Code Of Conduct
At Green Hive Management , we expect each and every one of us to always do the right thing and to challenge where others do not.
The Code of Conduct is not a set of rules and it cannot cover every possible situation. We are all required to use our best judgment in applying the principles of the Code and to demonstrate its spirit in everything that we do.
As well as setting out what is expected of everyone, the Code sets out where and how to seek guidance when the answer may not be clear. Do not let a question go unanswered and do not let unacceptable conduct go unchallenged. Green Hive Management will always support you for doing the right thing.
We act honestly
We respect everyone
We make safety personal
We support open and fair competition
We do not misuse property or information
We act honestly
False claims
We risk making false claims if we:
- Claim for something we don’t honestly believe we are entitled to
- Knowingly or recklessly misrepresent or inaccurately record time spent or materials or services provided
- Conceal defects or fabricate evidence even if the client requests or supports what we are doing and even where we believe it is for the benefit of our business
We must take particular care when calculating and claiming or applying for:
- Payment
- Extension of time
- Losses and expenses
- Variations
- Interim and final estimates, valuations and measurements
We must make sure our assessments are as reasonable and accurate as possible, backed-up and substantiated.
Bribery & corruption
We refuse to participate in any kind of corrupt activity, either directly or through third parties. This includes offering, giving or receiving bribes or improper payments including facilitation payments, even if such practices are perceived as part of local business practice.
An allegation of bribery can seriously damage our reputation. It is better to miss out on business than compromise our integrity.
Bribery – offering, providing or receiving something of value including cash, gifts, hospitality or entertainment as an inducement or reward for something improper. Usually, but not always, it is to obtain or retain business or gain an illegitimate advantage.
Corruption – dishonest practices including, but not limited to, bribery, extortion, fraud, deception, collusion, abuse of power, embezzlement or money laundering.
Facilitation payments – sometimes referred to as grease payments, facilitation payments are usually small payments or gifts generally made to junior or lower level public officials to speed-up or “facilitate” actions that officials are duty bound to perform.
The payments can appear harmless as they are low in value or part of local custom or culture and are considered the way things are done, however they are illegal in most countries.
We make no distinction between facilitation payments and bribes. Any type of facilitation payment is prohibited, large or small, and even if others engage in such practices. There is one exception and that is when the facilitation payment is being extorted or you are being coerced to pay it. Extortion means if your safety or liberty, or that of your family, is under threat or you feel that you have no alternative to pay for personal or family peace of mind. In these circumstances make the facilitation payment, record it clearly and report it immediately to your Finance Director and your compliance, legal or business integrity team. In these circumstances it is the company’s duty to support you.
We always:
- Seek to avoid even the appearance of wrong doing
- Record all payments and benefits provided to public officials
- Report any attempts to bribe us or solicit bribes from us
- Report any suspicions we have of bribery or corruption
We never:
- Participate in any form of corrupt behaviour
- Engage public officials to provide services without approval from Group Head Office
- Conceal or fail to record accurately and completely the true nature of our activities
- Falsify or tamper with the company’s books or records
- Pay more than the fair market value for goods and services
Complete & accurate records
Our books, records and financial reporting should accurately reflect the underlying transactions and represent the true state of the business, based on applicable accounting standards and our company accounting policies. They are an essential part of doing business correctly, honestly and openly and protect us, our customers and those we work with.
Many serious offences involve falsifying or tampering with the books or failing to account for an activity properly. Some serious offences start out as attempts to cover up relatively minor offences.
Project reporting is part of our accounting records. The appropriate accounting for a project may be more conservative than our commercially expected outcome. It is important that our record keeping recognises this distinction.
If your role involves the preparation and maintenance of accounting records of any kind, you must adhere to the guidelines set out in the Group Finance Manual or other applicable business guidelines.
The appropriate recording of a transaction or project is not always obvious. It is important to agree the proper recording of any transaction based on the facts of the situation and agree this with the relevant Finance team.
