ALEX STEWART
INTERNATIONAL’S
CODE OF
PROFESSIONAL
CONDUCT
PRINCIPLES OF PROFESSIONAL CONDUCT
•Integrity
•Conflicts of interest
•Confidentiality
•Anti-bribery
•Fair marketing
COMPLIANCE CODE
WHO DOES IT APPLY TO?
• ASIC Group Commitment to IFIA Compliance Code
• Group partners and senior management
• Employees
• Subcontractors
• Suppliers
• Consultants
IMPLEMENTATION OF CODE
•IFIA Compliance Programme
•Principles, policies, guidelines
•Compliance officer, Management Committee, Training
•Management declarations
AUDIT MANAGEMENT
• ASIC Compliance Officer
• Internal integration with ISO procedures
•Independent external audit – HQ and selected offices
INTEGRITY
• Confidentiality in reporting
• Tolerances must be within parameters
• Methods to be proven, applicable and auditable
• Reports must reflect actual findings
• Client abuse or pressure to be reported to management
CONFIDENTIALITY
• All information is business confidential
• All employees to sign non disclosure agreement
CONFLICTS OF INTEREST
•All business should be free of conflict of interest
•No partner, manager or employee should hold outside
interests e.g. Client, supplier, competitor that could
damage Company’s performance or reputation
•Employees should not conduct business with family
members
•Client abuse or pressure to be reported to management
FAIR MARKETING
• Non critical of competitors/fellow IFIA members
• Marketing must not mislead clients
• Marketing must be fair
• Marketing must be representative and truthful
• Marketing promotional materials must be accurate
• Gifts and hospitality should be made for the right
reasons and without obligation
ANTI-BRIBERY
•All partners, management and staff are prohibited
from offering, soliciting, giving and receiving bribes
•All knowledge of any bribes must be reported to
ASIC/IFIA Compliance Officer
•Any client applying pressure through bribes must be
reported to the compliance officer
ACCOUNTING
•Accounts and financial records must be accurate
•Off books accounting is not permitted
•Accounts should be audited annually
SUMMARY
•
•
•
•
•
•
•
Do not do anything which you believe to be illegal or
unethical
Do not use any company property for your own benefit
Do not engage in any transaction, which does not have a
genuine, legitimate business purpose
Ask yourself whether any contemplated transaction or
business practice would withstand investigation
Do not do anything, which could require you to be
untruthful
Report any breaches or abuse of IFIA Code to ASIC
Compliance Officer
Reported breaches will be investigated, disciplinary action
will prevail if breached proven and substantiated
THANK YOU FOR YOUR ATTENTION
Alex Stewart International Corporation
Sefton Business Park
Netherton
Liverpool
Merseyside
L30 1RD
T: +44 151 525 1488
F: +44 151 530 1563
E: inspections@alexstewartinternational.com
W: www.alexstewartinternational.com