Code of Ethics
This policy applies to everyone we employ or have business relations with. This includes individual people such as employees (including interns, volunteers and members of our Board) but also business entities, such as vendors or venture capital companies.
Policy brief & purpose
Our professional code of ethics policy aims to give our team members guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgement, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act.
This policy has been created to provide a framework and guidance on Oxwash’s approach to achieving and maintaining good business behaviour using sound ethical conduct. It serves to ensure that all employees and other entities that Oxwash does business with are aware of their individual and collective responsibilities with regards to Oxwash’s ethics, and to emphasise our employees, suppliers, and customers’ expectations of being treated fairly and by good business practices. All employees are responsible for reading this document in its entirety and for ensuring that they comply with all the policy requirements as stated within this document. The purpose of the Code of Ethics is to maintain a culture of openness, trust and integrity in Oxwash’s business practices. Effective ethics is a ‘team effort’ involving the participation and support of every Oxwash employee. Oxwash is committed to protecting employees, business partners and suppliers from illegal or damaging actions by individuals, either knowingly, or unknowingly.
The purpose of the Code of Ethics is to guide employees in situations when they might not be sure how to act. Some professional ethics correspond to laws that must be followed, however, there are some circumstances where there are grey areas which is when the Code of Ethics will provide guidance.
We base our business code of ethics on common principles of ethics:
Diversity, Equality and Inclusion
Anti-Bribery And Corruption
Political and Charitable donations
Teamwork and Collaboration
Diversity, Equality and Inclusion
Oxwash understands that everyone is different and has unique qualities to offer. We seek to respect and understand these differences, so we can make the most of everyone’s talents, to the benefit of individuals and the business as a whole. To this end, Oxwash is committed to the promotion of equal opportunities throughout its business.
Oxwash believes that Equality is about creating fairness, where everyone can participate and has the same opportunity to fulfil their potential. We are committed to fully complying with our obligations under the Equality Act (2010) by preventing unfair discrimination, harassment and victimisation; advancing equality of opportunity and fostering good relations between people with a protected characteristic and those with none.
Oxwash recognises that Diversity acknowledges and values the full range of differences between people both in the workplace and in wider society. Diversity acknowledges that entry into the workplace and an individual realising their potential once there, can be influenced by a range of factors beyond the characteristics included within equality legislation. These include social, economic and educational background, professional background, hierarchical level, working style, nationality etc.
Oxwash understands that Inclusion relates to an individual’s experience
within both the workplace and in wider society, and the extent to which they feel valued and included. It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence is strictly prohibited, as well as harassing or victimising others.
For more information of what constitutes harassment, victimisation and bullying, read the Oxwash Bullying and Harassment Policy.
If anyone that you interact with, whether a colleague, a customer, or other stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to your manager. You can also report rudeness and dismissiveness if they become excessive or frequent.
Anti-Bribery and Corruption
At Oxwash we value upholding fair business practices. Oxwash is committed to promoting and maintaining the highest levels of ethical standards concerning all of its business activities. Oxwash’s reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values. Oxwash therefore has a zero-tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems to counter bribery.
This Code of Ethics Policy sets out Oxwash’s position on any form of bribery and corruption and provides guidelines aimed at:
1) Ensuring compliance with anti-bribery laws, rules and regulations;
2) Enabling employees and persons associated with Oxwash to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others;
3) Providing suitable and secure reporting and communications channels and ensuring that any information that is reported is properly and effectively dealt with; and
4) Creating and maintaining a rigorous and effective framework for dealing with any
suspected instances of bribery or corruption.
This Policy applies to all permanent and temporary employees of Oxwash
(including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with Oxwash or who performs functions concerning, or for and on behalf of, Oxwash, including,but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors (“associated persons”).
All employees and associated persons are expected to adhere to the principles set out in this Anti-Bribery and Corruption policy which states that employees and others acting for or on behalf of Oxwash are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments, including kickbacks. As part of its anti-bribery measures, Oxwash accepts transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure, whether given or received. For more information, read the Oxwash Anti-Bribery Policy.
Political and Charitable donations
What are political and charitable donations?
Political donations are the giving or providing, directly or indirectly, of cash, venues, equipment, personnel time or other benefit to a political party, or to an individual who is standing for elected office, or to an individual or organisation who is nominated by or connected with a candidate for office, a political party or a member of a political party.
