Code of Conduct

Introduction

Grant Thornton International Limited (GTIL), has a clear ambition to support the growth of the Grant Thornton network coupled with a dedication to fully embrace and embed our core values of Collaboration, Leadership, Excellence, Agility, Respect and Responsibility into everything we do. The GTIL Code of Conduct demonstrates how our values and guiding behaviours are applied through our interaction with stakeholders. The Code of Conduct sets out the principles that should underpin our daily work activities and decisions.

We expect everyone who works on behalf of GTIL to behave in accordance with the principles contained in the Code of Conduct. If you do not understand the principles contained within the Code, or are not sure how to apply them, please contact the People and Culture team.

This Code of Conduct is applicable to GTIL employees, secondees, work experience students, interns and temporary staff working for GTIL. Third parties performing work for GTIL, such as vendors or consultants, should be made aware of the Code of Conduct and should behave in accordance with the principles contained in it.

We acknowledge that breaches of the Code of Conduct may result in our taking disciplinary action, up to and including termination of one's secondment or employment.

We affirm in writing our understanding of the principles contained in the Code of Conduct and our commitment to abide by them.

Our values

• Collaborationask for help, give help we work well together

• Responsibilityuse influence wisely we own our actions
• • speaking out
    • we take a leadership position on issues of importance to the accounting profession, GTIL and the public interest

      Respect listen and understand, be forthright we create honest relationships

      Content

      We all face difficult situations in our daily working lives and the Code of Conduct will guide us through those issues and help us live up to our commitment to ethical principles. Our reputation depends on our actions and each of us has a responsibility for applying the Code of Conduct in daily practice.

      A Code of Conduct cannot cover every situation that you may encounter and this document is designed to provide a principles based framework for ethical decision making. Speaking to other people in the company or organisation or referring to the written policies (available on the myGTIL portal) and procedures, will provide you with valuable advice to deal with the ethical dilemmas and issues that you have to deal with in practice. Remember - having the confidence to consult with others is a strength not a weakness.

      Our role in society

      • environment
        • we seek to reduce the impact on the environment of our business practices by managing effectively business travel, energy use, purchasing and waste disposal
        • corporate governance
          • we take account of the interests of all stakeholders in the way we manage our businesses
        • contributing to society
          • we seek to act in a socially responsible manner
      • we support charitable and community activities
        • we encourage volunteering at all levels in the organisation

  Our approach to people

  • diversity
    • we treat others as we would like to be treated regardless of their background
      • our diversity is an asset that we use to meet the challenges of a changing world
    • respectful treatment

   

  • we are committed to maintaining a work environment that is free from discrimination or harassment

   

  • we provide a safe working environment for our people, this includes circumstances where alcohol may be acceptable in a work environment e.g. social events. In this situation we expect individuals to behave responsibly. This includes safeguarding themselves and others from injuries and protecting the company's reputation

   

  • merit is the sole basis for career progression and reward
  • open and honest feedback
    • we express genuine appreciation for others’ contributions
    • we give and seek regular, open and honest feedback
  • • work life balance
      • we recognise the difficulties of balancing work and private life and endeavour to promote the mind-set that work is only one part of life

     

    • resolution of differences
      • we resolve differences promptly respecting differences of opinion and striving for a resolution to the benefit of all
    • working with member firms
      • in our dealings with member firms we ensure we treat them fairly and with proper consideration

     

    • we give honest advice even when this is unpopular
    • we provide various support but do not manage the member firms nor do we make decisions on their behalf

     

    • we avoid working with people, businesses and other parties who clearly do not share our commitment to ethical conduct

     

    Our conduct in business

     

    • responsiveness

     

    • we recognise that our member firms need timely advice and support and we work together to ensure we achieve this
    • consultation
      • we encourage consultation and recognise that consulting with others is a strength not a weakness

     

    • where differences of opinion arise, we seek the advice of others and work to ensure issues are resolved

     

    • the right people
      • we use our recruitment process to hire the people with the ability to do the work required of them

     

    • we aim to do best for our member firms by using the right people who have the requisite skills, knowledge and experience

     

    • we provide opportunities for our people to develop their skills and knowledge through a variety of means, such as training, planned experience and secondments

     

    • behaviour
      • we are honest and forthright in our dealings with member firms and each other

     

    Our integrity in the marketplace

     

    • integrity
      • we act with integrity, seek to be transparent in carrying out our duties and accept accountability for our actions
      • we reserve the right not to act for, or associate with, individuals and organisations that do not meet our Code of Conduct

     

    • anti corruption
      • we do not offer or accept bribes, facilitation payments or other improper inducements to/or from any party whether a member firm, supplier, government official or other entity or individual with whom we do business

     

    • we do not involve ourselves in questionable transactions
    • dealing with regulators
      • we recognise that it is in both our interest and the public interest that regulatory processes work effectively and therefore we cooperate with regulators and also seek to work with them in developing the regulatory environment
  • • confidential information
      • we respect the confidentiality of information received and take steps to safeguard that information from misuse, including following information security and data privacy policies, guidelines and best practices

     

    • we will not use any information for personal gain
    • we will continue to safeguard information as required by our policies and applicable laws and regulations
    • meeting our commitments
      • we honour our commitments; do what we say we will do, when we say we will do it

     

    • we keep proper records to ensure we can report and charge truthfully for our services
    • mistakes

     

