corporate &
social responsibility
TDC (Aberdeen) Ltd strives to be a good corporate citizen committed to maintaining the highest standards of integrity and corporate governance. Through our managers and employees we are committed to promoting equal opportunities, Human Rights & Equality.
We take a zero-tolerance approach to modern slavery and human trafficking within TDC Aberdeen Ltd and its supply chains and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
EMPLOYERS
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Provide employment equality to all, as per our Equal Opportunities Policy
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Respect the rights and dignity of every employee and treat them without discrimination
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Provide a safe and healthy working environment
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Forbid, eliminate and not be complicit in the use of forced child labour
CUSTOMERS
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We seek to be honest and fair in our relationships with our customers
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Provide the standard of product and service that have been agreed
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Take all reasonable steps to ensure the safety and quality of products and services produced
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Conduct business with respect to the Law in that Country of work
SUPPLIERS - ETHICAL PURCHASING
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We purchase a wide range of goods and services required in the operation of our business and we also rely heavily on a large number of critical suppliers for the delivery of our core services. Good working relationships with our suppliers are therefore central to the success of our business. For this reason, we clearly state our purchasing policy as part of ensuring that our business standards and Policies are integrated throughout the supply chain.
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We are committed to obtaining and retaining competitive goods and services while at the same time ensuring they are from sources which have not jeopardised human rights, safety or the environment.
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We endeavour to use locally based companies where possible, ensuring that items purchased are Fair Trade when relevant and available.
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We aim to develop strong relationships with our suppliers, based on mutual trust, understanding and respect.
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More specifically we expect our suppliers to:
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Adhere to business principles consistent with our own.
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Ensure that their products and services are produced and delivered to comply with all legislation relevant to their business.
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Seek to maintain continuous improvement in their supply chain relationship with us.
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Ensure they adopt and implement acceptable safety, environmental, product quality, product stewardship, labour, human rights, social and legal standards and in line with our own code and to ensure these issues are acceptably managed within the supply chain for any products supplied to us.
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We will seek to work with our key suppliers to:
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Develop long-term meaningful relations to the benefit of both parties.
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Improve the quality, environmental performance and sustainability of goods and services where this can be achieved to the benefit of both parties.
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ENVIRONMENT
The company takes in to consideration the impact on the environment at every stage of its services and activities, as per our Health, Safety & Environmental Policy.
COMMUNITIES
The company takes in to consideration the impact on the environment at every stage of its services and activities, as per our Health, Safety & Environmental Policy.
ANTI-BRIBERY &
CORRUPTION POLICY
PURPOSE
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company's business is conducted in a socially responsible manner.
POLICY STATEMENT
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad. Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.
THE PURPOSE OF THIS POLICY IS TO:
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Set our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and
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Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
GIFTS AND HOSPITALITY
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This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties provided that the following requirements are met:
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Not made with the intention of influencing a third party to obtain or retain business or a business advantage;
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Complies with local law;
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Given in the Company's name, not in your name;
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Does not include cash or a cash equivalent (such as gift certificates or vouchers);
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Appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time;
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Takes into account the reason for the gift, of an appropriate type and value and given at an appropriate time; and
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Given openly, not secretly.
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Declare and keep a written record of all hospitality or gifts accepted or offered.
FACILITATION PAYMENTS AND KICKBACKS
Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to.
Our strict policy is that facilitation payments must not be paid. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.
POLITICAL DONATIONS
We do not make charitable donations or contributions to political parties.
CHARITABLE CONTRIBUTIONS
Charitable support and donations are acceptable whether of in kind services, knowledge, time or direct financial contributions. However, employees must be careful to ensure that charitable donations that are legal and ethical under local laws and practices. No donations must be offered or made without the prior approval of the Managing Director.
YOUR RESPONSIBILITIES
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You must ensure that you read, understand and comply with this policy.
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The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
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You must notify your manager as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.
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Managers are responsible for ensuring their Department is fully informed of policy requirements. Managers are also responsible for adopting and enforcing appropriate controls and taking the steps necessary to ensure compliance with this policy by all employees, distributors, and consultants.
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Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
HOW TO RAISE A CONCERN
If you have any doubt or concern about any situation relating to the policy, seek guidance from your manager before doing or omitting to do anything that could compromise your position within the Company.
WHAT TO DO IF YOU ARE A VICTIM
OF BRIBERY OR CORRUPTION
It is important that you tell your line manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
PROTECTION
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager immediately.
RECORD KEEPING
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
MONITORING AND REVIEW
QHSE department will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