We always:
- Maintain and present financial records in accordance with the laws of each country we operate in
- Comply with internal financial controls and only process transactions in accordance with our delegated authority or once specific approval has been received
- Record transactions accurately in the proper accounting period supported by appropriately detailed evidence
- Comply with any applicable document retention and disposal policies
We never:
- Record things in the wrong place or way, even if the customer wants us to
- Fail to record any transaction or expenditure or record it in an ambiguous or misleading way
- Destroy or alter any information or data that must be kept for litigation, an investigation or other legal reasons
Tax evasion
Tax evasion is an illegal practice whereby measures are undertaken to fraudulently make a non-payment or underpayment of tax. Allegations can seriously damage our reputation and a conviction could result in sanctions including confiscation of revenue and the imposition of fines.
This does not cover tax avoidance or tax planning which do not constitute tax evasion. See our tax policy for further information.
In the UK, it is a criminal offence if Green Hive Management fails to prevent the facilitation of tax evasion by an associated person.
Associated person – someone acting on behalf of Green Hive Management during the course of their work. This is not restricted to the employees of Green Hive Management but can also apply to agents and subcontractors.
We always:
- Act honestly and openly
- Seek to avoid even the appearance of wrong doing
- Fully disclose all of our tax liabilities
- Manage our tax affairs in accordance with our tax policy
We never:
- Engage in tax evasion
- Assist anyone else to engage in tax evasion
We respect everyone
Developing our people
We are committed to helping people achieve their best. Developing our people is the best way to develop our organisation.
All of our decisions about recruitment, hiring, compensation, development and promotion must be made solely on the basis of ability, skills, experience, behaviour, performance and potential to do the job.
Through employing the best people and creating an environment in which they can develop we will achieve our business goals
Our commitments:
- To employ people who will uphold our values and our standards of ethical conduct
- To create a working environment in which all our people feel valued
- To encourage or support all of our people to achieve their best
- To identify and satisfy training and development needs so our people can perform and develop their potential
- To have a fair system of recognition, reward and promotion
- To not deny promotion or opportunity on the basis of any form of discrimination
- To maintain a safe and healthy working environment for all our people
Equal opportunities
We treat everyone equally and embrace difference. Equal opportunity in the workplace is about ensuring that everyone is treated the same, regardless of their differences. They are treated with dignity and respect and have equal access to opportunity. The criteria for employment and promotion are the same for everybody. Its purpose is to ensure fairness, act against all forms of discrimination and promote talent on merit.
We value difference and believe diversity of people, skills and abilities is a strength that helps us to achieve our best. We also believe everyone should be recruited and promoted on the basis of their personal ability, contribution and potential. We are committed to ensuring that everywhere across our organisation we promote, support and maintain a culture of fairness, respect and equal opportunity for all.
Our commitments:
- To provide equal opportunities for all
- To maintain a supportive, inclusive work environment free from discrimination, harassment, victimisation and bullying, see the Bullying, harassment & discrimination page.
- We hire the best candidate for the job and ensure they are appropriately qualified and respect that diversity brings value to our work environment
- We promote talent on the basis of merit
- We comply with all employment laws
Bullying, harassment & discrimination
We do not tolerate bullying, harassment or discrimination. We are committed to creating an inclusive working environment in which everyone is respected and can flourish equally, without fear or favour.
We do not tolerate behaviour or attitudes that support coercion, intimidation or discrimination. Whenever and wherever we observe such behaviour, we always challenge it and support others who do so.
Bullying and harassment refer to any action or behaviour that any individual or group finds unwelcome, humiliating, intimidating, threatening, violent, hostile or discriminatory. Employees should be particularly sensitive to, and aware of, actions that may be acceptable in one culture but are not in another.
Discrimination means treating a certain person or group based on factors such as age, race, religion, nationality or ethnic origin, colour, gender, marital status, disability unrelated to the task in hand, union membership or political affiliation. This is not necessarily an all-inclusive list and factors could vary based on the laws of where your business is located.
