About > Code of Conduct

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.
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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 quo.
    • 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.