Code of Ethics and Business Conduct

Our code of ethics and professional conduct outlines the ethical principles that govern decisions and behaviour at Jones and Palmer. They give general outlines of how employees should behave, as well as specific guidance for handling issues.

Our Core Values form the basis for this policy


Build Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. We are committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

Jones and Palmer is an equal employment opportunity employer and is committed to providing a workplace that is free of discrimination of all types, and from abusive, offensive or harassing behaviour. Any employee who feels harassed or discriminated against should report the incident to their manager or to human resources.

Create a Culture of Open and Honest Communication

At Jones and Palmer, everyone should feel comfortable to speak their mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

Jones and Palmer will investigate all reported instances of questionable or unethical behaviour. In every instance where improper behaviour is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith.

For your information, Jones and Palmer’s whistleblower policy is detailed in Appendix 1 (Company Handbook Section 6. Protected Disclosure Policy (Whistleblowing)). 

Employees are encouraged, in the first instance, to address such issues with their managers, the HR manager or our nominated confidante, as most problems can be resolved swiftly. Should this not be possible, or should the employee not feel comfortable raising the issue in this manner, we do have an open-door policy to Jones and Palmer’s Managing Director. You can always approach him if you have any issues.

Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behaviour does not simply happen; it is the product of clear and direct communication of behavioural expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At Jones and Palmer, we want the ethics dialogue to become a natural part of daily work.

Uphold the Law

Jones and Palmer’s commitment to integrity begins with complying with laws, rules and regulations where we do business. In addition, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Jones and Palmer policy, we should seek the advice from the HR manager. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Because of the nature of our business, some legal requirements warrant specific mention here; please refer to Appendix 2 (Company Handbook Section 23. Confidentiality Policy, and Section 35. Insider Trading). 

Competition

We are dedicated to ethical, fair and vigorous competition. We will sell Jones and Palmer products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Jones and Palmer or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorised use, copying, distribution or alteration of software or other intellectual property.

Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material non-public information with respect to Jones and Palmer, its securities, business operations, plans, financial condition, results of operations or any development plans. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material non-public information.

Health and Safety

Jones and Palmer is dedicated to maintaining a healthy environment. A safety manual has been designed to educate you on safety in the workplace. If you wish to have a copy of this manual, please see the HR department.

Avoid Conflicts of Interest

Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of Jones and Palmer may conflict with our own personal or family interests. We owe a duty to Jones and Palmer to advance its legitimate interests when the opportunity to do so arises. We must never use Jones and Palmer property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Jones and Palmer.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or the HR department.

Gifts, Gratuities and Business Courtesies

Jones and Palmer is committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favourable treatment of outside entities by Jones and Palmer was sought, received or given, in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom Jones and Palmer does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of Jones and Palmer or customers, or would cause embarrassment or reflect negatively on Jones and Palmer’s reputation.

Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at Jones and Palmer. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at Jones and Palmer to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that Jones and Palmer maintains, or may establish, a business relationship with.

Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts, must be particularly careful to avoid actions that create the appearance of favouritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when Jones and Palmer is involved in choosing or reconfirming a supplier, or under circumstances that would create an impression that offering courtesies is the way to obtain Jones and Palmer business.

Meals, Refreshments and Entertainment

We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:

  • they are not inappropriately lavish or excessive;
  • the courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity;
  • the courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future; and
  • the employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with their manager or co-workers, or having the courtesies known by the public.

Gifts

Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:

  • flowers, fruit baskets and other modest presents that commemorate a special occasion; and
  • gifts of nominal value, such as calendars, pens, mugs, hats and t-shirts (or other novelty, advertising or promotional items).

Generally, employees may not accept compensation, honoraria or money of any amount from entities with whom Jones and Palmer does or may do business. 

Employees with questions about accepting business courtesies should talk to their managers or the HR department.

Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Jones and Palmer. An employee may never use personal funds or resources to do something that cannot be done with Jones and Palmer resources. Accounting for business courtesies must be done in accordance with approved company procedures.

Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

  • the practice does not violate any law or regulation or the standards of conduct of the recipient’s organisation;
  • the business courtesy is consistent with industry practice, is infrequent in nature and is not lavish; and
  • the business courtesy is properly reflected on the books and records of Jones and Palmer.

Set Metrics and Report Results Accurately

Accurate Public Disclosures

We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Employees should inform a Board member and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made, or if subsequent information would affect a similar future filing or public communication.

Corporate Record-keeping

We create, retain and dispose of our company records as part of our normal course of business, in compliance with all Jones and Palmer policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books, in accordance with Jones and Palmer’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorised audit, nor interfere with any auditor engaged to perform an internal independent audit of Jones and Palmer books, records, processes or internal controls.

Promote Substance Over Form

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.

At Jones and Palmer, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that Jones and Palmer is committed to doing the right thing. At times, this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

Although Jones and Palmer’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.

Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code, and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department.

Jones and Palmer take seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of employment.

Be Loyal

Confidential and Proprietary Information

Integral to Jones and Palmer’s business success is our protection of confidential company information, as well as non-public information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses or non-public information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and non-public information without a valid business purpose and proper authorisation.

Use of Company Resources

Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.

Employees and those who represent Jones and Palmer are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Generally, we will not use company equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity, except for company-requested support to non-profit organisations. We will not solicit contributions nor distribute non-work related materials during work hours.

In order to protect the interests of the Jones and Palmer network and our fellow employees, Jones and Palmer reserves the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the internet or Jones and Palmer’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Questions about the proper use of company resources should be directed to your manager.

Media Inquiries

Jones and Palmer is a high-profile company in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the HR department or Managing Director. No one may issue a press release without first consulting with the HR department or Managing Director.

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:

  • Does what I am doing comply with Jones and Palmer guiding principles, Code of Conduct and company policies?
  • Have I been asked to misrepresent information or deviate from normal procedure?
  • Would I feel comfortable describing my decision at a staff meeting?
  • How would it look if it made the headlines?
  • Am I being loyal to my family, my company and myself?
  • What would I tell my child to do?
  • Is this the right thing to do?

Information and Resources

Managing Director
James Houston

Director of Human Resources
Heidi Hill

Directors
Stephen O’Brien
Jim Robinson
Steven Tolley

 

Appendix 1 (Company Handbook Section 6. Protected Disclosure Policy (Whistleblowing))