ local people on our projects wherever possible.

5. Our Assets

Centrebound is committed to being a sustainable and reputable business. Our physical and intangible assets including money, property, time and information are key to achieving this. How we use and protect our assets has a strong bearing on how we perform and how well prepared we are for the challenges we will face. Our employees can play an important part in this.

The services we provide are wholly dependent upon our human, information and physical assets and resources.

5.1 Financial Integrity

Our policies are clear, no employee will engage in any activity that is designed, or can be reasonably construed, to perpetuate a fraud or evade taxes.

Fraud is a criminal offence in most countries. Whilst its definition varies across these countries, fraud always involves deception and dishonesty. It’s fraud when you deliberately try to deceive someone, act dishonestly or abuse your position to gain any kind of material advantage, or use or involve anyone else to do so. Fraud is usually carried out for profit, or to obtain money, property or services unjustly. It can involve defrauding the company or a third party.

Centrebound will never knowingly seek to gain any advantage of any kind by acting fraudulently, deceiving people or making false claims, or allow anyone else to do so on or our behalf. This includes:

• defrauding or stealing from the company, a customer or any third party
• any kind of misappropriation of property
• any kind of misreporting of time or expenses
• tax evasion or deliberately or dishonestly taking action to help someone else to evade tax
• money laundering

5.2 Confidential Information and Records

Information for us is confidential if it has value to Centrebound and is not publicly available.

We might also obtain confidential information from our customers, partners and others.

Centrebound has a responsibility to keep confidential information safe and make sure it never gets into the wrong hands.

Centrebound will take all due care in handling, discussing or transmitting sensitive or confidential information that could affect the company, its , its companies, the business community or the general public.

5.3 Personal Information

Centrebound recognises its duty to respect personal information and ensure it is protected and handled responsibly and only used for the purposes for which it is provided.

Centrebound ensures that all personal information is controlled in accordance with, and their data and information systems comply with, applicable laws and regulations.

Centrebound will manage personal information in accordance with the following Data Protection Principles. We will:

• Process personal information fairly and lawfully
• Obtain personal information only for specified, explicit and legitimate purposes
• Ensure personal information is adequate, relevant and not excessive
• Ensure personal information is accurate and, where necessary, kept up to date
• Not keep personal information for longer than is necessary
• Process personal information in accordance with rights of the individual
• Keep personal information secure
• Not transfer personal information unless there is adequate protection in place

6. Communication, Monitoring and Compliance

Centrebound will communicate, through its existing ethical operating standards/practices or through this Code that its workers, supervisors and its permitted subcontractors are aware of the requirements detailed in this Code of Conduct.

If you have any questions about this Code, ask us.

Centrebound will take necessary corrective actions to promptly remedy any identified non-compliance. Centrebound reserves the right to terminate its business relationship with any Centrebound employee who is unwilling or unable to comply with this Code when termination is allowed by local laws.

We encourage Centrebound employee, supplier or client to communicate to us any actions taken to improve its business practices and to send us suggestions about how Centrebound can best contribute to the implementation of the principles set out in this Supplier Code of Conduct.

Full details of Centrebound’s Values, Code of Conduct, Policies and Standards are available centrebound.com.

If you have questions about our Supplier Code of Conduct, please contact Centrebound at info@centrebound.com.

7. Raising Concerns

Centrebound employees, suppliers or clients who believe that a company employee or anyone acting on behalf of the company has engaged in an illegal or otherwise improper conduct will report the matter to the data protection officer.

If you are aware of any violations of this Code you will report it.

At Centrebound we’re all responsible for knowing Our Code, using it and living it.

Centrebound Limited
Ducie House
Ducie Street
Manchester M1 2JW