1 Purpose and Objectives
This document sets out the ethical requirements for business practice and personal conduct of the employees of Silex.
This Code of Conduct represents minimum ethical standards and requirements for the Silex organization, its employees, consultants, and others who act on behalf of Silex. The objective is to prevent situations that might question the integrity of Silex.
In its business activities, Silex will act in an ethical, sustainable and socially responsible manner, and in accordance with applicable laws and regulations. Everyone who acts on behalf of Silex must abide by applicable laws and regulations and carry out their work in accordance with Silex requirements, including the Silex ethical Code of Conduct outlined in this document.
All Silex employees and Silex contractors are responsible for complying with this policy. The Technical & HSEQ Director is the owner of this document and responsible for implementing the policy.
The CEO is the approver of this document and responsible for confirming the validity of the document.
2 Code of Business Conduct
2.1 Correct Information and Financial Reporting
Silex requires honest, accurate and timely recording and reporting of information, internally and externally, to make responsible business decisions. All accounting information shall be handled in accordance with applicable laws and regulations. All financial reporting and public communication undertaken by Silex shall be full, fair, accurate, timely and understandable.
2.2 Preventing Financial Crime
Silex does not tolerate financial crime. Financial crime includes, but is not limited to, corruption, bribery, money laundering, terrorist financing, fraud, tax evasion, and balance sheet falsification. Financial crime is harmful to legitimate business activities and exposes companies and individuals to risk. Involvement in any form of financial crime by any Silex employee or representative is prohibited.
All employees or representatives of Silex must never, directly or through intermediaries, offer or promise any personal or improper financial or other advantage to a third party, whether public or private. Equally, Silex employees must never accept any advantages in return for any preferential treatment of a third party.
Procurement shall follow Silex established guidelines and procedures.
2.3 Gratuities to Representatives of Public Institutions
Representatives of public institutions, holders of public offices, members of public services or authorities and politicians should not receive gifts, invitations or other benefits which may question their independence from business interests. Silex prohibits the offer or receipt of gifts, hospitality or expenses that are intended to affect the outcome of specific business transactions.
A gift, hospitality or expense payment may be authorised in certain cases, when there is a legitimate purpose related to the relationship between the relevant authorities and Silex. Such authorisation shall never be given if it violates any applicable laws or regulations, or if it may be perceived by the public as an improper payment. Any offer or receipt of gifts, hospitality or expenses shall be modest and in accordance with acceptable legal and cultural practices.
2.4 Business Associates (suppliers, partners)
Silex will act in a manner that gives its suppliers and partners trust in the company. Partners and suppliers of Silex are equally expected to comply with ethical requirements consistent with the ethical standards of Silex.
2.5 Use of Intermediaries and Lobbyists
Intermediaries are agents, consultants and others who, through their business activities, act as links between Silex and a third party. Before intermediaries are hired, the responsible for the hiring shall ensure that the intermediary’s reputation and activities are in accordance with Silex’s ethical requirements. Any agreement with an intermediary shall be made in writing and Silex’s ethical requirements must be incorporated into the contract.
The primary aim of using a lobbyist as intermediary is to influence decisions, in both the public and private sectors. Any lobbyist working for Silex shall be obliged by contract to be transparent and fully disclose to the person or body in question that they work for Silex.
2.6 Political Activity
Silex does not support any political parties, organisations or individuals engaged in politics with the objective of obtaining any advantage in business activities or other transactions. Silex may participate in public debate on issues of interest for the company. Individuals working for Silex may be engaged in democratic activities, but shall always clearly separate their political activities and engagement from their relationship with Silex.
2.7 Equality and Diversity
Silex embraces diversity at all levels of the organisation and is committed to providing equal opportunity in all aspects of employment. We shall treat each other fairly and respectfully. Any illegal discrimination or harassment is not tolerated, including exclusion or preference on the basis of gender, race, religion, national or ethnic origin, disability, age, sexual orientation, political views, marital status or other circumstances that may compromise the principle of equality.