Charitable donations are the giving or providing, directly or indirectly, of cash, venues, equipment, personnel time or other benefit to a charity, or to an individual or organisation who is nominated by or connected with a charity. A donation could be considered to be a bribe if it is given or received with the intention of influencing someone to act improperly, or as a reward for having acted improperly.
Guidelines for political and charitable donations
To counter the risk of political donations being corrupt, or being perceived to be corrupt, or being in breach of applicable law, Oxwash totally prohibits the offer or provision of political donations by or on behalf of the organisation.
Oxwash does not ban employees from making personal political donations out of their own funds, however, no personal donations should be connected, or be seen to be connected, with a decision by a public sector body in relation to Oxwash’s business. For example, Oxwash will never pay or repay an employee’s donations, or co-ordinate or organise the employee’s donations.
Charitable donations are normally very different in concept to political donations. Most charities have no connection with politics and have no decision making role or influence over public sector procurement decisions, and Oxwash does not consider charitable donations to be at high risk of being corrupt or be perceived to be corrupt. Oxwash may be involved in charitable giving as an important part of our corporate social responsibility strategy. Therefore, a total prohibition of charitable donations is inappropriate. However, when there is a risk that a charity could be connected to a political party or a person with a decision making function, or that the charity may be placing or managing contracts, Oxwash controls the risk through different methods.
Oxwash has implemented effective controls over charitable donations, to minimise the risk that they could be corruptly given, or be perceived to be corruptly given.
Consider the intention behind the donation
The intention behind the donation should always be considered. If it could be intended to influence someone to act improperly, it should not be given.
Consider the perception
Do not give a donation if it could reasonably be perceived to be corrupt. There are two common perception tests:
“Newspaper test”. Would a newspaper be likely to report the donation, and, if a newspaper did report, what would the public perception be?
“Prosecutor test”. If the donation did lead to a corrupt outcome, with the result that a prosecution takes place, how would you explain the donation in court to a prosecutor? Would your explanation be plausible to the judge or jury?
Consider the legal and regulatory environment
Before giving a donation, ensure that the law of the territory, and the regulations of the recipient, allow such a donation.
Undertake due diligence on the charity before any donation is made
The purpose of this due diligence is to ascertain whether there is any connection between the charity, and any business transactions, organisations or individuals with which Oxwash is involved, or is likely to be involved. As with all due diligence, the level of enquiry depends on the circumstances, and should be reasonable and proportionate.
Be cautious about donations which could be intended to influence, or could reasonably be perceived to influence, a tender or other decision in favour of the organisation
If the due diligence above establishes a connection, then there is a risk that the donation could be an attempt to influence an outcome, or could be perceived to be such an attempt. Either avoid making a donation in these circumstances, or only make it if there is reasonable certainty that it could not influence, or be perceived to influence, an outcome.
Decide whether the donation should be publicly disclosed
In some cases, the law requires donations to be disclosed on a public register or in the organisation’s annual accounts. Even if not required, Oxwash may choose to disclose donations on the basis that transparency to help avoid the perception of corruption.
Request approval in advance of the donation from the CEO
Always require approval from the Senior Leadership to make charitable donations. The reasons for the donation should be documented, and the CEO must be satisfied that the donation is appropriate, and is not corrupt, and could not reasonably be perceived to be corrupt.
Appropriately report and register all charitable donations
Donations given and received should be recorded in a register or other appropriate record.
Sponsorship is the supporting or funding of any activity, usually for advertising purposes, or in consideration for a benefit of similar purpose. Sponsorships should always be provided pursuant to the terms of the applicable laws, and they shall never be associated, either directly or indirectly, with any unlawful act, or undue advantage for Oxwash.
All sponsorship proceedings by Oxwash should be recorded in writing. Sponsorship should be carried out directly dealing with the end entity or event, without any intermediaries.
Oxwash gives priority to sponsorship projects requiring continuity over one-off ones, and implements them at corporate level.
Integrity is one of Oxwash’s core values and we strive to achieve it across all levels of the business. One way in which Oxwash’s value of integrity is through its company culture where individual employees trust and respect each other. We expect all employees to behave honourably and follow strong moral and ethical values. Integrity is essential in many areas, including decision-making, customer service or interacting with colleagues.
