Business Code of Ethics Policy
This policy deﬁnes our responsibilities and expectations for ethical and responsible business practices for our Business Partners.
2. Core Values
Incubeta asks all of its employees to make continuous eﬀorts to embody our values. The company values exist to help and support us in the way that we approach and deliver our work and how we work with each other. Our values contribute to the image we present to our colleagues, clients and partners. Our values are:
- → Earn Trust
- → Exceed Expectation
- → Dare to Lead
- → Help Others Succeed
3. Who must follow this code
This policy applies to Incubeta UK Limited (“Incubeta”) and its operations, including all persons working for Incubeta or on behalf of Incubeta in any capacity, including employees at all levels, directors, oﬃcers, agency workers, third-party representatives and Business Partners.
Business Partners include joint venture partners, vendors, franchisees, distributors, suppliers, aﬃliates, contractors, consultants, agents and clients.
4. Laws and Regulations
Incubeta, its employees and Business Partners are required to comply with all laws and regulations in the markets in which they operate including environmental, safety, human slavery and fair dealings laws. We also expect our Business Partners to proactively monitor and measure the compliance of laws of its suppliers.
Incubeta reserves the right to measure the compliance to this policy when making a business relationship or procurement decisions. We may terminate relationships with Business Partners who show persistent disregard to the compliance of this code.
We expect our Business Partners to have policies and controls in place to monitor ethics and compliance related controls that are industry standard for its business operations and size. Business Partners are responsible for ensuring this policy is communicated with all employees and contractors.
We periodically request our Business Partners to complete a Due Diligence Questionnaire to monitor the operational practices and governance of this policy and may require supporting evidence to enable assessment. We expect our Business Partners to work collaboratively with Incubeta across all the following parameters outlined hereafter.
6. Health and Safety
Incubeta places a high priority on providing a safe workplace and minimising the risks identiﬁed by the Health and Safety at Work Act 1974 and associated legislation.
We require our Business Partners to provide a safe workplace environment and implement measures that enforce best practices that comply with UK laws and regulations and or laws applicable to their markets.
What is bribery and corruption?
Bribery is oﬀering, promising, giving or accepting any ﬁnancial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
An advantage includes but is not limited to money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
Incubeta requires its employees, workers and Business Partners at all times to act honestly and with integrity as well as comply with the Anti Bribery Act 2010.
Bribing a Public Oﬃcial
Incubeta expressly prohibits the bribery of a UK or foreign oﬃcial in order to obtain or retain business or an advantage in the conduct of business.
Gifts and Entertainment
Incubeta allows reasonable and appropriate hospitality or entertainment given to or received from Business Partners. Giving and accepting of gifts is allowed if the following requirements are met:
- (a)it is not made with the intention of inﬂuencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or beneﬁts;
- (b)it does not include cash or a cash equivalent;
- (c)it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;
- (d)it is given openly, not secretly; and
- (e)it complies with any applicable local law.
Promotional gifts of low value such as branded stationery to or from Business Partners will usually be acceptable.
Reimbursing or accepting an oﬀer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justiﬁable. The intention behind it should always be considered.
8. Conﬂict of Interest
A Conﬂict of Interest (“Conﬂict”) is a situation or arrangement where Incubeta, or a company with which it has an association, and/or any of its employees is subject to multiple inﬂuences, the competition of which might adversely aﬀect decision-making or outcomes in the course of conducting business.
Incubeta requires its employees, workers and Business Partners to consider the types of potential conﬂict of interest relevant to its services and activities. As such, full disclosure must be provided for all relevant personal, ﬁnancial or other interests in relation to any business relationship. Where an interest is declared, Incubeta will assess the situation taking into account the materiality of the conﬂict of interest and any necessary mitigation measure and will inform the party of the ﬁnal decision on how to proceed.
Incubeta requires Business Partners to apply good judgement and act with integrity. Any conﬂict must be reported promptly in accordance with the whistleblowing procedure outlined within this document.
Incubeta is committed to ensuring personal data, organisational information and all client information is treated under strict conﬁdentiality.
We expect our employees and Business Partners to act with due diligence and use the correct measures to safeguard conﬁdential information at all times against unauthorised access and comply with all laws applicable to the Business Partner market and any contractual obligations agreed by Incubeta and the Business Partner.
All intellectual property created by Incubeta; its employees or workers for the purpose of business operations and independently (whether prior to the start date or otherwise) of any agreement with a Business Partnerbelongs to Incubeta.1 This includes any patents, trademarks, copyrights, proprietary information and trade secrets. Incubeta is committed to respecting the intellectual property of Business Partners and it requires all employees to respect the intellectual property of Business Partners and any third parties.
Incubeta endorses and adheres fully to observing the eight individual rights set out under the UK GDPR as well as complying with The Data Protection Act 2018.
As per our own practices, we require our Business Partners to observe fully the conditions regarding having a lawful basis to process personal information and meet its legal obligations to specify the purposes for which information is used, obligations on how data is held and safeguarded.
10. Human Rights
At Incubeta we recognise our responsibility to operate in a manner that ensures people are treated with fairness, dignity and respect. We are committed to protecting human rights and ensure all functions and operations within our business are contributing positively towards this.
1 For clarity, this does not supersede any contractual obligations agreed with clients.
We ﬁrmly believe that a united approach is always the best approach and our code of conduct policy helps us ensure everyone is treated equally and respectfully.
Incubeta have a zero tolerance policy to forced labour and child labour. We require our Business Partners to comply with the Modern Slavery Act 2015 and all local laws, regulations and jurisdictions.
Equality, diversity and inclusion
Incubeta endorse the promotion of inclusivity and diversity. It seeks to ensure that the workplace is supportive of its staﬀ and one where individual respect is shown to all members of staﬀ, regardless of age, diability, gender, marriage or civil partnership, pregnancy or parental status, race, ethnic background, culture, sexual orientation, religion or belief, sex or any other factor. All staﬀ will be treated equally and fairly and supported and encouraged to perform to their potential.
We require our Business Partners to operate in a manner that respects human rights and the dignity of others including but limited to its employees, associates, partners and customers regardless of the parameters outlined above. We also expect Business Partners to promote a safe and fair workplace environment free of any bias, bullying or harassment.
11. Environmental and Social Responsibility
Incubeta is committed to minimising the environmental impacts of our business operations and improving the lives of local people. We communicate to all our employees the importance of individual responsibility and innovation in helping us enhance, protect and preserve the environment and make positive impacts on our communities. We continuously observe practices in our business operations and drive policies to enforce environmentally friendly behaviour in our oﬃces. We are committed to working with charities who share our values and regularly donate to causes that improve the lives of people and support positive environmental changes.
We expect our Business Partners to comply with all local environmental laws and regulations and meet industry standards in the industries it operates in. As such, we expect Business Partners to demonstrate a commitment to acting socially responsible in all operations and business decisions and demonstrate continuous improvement in their approach to sustainable and responsible business practices.
If you are concerned that there is a threat of, or breach of this policy you should report it to Rahela@Incubeta.com. If you prefer to make a conﬁdential report you can ﬁll out this form. This form will be received by the HR department.