Integrity and honesty in all our business dealings are core to the reputation of Aggreko and its long-term success. Therefore, appropriate ethical behaviour is the responsibility of all Aggreko employees, and this policy provides clarity on our expectations in this area. It will help us to continue to be a great company to work for, maintain our reputation for exceptional customer service and help us manage the business to a consistently high standard and protect shareholder value.
Business ethics covers a broad range of areas. We set out our expectations under headings which we hope provide further clarity and support our ability to ensure its delivery across all our business activities.
Our dealings with each other
We are committed to teamwork and providing a positive and satisfying place to work, where business and personal goals can be met. To achieve this all employees should contribute to, and therefore be able to enjoy, a safe, respectful work environment free from all forms of discrimination and harassment.
We are committed to ensuring that all our activities are conducted in accordance with all relevant international, national and regional laws and regulations. It is the responsibility of each business to understand its legal responsibilities and set in place actions to ensure compliance with these. It is the responsibility of every individual employee to understand their responsibility in meeting these requirements.
Representatives of the Company should always ensure that Aggreko is recognised around the world for its fair dealing. Personal and business reputations live long after a project is complete. All employees must therefore be open and honest in all business practices, never knowingly making commitments on behalf of Aggreko which cannot be delivered. We must be open and honest about both our successes and areas for improvement and never seek to gain unfair advantage for Aggreko through inappropriate payments or inducements.
Inappropriate payments or inducements
The direct or indirect offer, payment, solicitation, or acceptance of bribes in any form or other payments or advantages, for business or financial gain or to influence a decision made by political or governmental employees, or for any other reason are illegal and unacceptable. These include “facilitation payments” for which we have a separate policy, which is available to employees through the Aggreko Ethics link on the MyAggreko intranet site. Additionally, we will not use or permit others to do such things for us. Any approach made to an Aggreko employee for an inappropriate payment should be reported to a line manager, the Company Secretary or the Group Human Resources Director.
Aggreko does not make payments or other contributions to political parties, organisations or their representatives or take part in party politics. Employees are free to make their own political contributions but they will not be compensated or reimbursed by Aggreko.
Aggreko seeks to compete ethically and employees must abide by competition laws and not take any improper collaborative action with a competitor or its representatives.
Conflicts of interest
Employees must avoid any activities in which personal interests could conflict with the interests of Aggreko. It is recognised that these circumstances are not always avoidable and therefore, in all cases where there is a potential conflict of interest, the details of the interest should be clearly and openly disclosed to management prior to entering into any agreements to do business.
Gifts, entertainment and hospitality
Employees should not accept gifts, entertainment or hospitality if this means that the giver will expect preferential treatment from Aggreko in return. Employees should not offer gifts, entertainment or hospitality in order to gain preferential treatment or be perceived by others as potentially influencing their decisions. This does not mean that giving or receiving gifts and entertainment are inappropriate in all circumstances. Entertainment can be fundamental in building successful business relationships. Therefore gifts, entertainment and hospitality should only be given or received where it is proportionate and reasonable in terms of value and frequency to do so, provided that no obligation could be, or be perceived to be, expected in connection with the gifts, entertainment or hospitality. As a general rule, employees should not accept gifts, entertainment or hospitality if they are not prepared to reciprocate. All gifts, entertainment or hospitality must comply with Aggreko’s Gifts, Entertainment and Hospitality Policy, which is available to employees through the Aggreko Ethics link on the MyAggreko intranet site.
Relations with foreign public officials
In nearly all of the countries in which the Company operates it is subject to Government licence and regulation. Relations with Governments need to be carefully considered to avoid any suggestion of improper conduct. Gifts and the provision of entertainment and hospitality to public officials are an area where we need to exercise great caution because they can create the impression that we are seeking influence or a favour. Where it is legal, respectful of local customs, and in accordance with the rules of the relevant Government body, gifts, entertainment or hospitality of reasonable and proportionate value may be provided to public officials in order to assist in the presentation of our services or to build cordial relations. Any gift, entertainment or hospitality given in such circumstances must comply with Aggreko’s Gifts, Entertainment and Hospitality Policy, which is available to employees through the Aggreko Ethics link on the MyAggreko intranet site.