We always:
- Speak up and do something about bullying, harassment or discrimination
- Encourage and support those who challenge or report such behaviour
We never:
- Tolerate any action or behaviour that could be viewed as bullying or harassment
- Accept any kind of discrimination
- Make inappropriate jokes, try to humiliate a colleague or spread gossip and rumours
- Threaten a colleague with physical or verbal abuse
Human rights
We respect and protect human rights
Wherever we work in the world we ensure that we do not exploit anyone. We uphold the rights of all those who work for or with us and of the communities in which we operate. This means refusing to do business with any individual, company or organisation that fails to uphold the standards and principles of basic human rights or has links with an oppressive regime that give us cause for concern.
Human rights
The United Nations Universal Declaration of Human Rights proclaimed certain fundamental rights and freedoms. These include the right to life, liberty and security; equal rights of men and women; the right to protection under the law and against discrimination, slavery, servitude, torture, or inhumane or degrading treatment; and freedom of speech, thought, conscience and religion.
We do not tolerate forced, debt bonded, indentured labour practices, or human trafficking. In the UK, we expect every party who we have dealings with to adhere to the principles of the Modern Slavery Act 2015, as we do ourselves.
Our commitments:
- To support all the principles set out in the United Nations Universal Declaration of Human Rights
- To support the principles of the Modern Slavery Act 2015 in relation to slavery and human trafficking
- To support the International Labour Organisation’s standards regarding child labour and minimum age
- To comply with national legal requirements regarding wages and working hours
- To comply with this Code and every business policy setting out the rights of everyone who works for or with us, or who is impacted in any way by our activities
- To observe, protect and promote these rights wherever we operate
- To encourage our staff and suppliers to identify any person they think may be at risk from these practices and so help us to help people at risk
The environment
We care about the natural world and recognise our responsibility to work within environmental limits
For an infrastructure business like ours, maximising the use of infrastructure assets for our clients whilst minimising use of resources is essential if we are to minimise our impact on the environment, contribute to society and offer best value. Key to this is that the infrastructure we design and construct is resilient and that we use the earth’s resources, both its materials and people, carefully and responsibly, using what we need, but being mindful of tomorrow’s needs as well.
Our aim is for customers and investors to choose Green Hive Management because we contribute to their long-term profitability by adopting and promoting more sustainable solutions. This is not a choice about sustainability or profit.
By looking for opportunities to add value through sustainability, we will deliver additional benefits to society and help grow the business. As a world-class infrastructure group, this is the right thing to do.
We have, therefore, set our own ambitious vision and have a strategy, the Blueprint, for establishing a more sustainable business.
Each one of us also has a role to play: through our decisions we can offer more sustainable solutions, minimising our impact on the environment.
Sustainable development
We know the world’s resources are finite. We also recognise that sustainable development – particularly of public infrastructure – is vital to maintain and improve the standard of living in the countries in which we operate. It is our responsibility to do all we reasonably can to reconcile these two statements.
Our Commitments:
- Continually improve our environmental performance and results and review it on a regular basis
- Aspire to provide infrastructure that enhances ecology and ecosystem services
Communities
We respect the community around us and commit to contributing to its improvement.
Green Hive Management contributes positively to communities wherever we work through the services we provide and the lasting infrastructure we leave for the public, such as schools, hospitals, other social infrastructure and transport systems. Furthermore, we run community investment programmes that support local people, businesses and environmental projects.
We are never complacent about the way we work in a local area, or the impact our operations can have on local people and their environment. We listen, we care about people’s concerns and we act on them wherever and whenever we can. We will proportionately address community needs as part of our project work and positively impact, through our community benefit programmes, the social, economic, or environmental circumstances of the communities we work in.
We believe that our strategy to be a more sustainable business and profitable markets, healthy communities and environmental limits are not competing interests and that when aligned they can create shared value. In order to be a successful and profitable company, we need to realise that.
