Standards of Conduct

The Company expects the highest standard of integrity and conduct in all matters from all our staff. During your time with the Company, you will be expected to behave in a proper and reasonable manner and to maintain good professional working relationships. This includes your general behaviour, language and social interaction with other staff, customers, potential customers and other third parties. If you are found to be in breach of the Company's required standards of general conduct or behaviour, disciplinary action may be taken against you. 


You are required to act in the best interests of the Company at all times and must not place yourself in any position where your responsibilities may conflict with your private interests. We expect you to comply with all reasonable directions given to you and to observe all of the Company's policies, procedures and rules that are in force at any time. 


Your Contract contains various obligations with which you must comply. These policies expand upon and supplements the general obligations contained in your Contract.

General Standards

  • The Company expects the highest standard of integrity and conduct in all matters from all our staff. During your time with the Company, you will be expected to behave in a proper and reasonable manner and to maintain good professional working relationships. This includes your general behaviour, language and social interaction with other staff, customers, potential customers and other third parties. If you are found to be in breach of the Company's required standards of general conduct or behaviour, disciplinary action may be taken against you.

Media Statements

  • No interviews are to be given to representatives of the press, radio or television on any matter concerning the affairs of the Company unless you are authorised to do so by the Company. If you have any ethical concerns, you should raise these internally through the Whistleblowing Policy.

Postage, Photocopying & Stationery

  • You must not use Company stationery, photocopiers or faxes for personal use, unless authorised by your Manager.

Punctuality

  • All staff are expected to arrive for work punctually. If there is a reason why you cannot achieve this, you must ensure that you communicate the fact that you are delayed to your Manager as soon as possible. You should explain the circumstances of your delay to your Manager and inform him/her of your expected arrival time. If you are delayed meeting an external contact, you should communicate this fact with your apology as soon as possible as a matter of courtesy.

Telephone Calls

  • The Company does not undertake regular monitoring or recording of the content of telephone calls. We may however monitor call information including numbers dialled and the length of calls, mainly for billing purposes. [Some personal use of telephones is permitted. However if the Company feels that this is being abused the Company reserves the right to deduct the costs of personal calls from your salary and to take disciplinary action where appropriate.] 

  • TYF does not currently issue mobile phones, however guides are expected to carry a mobile phone as part of their safety kit as detailed in the SOP’s (Standard Operating Procedures). TYF staff may use personal mobile phones for TYF work purposes during working hours, but do so by their own choice and without expectation of remuneration for any calls made. You may use your mobile phone if you are on a break or if you have permission from your Manager. You must not use any mobile phone for business purposes whilst you are driving.

Activities Outside the Company

  • You are required to seek prior written approval from your manager if you wish to become involved in any activities outside of the Company that may conflict with your obligations to the Company. One reason for this is to ensure that we meet our obligations under the Working Time Regulations. You are not permitted to become involved in any activities outside of the Company that may conflict with your obligations to the Company.

Anti Corruption & Bribery

About

  • It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery.

  • We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

  • This policy sets out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and provides information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

  • Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

  • We have identified that the following are particular risks for our business:

    • Employees receiving vouchers or gifts in return for business referrals.

    • The receipt of gifts from existing suppliers of materials or services for business referrals.

    • The acceptance of hospitality by employees at sporting events, dinners etc in appreciation of business referred.

  • To address those risks we have considered these in detail and come to the following conclusions:

    • Small gifts to employees will not be deemed to be bribery – such gifts should be of low monetary value (£100 or less) and purely represent an appreciation for work referred. If a gift exceeds £100 then approval should be obtained from the General Manager prior to accepting this gift. A record of any gifts should be provided to the General Manager.

    • Acceptance of hospitality (attendance of sporting events, music shows, lunches or dinners) from suppliers or service providers would not be construed as bribery under the Act. Suppliers or service providers may on occasion offer employees of the Company hospitality by way of appreciation of business to date. Any hospitality offered to /accepted by employees should be advised to their Manager.

    • The acceptance of hospitality by employees at sporting events, dinners etc in appreciation of business referred.

  • Employees covered by this policy

    • This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, apprentices, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us or their employees, wherever located (collectively referred to as workers in this policy).

Definitions

  • Third Party: means any individual or Company you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

  • A bribe: is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. For example:

    • Offering a bribe: You offer a potential client tickets to a major sporting event, but only if they agree to do business with us.This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept your offer.