Examples of daily integrity
Show your team that you're reliable by keeping your commitments
Be honest and transparent when you communicate with other people
Hold yourself accountable for your actions and admit to your shortcomings
Ensure you're honest with your team members and supervisor
Not engaging in gossip about others
If you make a promise to a team member, keep it
How can you demonstrate integrity in the workplace?
Integrity impacts the day-to-day work environment at Oxwash. When you behave with integrity, you demonstrate to your managers and fellow employees that you can handle responsibilities. Your behaviour can help foster a positive company culture at Oxwash. You can show your integrity in the work environment with these actions:
Be ready for work - Arrive on time and with the right mindset to work
Set a positive example - Try to be optimistic, inspiring and encourage your colleagues
Remain respectful during conflict situations - If you disagree with colleagues or managers always be mindful about how you communicate and never raise your voice, insult or intimidate anyone
Practice accountability - Take responsibility for your actions and admit when things go wrong
Respect property - Treat Oxwash’s and your colleague's property with care. Never steal or use company property for private purposes.
Conflict of interest
A conflict of interest occurs where an employee’s or Board member’s private interest interferes with the interest of Oxwash. Oxwash has a responsibility to maintain all its stakeholders’ trust by being open and honest about situations that may give rise to such conflict.
Conflict of interest may take many different forms that include, but are not limited to:
Employees’ ability to use their position at Oxwash to their personal advantage
Employees engaging in activities that will bring direct or indirect profit to a competitor
Employees owning shares of a competitor’s stock
Employees using connections obtained through Oxwash for their own private purposes
Employees using Oxwash’s equipment or means to support an external business
Employees acting in ways that may compromise Oxwash’s legality (e.g. taking bribes or bribing representatives of legal authorities)
The possibility that a conflict of interest may occur can be addressed and resolved before any actual damage is done. Therefore, when an employee understands or suspects that a conflict of interest exists, they should bring this matter to the attention of management so corrective actions may be taken. Managers must also keep an eye on potential conflict of interests of their subordinates.
The responsibility of resolving a conflict of interest starts from the immediate line manager and may reach senior management. All conflicts of interest will be resolved as fairly as possible. Senior management has the responsibility of the final decision when a solution can not be found.
In general, employees are advised to refrain from letting personal and/or financial interests and external activities come into opposition with the company’s fundamental interests.
Note: The same principles apply to the company in regards to its clients. When applicable, we are committed to not offer services or form partnerships with companies who are in direct competition with one of our existing clients.
In cases when a conflict of interest is deliberately concealed or when a solution can not be found, disciplinary action may be invoked up to and including termination.
All Oxwash employees are obliged to follow all legislation which apply to our company.
If you are in a position where you prepare contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), always ask for a verification by your manager before finalising anything.
All Oxwash employees are covered by our confidentiality and data protection policy. You must not expose, disclose or endanger information of customers, team members, stakeholders or our business.
You must follow all legislation regarding fraud, bribery, corruption and any kind of assault. You are also obliged to follow laws on child labour and avoid doing business with unlawful organisations as stated in the Oxwash Modern Slavery Statement. If you’re not sure what the law is in a specific instance, ask your line manager.
Oxwash expects all employees to practice fairness and adhere to the following principles:
Practice zero tolerance to exploitation of others, their work or their mistakes
Be objective when making decisions that can impact other people. Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example, when interviewing candidates, ask the same interview questions to all candidates and avoid judging non-job-related criteria, like dress, appearance, etc.
When exercising authority, always strive to be as fair as possible
Never show favouritism toward specific team members and be transparent when you decide to praise or reward a team member.
If you need to raise a formal disciplinary with a team member, be sure to have prepared a case together with the People team that you can present to the Leadership.
Be just toward customers or vendors. If you think our company was in the wrong in a specific instance, be honest about it and discuss with your manager to find solutions that can benefit both sides.
Teamwork and Cooperation
Our success begins and ends with teamwork. It is expected that each person will do their part to avoid situations that disrupt or promote others in their group to act in ill-will, to be insubordinate to a supervisor or to intentionally sabotage the efforts of other employee teams or departments.
Teamwork is promoted when everyone acknowledges the team leader, respects the leader's judgement and authority and follows through on requests / directives without questioning them in a hostile or demeaning way. Mutual respect is the underlying factor. If someone is known to intend harm against the company or a team, please see your manager.
You are expected to work hard, do your share of work and complete it within set timelines. We encourage ambition, willingness to learn and curiosity. We want you to participate in employee training and development, and constantly work towards continuous improvement.