Our commitments:
- We will respect the cultures and laws of the countries in which we operate
- We will take into account the concerns of the wider community, including both national and local interests
- We will listen to the concerns of local communities and, wherever we can, we will act to mitigate them
- We will keep the communities affected by our projects regularly updated and informed
- We will seek to employ local people and local resources on our projects wherever possible
- We will work with communities to understand how we can help them to improve their wellbeing
- We will collaborate with the project stakeholders, customers and impacted communities to help improve and optimise our social impact
- We will keep records of the resources and time spent delivering community benefit and social value activities, clearly showing who worked alongside us and who we provided benefits to
We make safety personal
We support open and fair competition
Gifts & hospitality
We make sure gifts and hospitality are reasonable and don’t improperly influence a decision.
To foster goodwill or working relationships employees may occasionally receive or offer gifts or hospitality. Hospitality includes invitations to social functions, sporting events, meals and entertainment. Gifts can vary in type and are generally low value or customary tokens of appreciation.
Any gifts or hospitality we receive or give should always be customary and reasonable in terms of value, frequency or timing. Information on limits and guidance may be available within your business unit and you should use your judgement to assess if the gift or hospitality offered or being offered is appropriate.
We always:
- Ensure any gifts or hospitality offered, received or declined is recorded on our register
- Comply with financial limits and approval requirements as set out in our Gifts & Hospitality policy
- Check with your Legal, Compliance or Business Integrity team before offering gifts or hospitality to public officials
- Check with customers before offering any kind of gift or invitation as they may have rules requiring them to report or refuse such things
We never:
- Offer or accept gifts or hospitality if we think it will impair objective judgement, inappropriately influence a decision or create a sense of obligation
- Solicit gifts or hospitality
- Offer or accept gifts of cash or cash equivalent e.g. vouchers
Conflict of interest
Conflicts of interest arise when we find ourselves in a position where two or more interests compete, potentially compromising our judgement or independence. Usually the conflict is about individuals benefiting at the expense of the company or another employer. Very often, perceptions of a conflict of interest can be just as damaging as an actual conflict of interest.
We take great care not to involve ourselves in anything that can give rise to a conflict between our interests and those of the company.
Given the size and nature of our organisation, we recognise that conflicts of interest are sometimes unavoidable. As soon as we realise there’s a potential conflict, we must disclose it and seek approval or guidance.
Employment outside Green Hive Management
In general, staff may not be employed outside Green Hive Management. However, you may serve as an officer or a member of the board of directors of another business if permitted to do so under your local Conflicts of Interest policy. Please check this policy for any approval or registration requirements before accepting any such appointment.
We always:
- Take great care with contracts between Green Hive Management and a family member, friend or company/business they own and notify our manager or supervisor in writing and abstain from the decision-making process
- Take great care with any personal investments or business interests, or those of family members or associates, which could affect or appear to affect our decision-making responsibilities, or conflict with the interests of the company or its customers or suppliers. (Holdings of less than 1% in a publicly quoted company are excluded.)
We never:
- Use our position, contacts or any knowledge gained at Green Hive Management for personal gain or to benefit family or friends
- Pay a third party more than a contractually agreed, market-based fee for goods or services
- Accept gifts or hospitality that could impair our judgement or independence, or be open to misinterpretation
- Do anything that might create the impression that customers or suppliers have a contact in Green Hive Management who can exert influence on their behalf
Agents & representatives
We only use agents or representatives if we have to and they act to standards consistent with our Code.
Agents and third party representatives provide help, advice and local knowledge that can be essential to business activities. At all times, they must operate in accordance with our standards, particularly in the areas of bribery or corruption.
If you are using the services of an agent or third party representative, it is your responsibility to make sure they are aware of, and operating in accordance to, our Code of Conduct. Ignorance of what others are doing on our behalf or in our name is no excuse.
We always:
- Obtain appropriate approval before appointing an agent or third party and follow the process set out in the Green Hive Management Commission Agreements policy or other business policies relating to agents or third parties
- Follow the third party assurance process
- Complete due diligence on experience, background and reputation
- Ensure we understand what third parties will do on our behalf
- Make sure that all money can be properly accounted for
We never:
- Permit anyone to offer bribes or make facilitations payments on our behalf
- Permit anyone to do anything that we would not be permitted to do ourselves
- Enter into an agreement that does not have commercial rationale
- Pay any money to an agent or third party without a written binding agreement being in place and knowing exact details of what the payment is for
Public policy & political activity
We make sure any public policy or political activity we undertake is lawful, ethical and within our Code of Conduct. As a company, we do not participate in party political activities.
