APPLYING PERSONAL AND BUSINESS INTEGRITY

A. Fraud, bribery and corruption
B. Conflicts of interest
C. Personal Investment
D. Insider trading and market abuse
E. Handling of gifts and improper payments
F. Offering gifts and entertainment
G. Political activity

4A. Fraud, bribery and corruption
We are committed to maintaining the highest standards of ethics and integrity in the way we do business. Any act of fraud, bribery or corruption is not tolerated by GS Group, nor is any help given to people carrying out such acts.

What does it mean for me?

DO

DON'T

  • immediately report any attempts to
    offer you a bribe or to get you to act in a
    way that could be disadvantageous for
    GS Group to your direct manager, chief
    compliance officer, local ombudsman or
    compliance hotline
  • cooperate fully with law enforcement
    agencies and investigators and support
    prosecution or disciplinary action where
    sufficient evidence exists
  • be aware of the possibility that bribery
    and corruption can occur and regularly
    review our procedures and controls to
    ensure they are current
  • check with the chief compliance officer
    as to what is permitted and acceptable
    before taking any action
  • accept bribes of any kind
  • give bribes

4B. Conflicts of interest
A “conflict of interest” arises when you use your position to make a personal gain or benefit over and above what is defined in your employment agreement. We must ensure that our personal interests do not conflict with the interests of the business or our customers.

What does it mean for me?

DO

DON'T

  • inform your direct manager if you feel
    you might have a potential conflict of
    interest
  • ensure that your personal activities
    and interests do not conflict with your
    responsibilities to the company
  • immediately report any attempts to act in
    a way that could be disadvantageous for
    GS Group
  • check with your direct manager, HR
    leader or chief compliance officer as to
    what is permitted and acceptable before
    taking any action
  • do business on behalf of GS Group with
    a company from which you or a family
    member might benefit from unfairly
    (other employees can do business
    with such a company, though you must
    not be involved or try to influence the
    relationship in any way)
 

4C. Personal investment
Ensure that your investments or personal business do not create conflicts of interest or impair your ability to make objective decisions on behalf of GS Group. Conflicts can occur if personal investments are made in GS Group competitors’, suppliers’ or customers’ businesses. Publicly traded mutual funds, index funds and similar pooling of securities, when the individual investor has no say in which investments are included, do not present conflicts.

What does it mean for me?

DO

DON'T

  • check with your line manager and legal/
    HR leader as to what is permitted and
    acceptable before taking any action
  • invest in a supplier if you have any
    involvement in the selection, negotiation
    with or assessment of said supplier, or
    if you supervise anyone who has such a
    responsibility
  • invest in a customer if you are
    responsible for dealing with them or
    if you supervise anyone with such a
    responsibility
 

4D. Insider trading and market abuse
We have a legal duty to never use company information that has not been made public for our own benefit, or for the benefit of others we know – for example, by selling or buying shares on the basis of price-sensitive information. Using information for our own benefit or for others is called insider trading and in almost all cases is a serious criminal offense. Other abuses of information such as disclosing sensitive material other than in the proper course of your employment (known as “market abuse”) may also result in serious criminal and/or civil penalties.

What does it mean for me?

DO

DON'T

  • maintain the confidentiality of company
    information
  • consult with your chief compliance
    officer before trading in the security or
    disclosing company information
  • deal in other publicly traded companies’
    shares
  • note that where your employment
    requires you to be in possession of nonpublic,
    price-sensitive information, you
    will be added to an “insider list” and
    notified by the company secretary. You
    may not deal in the company’s shares
    until you have been taken off the insider
    list
  • talk about sensitive information
    regarding GS Group business or what
    you are working on with family and
    friends
  • convey information to anyone outside the
    company unless it is necessary for the
    company’s business activities
  • pass on non-public, price-sensitive
    information to other people or encourage
    others to deal in the company’s shares on
    the basis of such information, even if you
    yourself do not deal in or otherwise profit
    from passing on the information
  • buy or sell a security, asset or property
    because you heard about it at work and
    think the price will go up or down once it
    is publicly announced
 

4E. Handling of gifts and improper payments
Business gifts and entertainment from business partners build goodwill, but they should never influence – or appear to influence – our business decisions in any way. As such, we will never seek or exert improper influence in exchange for promises or gifts, regardless of the local business practice.