    • we know that, despite everyone's best efforts, mistakes happen and where they do, we acknowledge our contribution and act promptly to rectify the situation

     

    Protecting GTIL

     

    • acting within the law
      • we seek to comply with all applicable laws and regulations
    • proper use of assets
      • we do not misuse the assets of our GTIL, member firms or others with whom we have dealings

     

    • protecting the "Grant Thornton" name
      • we represent Grant Thornton in a way that enhances our reputation and distinguishes us in the marketplace

     

    • our global network is a strength and we act in a manner that preserves the integrity of that organisation

     

    • when speaking in public forums we give GTIL's view and not our own
    • when using social media we do not engage in defamatory comments or make statements that might damage the company's reputation – remember that comments in 'private' forums can easily become 'public'

     

    • describing "Grant Thornton" and acting in a manner consistent with this description, which means adhering to the following principles in what we say and how we act

     

    • GTIL and its member firms are not a global partnership · GTIL does not provide services to clients

     

    • GTIL and its member firms are not agents of and do not obligate, one another and are not liable for one another’s acts or omissions.

     

    • dealing with issues

     

    • we speak up within our company if something ‘feels wrong’ so that we can resolve issues and maintain our high standards

     

    • individuals are encouraged to consult on concerns without fear or reprisal or retaliation
    • unforeseen events
      • we follow the business continuity plan to protect ourselves and ensure business activities are not interrupted in the wake of an unforeseen event.
    • confidential information
      • we respect the confidentiality of information received and take steps to safeguard that information from misuse, including following information security and data privacy policies, guidelines and best practices

     

    • we will not use any information for personal gain
    • we will continue to safeguard information as required by our policies and applicable laws and regulations
    • meeting our commitments
      • we honour our commitments; do what we say we will do, when we say we will do it

     

    • we keep proper records to ensure we can report and charge truthfully for our services
    • mistakes

     

    • we know that, despite everyone's best efforts, mistakes happen and where they do, we acknowledge our contribution and act promptly to rectify the situation

     

    Protecting GTIL

     

    • acting within the law
      • we seek to comply with all applicable laws and regulations
    • proper use of assets
      • we do not misuse the assets of our GTIL, member firms or others with whom we have dealings

     

    • protecting the "Grant Thornton" name
      • we represent Grant Thornton in a way that enhances our reputation and distinguishes us in the marketplace

     

    • our global network is a strength and we act in a manner that preserves the integrity of that organisation

     

    • when speaking in public forums we give GTIL's view and not our own
    • when using social media we do not engage in defamatory comments or make statements that might damage the company's reputation – remember that comments in 'private' forums can easily become 'public'

     

    • describing "Grant Thornton" and acting in a manner consistent with this description, which means adhering to the following principles in what we say and how we act

     

    • GTIL and its member firms are not a global partnership · GTIL does not provide services to clients

     

    • GTIL and its member firms are not agents of and do not obligate, one another and are not liable for one another’s acts or omissions.

     

    • dealing with issues

     

    • we speak up within our company if something ‘feels wrong’ so that we can resolve issues and maintain our high standards

     

    • individuals are encouraged to consult on concerns without fear or reprisal or retaliation
    • unforeseen events
      • we follow the business continuity plan to protect ourselves and ensure business activities are not interrupted in the wake of an unforeseen event.

    Seeking advice

     

    The Code of Conduct sets out guiding principles for the standard of behaviour we expect. Each of us has a personal responsibility to understand and live up to these principles and in doing so bring our values to life.

     

    However, the Code of Conduct is not intended to be a substitute for our individual responsibility to exercise good judgement, to consult with others when faced with difficult decisions which compromise GTIL's reputation.

     

    If you have questions about the Code of Conduct or its application in practice, you are encouraged to seek advice. There are a number of ways in which you can find advice and guidance including:

     

    • consulting your line manager

     

    • consulting members of your team

     

    • speaking to other people in the company such as the GLT, department heads, the Risk and regulatory team, the Legal team and the People and Culture team

     

    • referring to written policies, procedures and guidance, which include internal sources such as:
      • the myGTIL portal
      • risk management bulletins, alerts and other publications
      • GTInet

     

    Putting the code into practice

     

    If you are faced with a situation where you are unsure what to do, use this list of questions below as a framework to help you make a decision and remember that asking others for advice is a strength not a weakness:

     

    • Do I need to consult?

     

    • Would I be happy for other people to know of my actions?
    • Would my actions seem reasonable to a reviewer?
    • Are my actions legal and in compliance with professional standards?

     

    • Am I upholding the values?
    • Am I treating others as I would expect them to treat me?
    • Would my actions damage the brand?
    • Are my actions the right thing to do?

     

    Compliance

    If you have concerns about compliance with this code of conduct please consult the section "Seeking Advice".

    Individuals who violate the code of conduct will be subject to disciplinary action, up to and including dismissal in accordance with GTIL or the secondee's home member firm's procedures, as the case may be.

    Individuals who in good faith report a matter which they reasonably believe represents legal or ethical obligations will not be subject to retaliation for doing so. Furthermore, no retaliation will be taken against an individual because of his or her assistance with, or

    participation in, any investigation of a suspected violation. Anyone who retaliates against another individual for reporting or participating in an investigation of known or suspected legal or ethical violations is in violation of the Code of Conduct and may be subject to disciplinary action.

    Please see Appendix A for examples of how to abide by the Code.