We all need to take the greatest care about what we say, do or support in the public or political domain.
Political contributions and donations can involve cash and non-cash, such as the use of corporate facilities, services or materials or employee time. Typically they are to support a governmental entity, or a political organisation, party or candidate.
Any political contribution in the EU needs approval from our shareholders. In the US, certain political contributions and campaign donations are permitted by law and are an accepted part of local custom and practice with respect to government/industry engagement.
The company does not make any political donations or contributions in the European Union. In the US, our businesses may make political contributions or donations, provided they are approved by the relevant business managing director and comply with policies and processes approved by the Chief Executive Officer of Green Hive Management. Any permitted political contribution should not be such that its scale or affiliation might be seen as excessive or inappropriate.
The laws on lobbying and government relations are complex and differ between jurisdictions. Whenever and wherever we act on behalf of Green Hive Management we must take great care about what we say, do or support in the public or political domain.
Your right to your political view
Everyone who works for us has the right to participate in politics in their personal capacity and to pay political contributions out of their own pocket, so long as this does not lead them into a conflict of interest. See the Conflicts of interest section. You can’t use the company’s time or resources to do so and you must never appear to represent the company or its views when engaging in personal political activities, unless specifically authorised by the company to do so.
We always:
- Make sure of our facts and have the appropriate approvals when talking with governments and public bodies
- Make sure all our interactions with public officials comply with our Code
We never:
- Engage in any public policy activity on behalf of Green Hive Management or appear to represent the views of the company unless expressly authorised to do so by the Corporate Communications and Investor Relations team
Boycotts, sanctions & legal requirements
We want to trade lawfully and properly at all times. So we comply with all trade regulations and restrictions imposed by recognised national and international authorities.
These include the United Nations, EU, US and the UK. This requires particular diligence. Breaking a country’s laws on these issues, even inadvertently, could mean we are unable to work in that country again. However, in some areas of the world there are attempts to impose illegal or unofficial restrictions. We do not comply with them and we refuse to engage in restrictive trade practices that are prohibited.
Boycotts and Sanctions
These are both forms of trade restriction. A boycott means a country refuses to do business with another (or others) and prohibits others from doing so. Sanctions (which include embargoes) seek either to limit or prevent trade with or inside specific countries or with specific individuals.
- As well as complying with all relevant local laws, we must obtain all necessary licences to import and export goods and other items and provide accurate information to customs authorities
- We must use all reasonable efforts to ensure that our goods’ ultimate destination and purpose are as we intend
Charities & non-profit organisations
We want to have a positive and beneficial effect on the communities we live and work in. So we actively participate in local communities and charitable activities. We also encourage our employees to devote time to good causes and empower them to conduct authorised volunteering and charity activities using a volunteering policy. However, when acting on the company’s behalf, we must be mindful of our responsibilities.
What’s appropriate?
If we are making a charitable donation or commitment of support using the company’s resources, we need to check if it’s appropriate and is approved in compliance with local business policies and processes. We realise that we can make significant impact by working with charities and non-profit organisations local to our projects targeting local needs. The charity must be bona fide and any use of our shareholders’ money or resources for charitable purposes should be consistent with our broad community support and our corporate responsibility policy.
Your rights as an individual
Of course you have every right as an individual to make personal donations to charity and participate in charitable activities for any causes you believe in. All we ask is that in these circumstances it is clear that you are acting in a personal capacity.
We always:
- Ensure the charity is appropriate and approved in compliance with local business policies and processes
- Check for potential conflicts of interest
- Keep records of the resources and time spent delivering charity and volunteering programmes, demonstrating who we invested in and how
We never:
- Offer or make a charitable contribution as an incentive or reward for obtaining or retaining business or for any other improper purpose
- Make a contribution to a charity unless we are sure the charity is bona fide and has all appropriate registrations
- Use charitable donations as a substitute for political payments
- Use company time or resources without permission
We do not misuse property or information
Confidential information
We keep confidential information safe and make sure it never gets into the wrong hands.