2.8 Labour Standards, Health and Safety
Silex actively communicates with employees and follows international and local labour legislation. Silex strives to ensure that the working environment provides job satisfaction as well as safe and good health conditions. Individuals working for Silex should find their jobs stimulating to foster creativity and efficiency. A good working environment is important to the individual employee and essential to successful goal achievement.
The Silex HSE handbook describes and documents how Silex manages HSE within the company.
2.9 Cooperation with regulators
Silex aims to maintain respectful and cooperative interactions with governments and regulators. This refers to every touchpoint, i.e. regular contacts as well as particular requests or audits. We strive for diligent and timely responses which provide a true and fair view.
2.10 Corporate responsibility / sustainability
Silex works to establish environmental consciousness in relation with all its business activities and actively works to reduce the environmental footprint of all Silex operations. Silex sees global climate challenges as a common responsibility and strives to exploit energy as efficiently as possible ensuring sustainable development.
The Silex HSE handbook describes and documents how Silex manages corporate responsibility and sustainability issues within the company.
3 Code of Personal Conduct
Confidentiality is required from all employees to prevent unauthorised access to sensitive and confidential internal information. All data and information shall be handled in a proper manner, to protect the interest of Silex, its employees and business partners. Silex shall comply with applicable copyright laws and confidentiality obligations. The dissemination of information externally concerning Silex shall be handled by authorised representatives of Silex only.
3.2 Use of Company Property
No employee of Silex may use corporate property, information or position for personal gain or for activities that compete with or are detrimental to Silex.
3.3 Corruption and Bribery
Silex is strictly against corrupt business practices, and involvement in any kind of corruption and bribery is prohibited.
3.4 Acceptance or Offering of Gifts and Entertainment
The acceptance or offering of gifts and entertainment by any individual representing Silex is prohibited when the interests of Silex are affected, or the professional independence of the employee or representative may be questioned. It is strictly prohibited to offer or accept gifts, hospitality or expenses intended to affect the outcome of specific business transactions. Any offer or acceptance of gifts, hospitality or expenses shall only be made if there is a clear business reason and shall then be modest and in line with acceptable legal and cultural practices.
All acceptance or offering of gifts and entertainment shall be registered to ensure transparency.
In the event Silex donates money it shall be registered to ensure transparency.
3.6 Conflict of Interest
No employee shall have any financial or other interest, directly or indirectly, in any activity or business that may undermine the integrity or impartiality of the employee or Silex. The employee shall behave impartially in all business activities and not give improper advantages to other organisations, companies or individuals.
Acceptance of directorships, employment or other assignments by a Silex employee requires prior written approval to ensure it does not interfere with the interests of Silex.
3.7 Information and Record Keeping
Employees’ use of information, IT systems and internet services shall be governed by the needs of Silex and not by personal interests. Silex is committed to transparency and accuracy in its activities, while maintaining its confidentiality obligations. Hence, employees are responsible for maintaining necessary records of Silex business activities, and for storing produced information in electronic files and archives in an orderly manner.
Employees taking part in public discussions do not represent Silex unless being authorised to do so, and should state that s/he acts as a private person to avoid confusion of roles.
4 Living the Code
Each individual employee of Silex shall ensure that they are familiar with and will carry out their work in accordance with the requirements in this document, applicable laws and regulations. All new employees will be given an introduction to the Silex Management System including the Code of Conduct. The introduction training shall be logged. In addition a refresher will be conducted as part of the annual Management review.
Managers are responsible for communicating and guiding employees in the requirements set out in this document. All managers shall ensure that activities within their area of responsibility are undertaken in accordance with the requirements in this document, applicable laws and regulations.
Violation of the company’s ethical requirements may result in disciplinary action, including termination of employment or contract, as well as potential legal proceedings.
Employees shall report any practices or cases of ethical doubts or breaches of Silex’s ethical requirements. It shall be reported to the CEO or to the Chairman of the Board.
Silex does not permit retaliation against any individual who, in a responsible manner, informs individuals in positions of responsibility or relevant authorities about possible breaches of the company’s ethical requirements, applicable laws, regulations, or company codes and policies.