What does it mean for me?

 

DO

DON'T

  • keep your manager updated, obtain
    receipts and document the details
    of your payment for any private
    work where you know the supplier or
    contractor works for GS Group
  • if you accept a gift or entertainment
    above a locally determined financial
    value, tell your manager and document
    the details
  • require any person or firm who
    represents GS Group (such as a
    consultant, agent, sales representative,
    distributor or contractor) to comply with
    this policy and the related laws
  • return any gift or cash equivalents such
    as gift certificates that are transferrable
    or convertible into cash, bank check,
    money order, investment securities,
    negotiable instrument, loans, stocks or
    stock options
  • immediately report any attempts to
    offer you gifts and entertainment or to
    get you to act in a way that could be
    disadvantageous for GS Group
  • regularly review our procedures and
    controls to ensure they are current
  • accept any gift or entertainment that is
    illegal or would result in any violation of
    the law
  • accept any gift of cash or cash
    equivalent, bank check, money orders,
    investment securities, negotiable
    instrument, loans, stocks/stock options
    or services from third parties/suppliers/
    contractors for your personal benefit
  • accept a commission that is
    disproportionate to the services provided
  • participate in any entertainment that is
    unsavory, sexually-oriented or otherwise
    violates our commitment to mutual
    respect
  • participate in any activity that you know
    would cause the person providing the gift
    or entertainment to violate his or her own
    employer’s standards
  • accept free or discounted work or
    services from a supplier or contractor for
    personal gain
  • accept any gift, entertainment or
    service from a third party that comes
    with conditions that result in suppliers
    (including potential new suppliers)
    gaining a benefit
  • offer a business courtesy such as a gift,
    contribution or entertainment under
    circumstances that might create the
    appearance of impropriety
  • pay, promise, offer or authorize anything
    of value (such as money, goods or
    services) to a government official or
    employee of a customer to obtain or
    retain an improper advantage
 

4F. Offering gifts and entertainment
It is common in the commercial world to offer social amenities and business courtesies such as modest gifts, meals and entertainment to enhance business relationships. However, every courtesy offered should always comply with the policies of the recipient’s organization.

What does it mean for me?

DO

DON'T

  • immediately report any attempts to
    offer officials (government/private) or
    employees gifts to the direct manager/
    legal/HR leader
  • regularly review our procedures and
    controls related to offering gifts to ensure
    that they are officially and legally within
    acceptable limits
  • offer or provide a gift, entertainment or
    anything of value if it is:
    • illegal
    • known to be in violation of the rules of
      the recipient’s organization
    • cash or other monetary instrument
    • unsavory, sexually-oriented or
      otherwise violates our commitment to
      mutual respect
    • a quid pro quo1
    • not recorded properly on company
      books/gift registry
  • offer or provide a gift or anything of
    value to a government official that is
    illegal or would cause the official or
    employee to violate established ethics or
    rules governing his or her conduct
 

4G. Political activity
We have no political affiliations and make no political donations – we work with governments and parties around the world only on issues vital to the interests of GS Group. All employees have the right to be politically active as long as they keep their work separate and remain professional around customers, colleagues, etc.

What does it mean for me?

DO

  • you are free to engage in political activity
    as long as it is done on your own time and
    does not adversely affect the reputation
    of the business
  • talk to your manager if you require
    time off from work for political or
    representative activity, e.g., carrying out
    duties as an elected councilor

 

Did you know?

Every 6th canned pineapple in the world comes from Great Giant Pineapple

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