    • Receiving a bribe: A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in our Company to ensure we continue to do business with them.It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage. 

Gifts & Hospitality

  • This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. 

  • The giving or receipt of gifts is not prohibited, if the following requirements are met: 

    • 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; 

    • it complies with local law; 

    • it is given in our name, not in your name;

    • it does not include cash or a cash equivalent (such as gift certificates or vouchers);

    • it is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time;

    • taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;

    • it is given openly, not secretly; and

    • gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the Compliance Manager.

  • We appreciate that the practice of giving business gifts varies between regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

What is Not Acceptable?

  • It is not acceptable for you (or someone on your behalf) to:

    • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

    • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;

    • accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

    • accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

    • threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

    • engage in any activity that might lead to a breach of this policy.

Facilitation Payments & Kickbacks

  • We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK, but are common in some other jurisdictions.

  • If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Compliance Manager.

  • Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

  • We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Compliance Manager.

Your Responsibilities

  • You must ensure that you read, understand and comply with this policy.

  • The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

  • You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption are set out in the Schedule.

  • Any employee who violates this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

Record-Keeping

  • We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

  • You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

  • You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

  • All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.

How to raise a concern

  • You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your Line Manager. Concerns should be reported by following the procedure set out in our Whistleblowing Policy.

What to do if you are a Victim of Bribery or Corruption

  • It is important that you tell your Line Manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

Protection

  • Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. 

  • We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Compliance Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure. 

Training & Communication

  • Training on this policy forms part of the induction process for all new workers. All existing workers will receive regular, relevant training on how to implement and adhere to this policy.

  • Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter. 

Potential Risk Scenarios 'Red Flags'

  • The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

  • If you encounter any of these red flags while working for us, you must report them promptly to the Compliance Manager or using the procedure set out in the Whistleblowing policy:

    • you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

    • you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them.

    • a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

    • a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

    • a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

    • a third party requests an unexpected additional fee or commission to "facilitate" a service;

    • a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services or you are offered an unusually generous gift or offered lavish hospitality by a third party.

    • a third party requests that a payment is made to "overlook" potential legal violations;

    • a third party requests that you provide employment or some other advantage to a friend or relative;

    • you receive an invoice from a third party that appears to be non-standard or customised or you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

    • a third party insists on the use of side letters or refuses to put terms agreed in writing;

    • a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;

Property

Company Property

  • The term "Company Property” includes all property belonging to the Company and includes documents, physical property such as adventure equipment stationery, samples, computer equipment, mobile phones, security passes and non-tangible property such as trade secrets, intellectual property and confidential information.

  • During your employment, you must not use any Company Property for any purpose other than to enable you to carry out your duties.

  • At the end of your employment, you must return all Company Property in your possession to the Company. Where the property consists of documents, you must return all copies of them. You must also ensure that you have not retained any Company information on any of your personal computer equipment.

Personal Property

  • The Company is not responsible for the security of any personal property.

Dress Code

  • We encourage everyone to maintain an appropriate standard of dress and personal appearance at work and to conduct themselves in a professional manner. The purpose of our dress code is to establish basic guidelines on appropriate clothing and appearance at our workplace, so that we:

    • Promote a positive image and staff look professional;

    • Respect religious, racial and gender-specific clothing requirements and those of staff with disabilities where possible;

    • Take account of health and safety requirements; and

    • Help staff decide what clothing it is appropriate to wear to work.

  • Different departments may have specific requirements that result in particular clothing demands, for example, because their work raises health and safety risks. It is important that all staff dress in a manner appropriate to their working environment and the type of work they do.

  • We expect staff to take a common sense approach to the dress code. Any enquiries regarding the operation of our dress code (including whether an article of clothing is suitable to wear to work) should be made to your Manager.

  • While working for us you represent us. Your appearance contributes to our reputation and the development of our business. It is important that you appear clean and smart at all times when at work, particularly when you may be in contact with clients, other business contacts or the general public.

  • Staff should not wear clothing or jewelry that could present a health and safety risk.

  • Staff may wear religious and cultural dress unless it breaches this policy or compromises the health and safety of the wearer, their colleagues or any other person. Priority is at all times given to health and safety requirements.

  • Failure to comply with the dress code may result in action under our Disciplinary Procedure.

