Environmental, Social and Governance (ESG) Policy

Code of Conduct

The Manolete Board requires the highest standards of corporate governance, operational excellence and financial reporting throughout the Company and from all directors and employees.

In turn this demands that the Company, its directors and its employees operate in an honest, professional and ethical manner which is essential for our reputation as well as building trust and respect with our key stakeholders including customers, business associates, employees, communities and shareholders.

This Code contains the fundamental business principles that set these standards and guides our conduct across the Company and in our business dealings. The Company expects all business associates to follow the principles set out in the Code.

  1. Conduct
    The Board is committed to the highest standards of corporate governance, operational excellence and financial reporting throughout the Company and from all directors and employees, and requires that the Company, its directors and its employees operate in an honest, professional and ethical manner. We shall trade lawfully and properly at all times and, as a minimum, will comply with all laws and regulations.

  2. Integrity
    Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organisation. Accordingly no director or employee may:

    • pursue any personal or business interests which could interfere or be seen to interfere with the business or interests of any member of the Company; or
    • accept or provide gifts or entertainment which cause inappropriate influence over the recipient, or gives the appearance of doing so.

    In particular, all directors and employees are required to disclose any substantial interest that they or their immediate family might have in our suppliers, customers or competitors. We do not tolerate any form of bribery in our business or in those we do business with and the Company has in place an anti-bribery and corruption policy reflecting the standards that we expect of our staff and those who perform services for us.

  3. Customers
    We are committed to treating our customers in an open, honest and fair manner (including selling products and services that fulfil their needs and meet the appropriate quality criteria in accordance with regulatory and legal requirements) as well as operating an effective complaints process to address any issues that may arise.

  4. Competition
    We are committed to fair and competitive sales practices and to treating our business associates properly and fairly and in accordance with relevant competition laws. We will not engage in or be party to practices or agreements that would unfairly limit trade or exclude competitors from the market place.

  5. Employees
    We are committed to creating a safe and healthy environment for all employees and contractors. We promote diversity, fairness and respect in our working environment and do not tolerate any improper behaviour or harassment. We believe that our employees are central to the success of our business and are committed to their development and providing recognition based on success and achievement.

  6. Information
    We ensure the recording of all business transactions is complete and accurate, and we protect against inappropriate access or use of confidential and privileged information relating to the Company. We provide accurate and timely information to external stakeholders in compliance with relevant laws and regulations.

  7. Environment
    We comply with environmental protection laws, including recycling and waste disposal requirements, and seek to minimise detrimental effects that our activities may have on the environment. Wherever possible, employees are strongly encouraged to use the lowest form of carbon-emission transport for the many meetings they attend.

  8. Communities
    We contribute to the communities in which we operate including local and national charities and operating work experience programmes.

  9. Crime prevention
    The matter of fraud and financial crime is core to our business, and we have measures in place for detecting, preventing, reporting, investigating and prosecuting suspected fraud and financial crime. We have effective anti-fraud and anti-money laundering systems and controls as well as an anti-bribery and corruption policy in place in addition to effective claims management and counter-fraud capabilities. We also share data with appropriate industry bodies and government agencies.

  10. Regulators
    We are committed to engaging with our Regulators in an open, honest and transparent manner which is essential in order to build trust and promote the regulatory framework in which we operate.

  11. Reporting
    Any questions, concerns or alleged breaches in respect of this Code or any other matter may be raised by employees through line management or the Company’s Board of Directors, Whistleblowing Policy or Grievance Procedure. Business associates may also raise questions or issues through their relationship manager at the Company. All reports are treated confidentially and investigated promptly and properly.