Redpath Buchanan

J Redpath Buchanan & Co Ltd Ethics Policy


1. This Ethics Policy is supported by the Board of Directors of J Redpath Buchanan & Co Ltd and shall be reviewed from time to time. The policy sets out standards of professionalism and integrity to be maintained by individuals in all the company's operations.

2. Every employee has a right to expect the company to maintain proper standards and in turn all employees have a duty to maintain these standards through their decisions, actions and communications. A heavier responsibility is borne by those who hold positions of authority. They must openly demonstrate leadership in applying the business practices outlined in this policy.

3. This policy provides guidance on the way all staff are expected to conduct themselves -operating with integrity, fairness and in compliance with the law and regulatory requirements.

4. Whilst the policy applies primarily to directors and managers, it is also intended to apply to all employees of the business insofar as it is appropriate to their role.


5. The company expects all of its staff to operate with integrity and to high standards of ethical conduct when carrying out their duties on behalf of the company.

6. In particular they are expected to:-

7. Staff must not:-

8. If in doubt as to your responsibilities please ask a director or manager.


9. This policy provides general guidance on business ethics to all staff but should be read alongside other relevant company policy statements and the express provisions of service contracts and contracts of employment.

10. The provisions of the policy will be rigorously enforced and any infringements could result in disciplinary action being taken under formal procedures including in the most serious cases dismissal from the company, a police referral for criminal prosecution and a claim for recovery of loss or damage.

11. Any person suspected of any infringement of this policy will be afforded an opportunity to explain his or her actions before formal disciplinary procedures are implemented.


12. All directors and managers should ensure that they are aware of the laws and regulatory requirements affecting their areas of operation and where necessary should seek advice from specialist managers or from the Company Secretary's department where appropriate. In particular all directors and senior managers should be aware of their responsibilities under the regulatory requirements and company guidance relating to our core operations.

13. Directors and managers are responsible for ensuring their staff are familiarised with the contents of this Policy and other company policies.


14. An 'open door' policy is encouraged throughout the company so that, if necessary, any queries and concerns can be brought to the attention of management.

15. Directors and managers should promptly report to the Board of Directors or Company Secretary any illegal or unethical behaviour of which they become aware. All matters of suspected fraud, theft or mis-appropriation of company property must be reported to the Board of Directors or Company Secretary immediately.

16. Whilst the company would consider any director or manager to have a responsibility to disclose serious breaches of this policy an anonymous tip off placed in the Health & Safety suggestions box will also be investigated in full. The company will not tolerate reprisal or bullying of anyone who in good faith reports a serious breach of this or any other company policy. All directors and managers are expected to co-operate fully in any internal investigation into illegal or unethical behaviour.


17. Directors and managers must maintain the privacy of non-public confidential information entrusted to them by the company, its customers or any other party with whom the company conducts business. Specific categories of confidential information that should never be disclosed to persons outside the company, except where disclosure is authorised or legally required would include:-


18. Each director and manager owes a duty of care to the company to avoid situations which may give rise to a conflict of interest. A conflict of interest occurs when the private interests or actions of an individual may interfere with the interests of the company as a whole and make it difficult for an individual to perform his or her work objectively and effectively. Conflicts of interest may also arise where a director or manager or a member of his or her family received improper benefits or personal advantage as a result of his or her position in the company. All such potential conflicts of interest must be notified to the individual's immediate line manager or to the Board of Directors or the Company Secretary.

19. All directors and managers must disclose any direct or indirect interest including shareholdings and family relationships in any competitor company, contractor, supplier, consultancy or other partner or any other person or body working with or providing goods or services to the company.


20. The company's financial records should be complete and accurate so that they reflect the true state of the business and disclose the true nature of disbursements and transactions. All the Group's books, records, accounts and financial statements must be maintained in reasonable detail using standard company systems; must appropriately reflect the company's transactions; must conform both to applicable legal requirements and generally accepted accounting principles and to existing systems of internal control. In particular it is prohibited to undertake transactions that contravene tax laws, legal regulations and/or policy or procedural requirements of the company including:


21. Corruption causes loss and damage, inhibits business growth, is harmful to the reputation of the business, and may result in criminal and civil liability and penalties for the company and individuals.

22. The company prohibits its directors, managers, officers and employees, from engaging in any form of corruption in relation to its business and affairs.

23. All donations, gifts and hospitality received by the company or its officers or employees must comply with the Policy on Receipt of Gifts and Hospitality.


24. Each director and manager is accountable and responsible for ensuring compliance with all company policies, including this Ethics Policy, and where applicable, ensuring that adequate records are maintained to demonstrate compliance. Support is also provided by the Board of Directors through:-


25. All other company Policies, including policies on staff purchases and discounts, hospitality, gifts and entertainment should be read in the light of and in conjunction with this Ethics Policy and Code of Conduct.


26. If you have any questions about this policy, for instance - apparent conflicts between the application of this policy and legal requirements and procedures, or your conduct or the conduct of others in a particular circumstance please contact your immediate manager, the Board of Directors or the Company Secretary.

Paul Sturges
Managing Director
J Redpath Buchanan & Co Ltd
June 2011