The Vitec Group plc
CODE OF BUSINESS CONDUCT
Our people
Vitec employees are passionate about their businesses, innovative, pro-active, open and honest. We promote teamwork, individual responsibility and the strength that comes from diversity.
Vitec is committed to equality of opportunity in all its employment practices, procedures and policies. When we hire someone to work in our individual companies we choose the best candidate, irrespective of age, race, national origin, disability, religion, gender, sexual preference or membership/non-membership of any trades union. We apply the same standard when selecting suppliers and other people we do business with.
Vitec supports the United Nations Universal Declaration of Human Rights and will provide a safe and healthy workplace for employees with respect for their privacy and life outside work.
People working for Vitec can expect adequate pay for doing their job and special rewards for extraordinary work or performance. Vitec will continue to invest in the personal growth of its employees and will aim to offer stable employment in the communities where we are based.
Our company
Vitec employees do not compete with any activity or business of the company, either directly or indirectly, or use knowledge gained while working for Vitec to help anyone else compete with the company.
Vitec employees aim to avoid conflicts of interest between the company and themselves, for example we do not do business on behalf of Vitec with a company from which we or a family member may benefit. We do not have personal interests in companies that compete with or do business with Vitec unless we have agreed this with Vitec’s senior management in advance, although we can of course own shares in publicly-traded companies.
We treat company property as if it was our own but we remember it’s not. We make sure it is taken care of and is not used for personal purposes unless previously authorised.
Our suppliers
We aim to develop long-term relationships with our suppliers and expect them to make a fair return on the investments they have made in doing business with us. We select them on objective criteria such as quality, delivery, performance and price.
We also expect them to adhere to standards of ethical conduct similar to this Code. Where concerns exist, suppliers will be asked to confirm their compliance using a survey similar to that shown at the end of this Code. In particular Vitec will not use child or forced labour, nor tolerate working conditions or treatment that conflict with the International Labour Organisation’s Core Labour Standards that cover the four main areas of forced labour, freedom of association, discrimination and child labour. Vitec cares about the ethical performance of its suppliers and will take rapid and thorough steps in cases where that performance comes into question.
We do not accept gifts or gratuities from present or potential suppliers, other than gifts of nominal value (‘nominal’ defined as less than €100 or equivalent) or reasonable hospitality given in the ordinary course of business. Any agreement or understanding regarding benefits or favours in exchange for such gifts must be avoided. Gifts of other than nominal value may not be accepted without full disclosure to, and the advance agreement from, the employee’s managing director.
We respect the patents, copyrights, trademarks and proprietary information of our suppliers, as well as the confidentiality of others with whom we do business.
Our customers
We aim to offer products and services that are safe, consistently reliable, innovative and relevant to their needs.
When customers have a complaint we take the complaint seriously and start with the assumption that whatever they say is correct and well founded and we follow it up diligently. We aim to always resolve any situations in a quick, friendly and professional way.
When we advertise or solicit for business we are truthful in every detail concerning our products and services. We do not make misleading statements about offerings from our competitors. Customers will trust us because of our openness and expertise.
Vitec and its employees will not pay or offer to pay bribes or illicit payments under any circumstances to customers, government officials or other parties in order to obtain or retain business.
Our shareholders
We comply with the relevant securities laws and we do not use company information that has not been made public for our own or others’ benefit.
We do not trade in Vitec shares except during declared open periods (for further information consult the Company Secretary).
We take scrupulous care to maintain our books and records so that they fairly reflect our business transactions as they occur. We do not make misleading or false entries or conceal or confuse our records in any way. We observe our internal control and financial policies as set down and safeguard Group information that is not in the public domain. Our shareholders will invest in us because they have confidence in what we say and do.
Our responsibility to society
We comply with the laws and regulations of each country in which we do business.
We always aim to compete fairly and honestly, observing all applicable anti-trust and competition laws.
Whilst we believe our operations have only limited environmental effect, we work to minimise the impact of our products and operations on the environment and on the communities in which we operate.
We support the giving of time and money to a variety of local and international causes that fall within the themes of: Children, Personal Development and Media-related. At the discretion of the local management we will give a matching payment to causes for which employees have volunteered their time, to the value of that time.
Vitec does not make donations to political parties nor to any cause that might bring either local business units or any part of the Group into disrepute.
Making sure this Code is understood
All new employees are given this Code when they join, and it is distributed to all current employees. It is available on the Vitec website and intranet, as well as the websites of each operating company.
If there is anything about this Code an employee does not understand, if an employee needs help in applying it or if an employee just wants further guidance, they are free to contact their immediate line manager, their business unit managing director or their divisional director. If the employee wants to talk to someone at Vitec head office, they should call the Company Secretary, Roland Peate, or Vitec Group CEO, Gareth Rhys Williams, on +44 (0)20 8939 4650.
Making sure we comply with the Code
All employees are responsible for complying with this Code and the detailed policies we adopt that flow from it.
Violations of this Code affect us all in that they damage the name and reputation of all Vitec businesses. Consequently, if Vitec employees feel that someone is acting inconsistently with this Code they should report it without delay to their local management. If an employee feels uncomfortable with this course of action they should contact the Company Secretary (roland.peate@vitecgroup.com) who is responsible for following up such calls. If the employee prefers to leave him an anonymous message, they should do so on the Company Secretary’s phone line: +44 (0)20 8939 4656.
Investigations will be confidential and results reported to the appropriate senior management and, if appropriate, the Board of Vitec. Vitec will ensure that there will be no adverse work-related consequences, regarding promotion, pay increases or other benefits, for an employee as a result of them bringing complaints of violations of this Code to management’s attention.
April 2008