Dealings with representatives, agents and consultants
All representatives, agents, consultants and other providers of services acting on behalf of Aggreko must fully comply with all relevant requirements set out in this policy. Aggreko employees must take all reasonable steps to ensure that before engaging any third party, their expertise, business experience and past performance in relation to compliance and integrity are reviewed and recorded, that the content of this policy is discussed with them and that written assurances are received that they will comply with the relevant requirements of this policy. All third parties engaged must only be paid appropriate and justifiable remuneration for the legitimate services rendered. All appointments of sales consultants must comply with Aggreko’s Sales Consultants Policy and for other significant engagements it may be necessary to employ a third party due diligence expert.
The Company will only support bona fide charities. All charitable donations must be appropriate and suitable and comply with Aggreko’s Charitable Donations Policy, which is available through the Aggreko Ethics link on the MyAggreko intranet site. Charitable donations must not be made if to do so would give the impression that they have been given with the intention of influencing customers or officials or anyone in order to win business.
When deciding to do business in any country or with new businesses, the responsible manager must take all reasonable steps to ensure that all relevant security, legislative, operational risks are identified and a plan is developed for managing those risks prior to any formal contractual agreements being signed. In some circumstances we may decide not to do business in certain countries (or with new businesses) where the risks to our application of this policy or security of our staff and assets are considered unacceptable.
Use of company assets by employees
Employees are responsible for the protection of all Aggreko property and for taking reasonable steps to prevent its misuse, misappropriation, damage or destruction. Company property is to be used solely for legitimate Aggreko business purposes and not for personal financial benefit or gain.
Use of the internet
Internet access, including the use of e-mail, is provided to employees as a business tool and should not be used for personal financial benefit or gain. The content of our policies for internet access and e-mail good practice should be read and understood by all staff with access to the internet.
Commercially sensitive information
Employees should respect confidential information of all types. Employees must not disclose commercially sensitive information to any persons outside Aggreko unless authorised to do so and must not disclose commercially sensitive information of others to those within Aggreko, except to the extent the employee is legally bound to do so. Information received in the course of business dealings should only be used for the purpose for which it is intended and never for personal gain.
All our external communications will be truthful, avoid concealment and not seek to create misleading impressions.
Safety and environmental responsibility
We will seek to understand the implications of Aggreko’s activities on the environment and the safety of our staff. We will fully comply with all statutory requirements relating to health and safety and environmental protection and where practicable we will seek to exceed these. Our intent and requirements for safety and environmental responsibility are provided in Aggreko’s health and safety policies and in our environmental policies.
Relationships with communities
We strive to be a good corporate citizen around the world, recognising our responsibility to work in partnership with the communities in which we operate and encourage such non-political, civic, philanthropic and charitable activities.
Aggreko will not condone any illegal or unlawful act committed by any employee in the course of his employment. In such circumstances, Aggreko will report the occurrence of the illegal or unlawful act that has come to its attention to the relevant authorities. If an employee is suspicious or aware that an illegal or unlawful act has been committed by another Aggreko employee in the course of his employment, this fact should immediately be reported to a line manager, the Company Secretary or the Group Human Resources Director.
Employees who suspect any breaches of this policy or any other violation should discuss this promptly with their line manager. In instances where this is not possible or appropriate, employees should raise the matter directly with the Regional Director, the Company Secretary or the Group Human Resources Director. Alternatively, employees can use the independent compliance hotline. Telephone numbers for the hotline can be found through the Aggreko Ethics link on the MyAggreko intranet site. Employees will not be blamed for speaking up and we will make all proper efforts to protect the confidentiality of employees who do raise concerns. Any attempt to deter employees from raising concerns will be treated as a serious disciplinary offence.
Application of the Ethics policy
The application of this policy is core to the management of Aggreko’s reputation and long-term success. It has therefore been approved by the Board of Directors, who will regularly review its application. All staff will receive a copy of the ethics policy and will receive relevant training in its contents; it will be included in induction training for all new recruits. It is the responsibility of managers and directors in each of the countries where we operate to identify possible risks to the application of this policy and develop practices that ensure compliance with it. However, appropriate behaviours are the responsibility of all employees. If any employee is in any doubt of the appropriate nature of an activity, they are to discuss the matter with their line manager, or raise it directly with the Company Secretary or the Group Human Resources Director. Alternatively, employees can use the independent compliance hotline. Telephone numbers for the hotline can be found through the Aggreko Ethics link on the MyAggreko intranet site. Any breach of this policy must be reported immediately and where necessary appropriate disciplinary processes will be initiated. All breaches will be investigated to identify why the situation arose and to identify actions that help prevent similar situations arising in the future.