Uniform

  • TYF provide a staff uniform. You are expected to keep this clean and presentable. 

  • HQ staff are issued with a lanyard and name tag. You are expected to wear this at all times while at work

  • If wearing the uniform outside of work hours you must not act in a way that could bring TYF into disrepute. 

Equality & Diversity

About

  • The Company is committed to ensuring equal opportunities for all our staff and aims to provide a work environment in which all staff are encouraged to reach their full potential and to contribute to the Company's success.

Equal Opportunities

  • We are committed to promoting equality of opportunity to all staff and job applicants. We aim to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.

  • We do not discriminate against staff on the basis of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (protected characteristics).

  • The principles of non-discrimination and equality of opportunity also apply to the way in which staff treat visitors, clients, customers, suppliers and former staff members.

Scope & Purpose 

  • This policy applies to all aspects of our relationship with staff and to relations between staff members at all levels. This includes job advertisements, recruitment and selection, training and development, opportunities for promotion, conditions of service, pay and benefits, conduct at work, disciplinary and grievance procedures, and termination of employment.

  • We will take appropriate steps to accommodate the requirements of different religions, cultures, and domestic responsibilities.

Recruitment & Selection

  • We aim to ensure that no job applicant suffers discrimination because of any of the protected characteristics above. Our recruitment procedures are reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities. Job selection criteria are regularly reviewed to ensure that they are relevant to the job and are not disproportionate.

  • Job advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. A copy of this policy shall be sent on request to those who enquire about vacancies.

  • We take steps to ensure that our vacancies are advertised to a diverse labour market. Where appropriate, use may be made of lawful exemptions which should be set out in the advertisement.

  • Applicants should not be asked about health or disability before a job offer is made. There are limited exceptions, which should only be used with Human Resources approval. For example:

    • Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).

    • Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.

    • Positive action to recruit disabled persons.

    • Equal opportunities monitoring (which will not form part of the decision-making process).

  • Applicants should not be asked about past or current pregnancy or future intentions related to pregnancy. Applicants should not be asked about matters concerning age, race, religion or belief, sexual orientation, or gender reassignment without the approval of Human Resources (who should first consider whether such matters are relevant and may lawfully be taken into account).

  • We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective staff, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from the UK Border Agency.

  • To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our Company, we monitor applicants' ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary and it will not adversely affect an individual's chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting, and kept in an anonymised format solely for the purposes stated in this policy. Analyzing this data helps us take appropriate steps to avoid discrimination and improve equality and diversity.

Staff Training

  • Staff training needs will be identified through regular staff appraisals. All staff will be given appropriate access to training to enable them to progress within the Company and all promotion decisions will be made on the basis of merit.

  • Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all staff who should have access to them and that there are no unlawful obstacles to accessing them.

Termination of Employment 

  • We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.

  • We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.

Disability Descrimination

  • If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.

  • If you experience difficulties at work because of your disability, you may wish to contact your line manager to discuss any reasonable adjustments that would help overcome or minimise the difficulty. Your line manager may wish to consult with you and your medical adviser(s) about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible.

  • We will monitor the physical features of our premises to consider whether they place disabled workers, job applicants or service users at a substantial disadvantage compared to other staff. Where reasonable, we will take steps to improve access for disabled staff and service users.

Fixed Term Employment 

  • We monitor our use of fixed-term employees, and their conditions of service, to ensure that they are being offered appropriate access to benefits, training, promotion and permanent employment opportunities. We will, where relevant, monitor their progress to ensure that they are accessing permanent vacancies.

Part Time Work

  • We monitor the conditions of service of part-time employees and their progression to ensure that they are being offered appropriate access to benefits and training and promotion opportunities. We will ensure requests to alter working hours are dealt with appropriately under our Flexible Working Policy.

Policy Breaches

  • If you believe that you may have been discriminated against you are encouraged to raise the matter through our Grievance Procedure. If you believe that you may have been subject to harassment you are encouraged to raise the matter through our Dignity at Work policy. If you are uncertain which applies or need advice on how to proceed you should speak to your line manager in the first instance or HR if you do not feel able to raise the matter with your line manager.

  • Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Staff who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations, which are found to have been made in bad faith will, however, be dealt with under our Disciplinary Procedure.

  • Any member of staff who is found to have committed an act of discrimination or harassment will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. We take a strict approach to serious breaches of this policy.