Code of Business Conduct

Preamble

SPL Consulting Limited is committed to a high standard of ethical conduct. This Code of Business Conduct reflects the business practices and principles of behaviour that support our commitment and sets out the expectations for all our employees and business partners. The Code is aimed at fostering a culture of business ethics, personal integrity, honesty, and accountability across our business.

This Code applies to all individuals working for SPL Consulting Limited, including managers, directors, and employees.

Our core business principles

Our core principles are simple:

  • Trust: Building and maintaining trust with employees, customers, and the community.
  • Value: Creating business value for all stakeholders through continuous improvement and service excellence.
  • Integrity: Operating with the highest level of ethics and integrity in every action and transaction.

Making good decisions

Ethical choices are critical to our business. When faced with a difficult or unclear situation, follow these steps:

  1. Pause: If a situation feels wrong, stop and reflect.
  2. Reflect: Ask yourself:
    • Is this action the right thing for the company?
    • Is it legal?
    • Would I be comfortable if this action were public?
  3. Ask: If in doubt, speak to your manager or a member of the Human Resources or Legal teams.

Reporting concerns

You have a responsibility to report any act that may violate our Code or the law. You can discuss concerns with your direct manager, the Human Resources department, or the Legal team. We have a zero-tolerance policy for retaliation against anyone who reports a concern in good faith. Human Rights, Health, and Safety

We are committed to respecting and promoting human rights in all our operations. We follow a zero-tolerance approach to human rights violations and expect our employees and suppliers to do the same. We also take all reasonable precautions to provide a safe and healthy work environment that complies with all statutory requirements.

Fairness, diversity and inclusion

We strive to create a work environment where everyone is treated with dignity and respect. We do not tolerate any form of unfair treatment, harassment, or discrimination based on any characteristic protected by law. We are committed to equal opportunities for all employees.

Privacy

We take our obligations to protect personal information seriously. We are committed to using personal data only for legitimate business purposes and must protect it from loss, misuse, or unauthorised disclosure. If you handle personal data, you must comply with our policies and relevant privacy laws, such as GDPR.

Fair competition

We strive to outperform our competitors fairly and honestly, based on the quality of our services. The use of unethical or illegal practices to gain an advantage is strictly prohibited. You must not disclose confidential information or trade secrets from a prior employer.

Bribery and corruption

We have a zero-tolerance approach to bribery and corruption. We never offer or accept anything of value to gain an unfair advantage. We are committed to complying with anti-bribery and anti-corruption laws in all countries where we operate.

Anti-money laundering

We comply with all applicable laws and regulations to combat money laundering and terrorist financing. You must be vigilant and report any suspicious transactions or activities.

Conflict of interests

A conflict of interest arises when your personal relationships or financial interests interfere with your ability to perform your job objectively. You must always act in the best interests of the company. Full disclosure is required for any activity or relationship that could create the appearance of a conflict of interest.

Gifts and entertainment

While gifts and hospitality can help build business relationships, they must not improperly influence a business decision. Giving or accepting anything of value is prohibited if it could create a conflict of interest. We expect you to exercise good judgment and decline any excessive offers.

Company assets

Company assets, both tangible (e.g., equipment) and intangible (e.g., intellectual property), must be used for legitimate business purposes only. We must protect our assets from damage, loss, and theft.

Protecting confidential information

We consider all non-public information about our company, customers, and partners to be confidential. You must safeguard this information and use it only for legitimate business purposes. Your duty to protect this information continues even after your employment ends.

Financial and business records

Our records are relied upon by management, banks, and tax authorities. All corporate and business records must be accurate and truly reflect our assets, liabilities, and transactions. The making of false or misleading entries is strictly prohibited. You must cooperate fully with the finance team to ensure our records are accurate and complete.