Any improper disclosure or misuse of confidential information about Green Hive Management can have a huge impact on the company. We must keep it safe, only share it internally on a ‘need to know’ basis, and only disclose it to a third party on a confidential basis and with appropriate authorisation to do so.
Confidential information
This refers to any and all confidential and/or proprietary information or material belonging to, or in the possession of, any member of the Green Hive Management. It may be oral, visual, in writing, or in any other form. It includes any information related to Green Hive Management:
- Financial information, business plans, projections or strategies, property, business practices and relationships, processes, systems, or methods of operation
- Specifications, pricing policies, marketing plans, costs or promotional activities
- Customer, supplier or employee information or agreements
- Technical information
- Inventions, innovations, improvements, know-how, trade secrets or other proprietary information
Confidential information belonging to joint ventures, customers or other third parties must be respected and protected in the same way.
We always:
- Ensure we protect confidential information
- Report any information we obtain that we think may be commercially sensitive
- Ask our Legal, Compliance or Business Integrity contact if there is any doubt about the use or disclosure of information
- Report confidential information received in error and return it to its rightful owner
- Make sure customers, partners, suppliers and other third parties protect confidential information
We never:
- Leave sensitive information lying around or unsecured, or otherwise fail to take care of it
- Divulge confidential information of or about a previous employer unless permitted to do so
- Use unsecured technologies and methods when exchanging confidential information
- Discuss confidential information in a way that it can be overheard in public
Disclosure
We disclose or communicate information about the company in a timely and accurate way, and we seek to inform and not mislead.
How we talk about ourselves plays a huge part in how much we are trusted. We always communicate with integrity. Whether favourable or unfavourable to Green Hive Management, the information we disclose is always timely, accurate, complete, truthful and reliable. We never seek to mislead.
Sometimes it’s possible to find yourself acting as a spokesperson when you didn’t really mean to. You should never communicate on behalf of Green Hive Management if you aren’t authorised to do so. And remember that internal communications are one press of a button away from being external communications.
Company communications
These are any internal or external messages from us or anyone we authorise to speak about us or our business. They include press releases, communications with news media or journalists, promotional materials and advertisements, public speaking opportunities or industry roundtables and other public statements.
Disclosures
These are statements submitted or published by us to shareholders, regulators, securities exchanges, the media and other third parties.
Computer systems
Company computer systems are for use at work. The company permits reasonable and appropriate personal use for non-work related purposes.
Our company computer systems and the information they contain are valuable assets. They must not be used for any improper purpose or in any way that might affect their operation or integrity.
Company computer systems
This includes information and communication technology, systems and equipment that are owned or used by Green Hive Management. They include:
- Desktop, laptop and handheld computers/devices, such as smart phones or tablets
- Servers and networks (including connections to public or external networks such as the internet)
- Storage devices such as memory sticks, memory cards, removable hard drives and CDs
- Telephones (including mobile phones) and computerised office equipment (such as fax machines, printers and scanners)
- Information stored in and transmitted by these technologies, such as emails, voice mails, instant messages, electronic files, database entries and internet postings
We should all assume that any company information stored or communicated on company computer systems is company property. We should all be aware that, subject to local law, the company reserves the right to monitor our emails and internet usage, whether work-related or personal.
Personal use is a privilege not a right and must not be abused.
We always:
- Follow all information security and acceptable use policies when using company computer systems for work-related or personal use or when accessing or storing company information on personal computer systems
- Take proper precautions to protect company computer systems and company information against loss, damage or theft
We never:
- Use company computer systems to access, obtain, create or distribute any material that’s illegal or offensive or that’s been obtained illegally. This includes obscene, pornographic, sexist, racist, defamatory and abusive material or material that is in breach of copyright.
- Have any expectation of privacy when using company computer systems for personal or non-work related activities, unless local laws state otherwise