Governance & Policies
Service Provider Code of Conduct
No matter which sector our clients work in, we apply the framework for legal and ethical business practice standards.
Introduction
The Company and its subsidiaries (“the Group”) believes that relationships with service providers should be based on the principles of integrity, honesty, accountability and compliance with laws and regulations. With this objective, the Service Provider Code of Conduct requires service providers, which include suppliers, contractors, professional advisors, consultants and other business associates, to adhere to this Service Provider Code of Conduct when conducting business with the Group. The Group may take the necessary action for breaches of the Service Provider Code of Conduct which includes but not limited to termination and preclusion from proposing any work for the Group for a pre-determined period.
The Code of Conduct
1. Objective and Scope of the Code
We respect the law at all times.
The Company expect its service providers to embrace the spirit of the Company’s commitment to integrity as set out in this Code. The Company employees are to adhere to the Code when dealing with its existing and potential service providers.
This Code provides guidance to both the Company employees and service providers on what it believes to be sustainable business relationships based on the key principles of integrity, honesty, accountability and compliance with applicable laws and regulations.
This Code shall apply to whatever form of entity incorporated and unincorporated, local and international.
2. Responsibility and Accountability
1. Service Providers
All service providers are:
(a) Expected to read and understand the Code, and consult the Company’s key contact if they have any questions regarding the Code; and
(b) Responsible for self-monitoring their compliance with this Code. If and when any situation arises that causes the service provider to operate in violation of this Code, the service provider should inform the Company key contact as soon as possible, and co-operate fully in any follow up action.
2. Employees
All employees are:
(a) Expected to ensure the ‘major’ service providers under their charge have been advised on the Code and signed off in the form provided in Appendix 1. In determining ‘major’ service provider, factors to be considered include criticality of goods and services, amount of transactions involved and frequency of dealing;
(b) Responsible to seek clarification from the Head of Department or relevant parties, in the situation where this or any part of the Code is not clear; and
(c) Required to review the compliance of service providers under their charge, according to the Code.
3. Principles
1. Antitrust (or Competition) Laws and Fair Dealing
All employees shall endeavour to deal fairly with the Company’s service providers and have a responsibility to ensure that they are familiar with applicable competition laws. No employee shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.
Service providers shall act lawfully in the proper handling of competitive data, proprietary information and other intellectual property, and comply with applicable laws regarding antitrust and fair competition. It is important to be aware of the laws, not only to avoid infringement but also to ensure that service providers are not engaging in anti-competitive activities that could damage the Company’s business.
2. Act with Integrity (Bribery and Corruption)
Service providers shall act lawfully in the proper handling of competitive data, proprietary information and other intellectual property, and comply with applicable laws regarding antitrust and fair competition. It is important to be aware of the laws, not only to avoid infringement but also to ensure that service providers are not engaging in anti-competitive activities that could damage the Company’s business.
3. Accountability
Service providers will maintain full accountability for services rendered/goods provided and honour their commitment on a timely basis and in accordance with their obligation under the specific agreements and undertaking with the Company.
4. Conflicts of Interest
All employees have a duty of loyalty to the Company which includes avoiding situations that may create, involve or give the appearance of a conflict of interest. All employees are expected to act in the best interest of the Company, disclose and resolve any potential conflict of interests in advance.
Service providers with a real or potential conflict of interest situation are expected to declare this to the Company even if such knowledge arises after appointment and to take action to proactively address that conflict as soon as it is known. If in doubt, these should be highlighted to the Company.
5. Honesty
Service providers shall provide honest and accurate representation about their organisation, qualification, experience, capabilities and references of previous work or engagements which they have undertaken.
6. Compliance
- Service providers shall have an unqualified responsibility to comply with all applicable laws and regulations, and lawful business practices that are conducted according to a high standard of business conduct.
- Service providers must take every effort to understand the Company’s compliance and business conduct requirements, and promptly report to the Company’s employees in charge for any potential activity that is inconsistent with this Code.
7. Favours and/or Unfair Advantage
During an evaluation process, service providers are refrained from entertaining or treating the Company employees involved in the evaluation and/or their families. Service providers should report to the Company if any the Company employees request for any such treatment.
8. Health, Safety and Environment
It is the Company policy to provide healthy and safe working conditions, and to maintain a safe, pollution-free and zero spillage operating practice that complies with national and international regulations and relevant standards and guidelines. Service providers are expected to perform in a manner that is consistent and compatible with this policy, and HSE performance are key factors in selecting service providers.
9. General
Procurement decisions will be made on service providers who share our commitment on principles as per item 2.3.1 above and based on the best value received, taking into account the merits of price, quality, performance and sustainability.
4. General Business Conduct
1. Sub-contract Arrangements
Any sub-contract arrangements or third party relationships shall be disclosed to and agreed with the Company.
2. Protection and Use of Assets
The Company’s assets are to be used for legitimate business purposes only. Assets include both tangible and intangible assets such as software programs, methods, tools and company records and files. Protection and honouring of assets should be reciprocal, and must extend to the use of assets of the service providers.
3. Confidentiality
All confidentiality and proprietary information concerning the Company is the property of the Company and must not be improperly disclosed to third parties.
4. Conflict of Interest
‘Conflict of interest’ describes any situation that could cast doubt on the service providers’ ability to act with total objectivity with regard to the supply of goods and services to the Company. The Company expects service providers free from any conflicting interests and to prevent or immediately disclose a conflict of interest or the appearance of a conflict of interest as soon as possible to the Company.
5. Offering and Accepting Business Courtesies
Service providers should use discretion and care to ensure that any items offered to or received by any of the Company employee is in the ordinary and proper course of business and could not reasonably be construed as a bribe or improper inducement. Business courtesies cannot be designed or appear to be designed to influence the recipient and secure unfair preferential treatment.
As a guide, offering and accepting business courtesies are permitted if:
- Serves a bona fide business purpose;
- Does not inappropriately influence, or appear to influence, any business decision;
- Is not offered during any pending bidding or negotiation process;
- Is given openly and transparently; and
- Is not unlawful or contrary to ethical business principles or local bus iness customs.
6. Reputation
Service providers are expected not to conduct in any manner that could damage the Company’s reputation and expose the Company to criminal, civil legal liability or other sanctions.
5. Business Conduct from Specific Service Providers
1. Consultants and Professional Advisors
The consultants and professional advisors will be providing advice, solutions and recommendations to the Company during the engagement. They must make certain that all information provided to the Company is based on sound and unbiased judgment, consider all the available facts and circumstances, and includes proper review.
Consultants and professional advisors of the Company are expected to deliver services as agreed and committing to the task until the job is completed within agreed timeline.
2. Suppliers of Goods and Services and Contractors
All goods delivered and services rendered by suppliers and contractors must meet the quality and safety standards required by applicable law.
6. Compliance with the Code
If a service provider wishes to report a questionable behaviour or possible violation of the Code, it is encouraged to work with his or her primary contact in the Company (typically Head of Department) in resolving a business practice or compliance concern. However, the Company recognises that there may be times when this is not possible or appropriate. In such instances, a concerned service provider should write in confidence to the MD or Head of CGRM of LFG.
LFG may take the necessary action against service providers for breaches of the Code which includes but not limited to termination and preclusion from proposing for any work for the Company for a pre-determined period.
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