Our Code of Ethics Statement

Ethical practice is managed as part of the existing system of governance within MBSL. We wish to ensure that regardless of where and how people interact with MBSL, they will be treated in the same way – with integrity, honesty and respect. If MBSL is to continue to grow, we all need to work to the same code of behaviour which will guide our thinking, decision making and ultimately the way we service our clients. Anything less would impact our reputation, and damage our ability to do business and serve our clients.

The very best in service delivered ethically will guarantee our future.

Our Purpose and Principles

Our purpose is to help make it as easy as possible for businesses to manage their processes. Running a business is challenging enough so we do not make things complicated for our clients.

We always conduct our own services honestly and honourably, and expect our clients and suppliers to do the same. Our provision of services and professional advice take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers.

The purpose of this Code of Ethics is to help all staff act responsibly, ethically and in the best interests of all key stakeholders.

Responsible Employment

It is vital that we treat all of our people fairly, respecting human rights and equal opportunities whilst maximising the talent, capability and performance of our people to benefit our business and ultimately the customer.

Vision and Strategy

Our vision and strategy should be clearly communicated to our people and everyone should understand how their role and objectives relate to it.

Employee Views

We listen and respond to views and opinions. This can take many forms including employee surveys, staff meetings and one to one discussions (both formal and informal). Our people will be involved in decisions that affect them whether as individuals or through consultation with representatives.

Grievance and Issues

We operate processes that enable our staff to raise grievances/ concerns and have these concerns fully investigated and resolved.

Diversity

We operate an equal opportunities policy that prevents discrimination during any aspect of recruitment or employment on grounds of gender, religion or belief, race, creed, age, disability, sexual orientation, ethnic origin or marital status. We aim to create an environment in which all our employees can develop their full potential. Valuing and promoting diversity across all of our businesses is an essential part of achieving that goal.

Health and Safety

We do our utmost to provide a safe and healthy work environment, ensuring that all legislation regarding health and safety is adhered to.

Performance and Reward

We will ensure that there is a clear process for setting performance standards and expectations and for measuring and rewarding performance.

Work Life Balance

We support a positive work life balance for all our people. Policies should be clear and well communicated to employees.

Talent

We establish a route to recognise and reward talent as part of our talent strategy.

Equality and Discrimination

We always strive to be fair and objective in our advice and actions, and we are never influenced in our decisions, actions or recommendations by issues of gender, race, creed, colour, age or personal disability.

Employee Conduct

Appropriate use of company resources

We expect all of our staff to use company resources in a responsible and ethical manner. While incidental or occasional private use may be allowed with prior approval from a member of the Senior Management Team, staff should not abuse resources provided to them in the course of their working role.

Intellectual property

It is our policy to establish, protect and maintain all commercial intellectual property rights and all staff must take steps to safeguard these. Commercially sensitive information must never be disclosed under any circumstances. Theft and misuse of trade secrets or proprietary information may result in criminal proceedings.

Staff must be aware and understand that all inventions, ideas and solutions devised whilst in employment are the intellectual property of the company. Whilst we actively encourages ideas and creative thinking in order to improve our level of service for our clients, it is vital that our staff understand that all work is the intellectual property of the company and the company has the sole ownership and use of it.

We will respect the intellectual property rights of others. When using logos, trademarks or other intellectual property, steps must be taken to ensure it is with the prior agreement of the owner and is correctly represented at all times. These obligations apply to all staff, including those who leave the company.

Conflicts of interest

Staff should not undertake any activities, financial interests or relationships outside employment that could represent a possible conflict of interest. It is recognised that staff may undertake legitimate financial and business activities in their own time, but these should not conflict with or damage the reputation of MBSL.

Doing Business

In the course of doing business with clients, suppliers and other third parties, we must behave with integrity and professionalism.

Clients

Clients are our main priority and all dealings with clients must be undertaken with honesty, integrity and openness. We will communicate in an accurate, timely and truthful way to in direct communication. A promise made by any member of staff is a promise made by MBSL and must be treated as such.

Client data will always be treated with sensitivity and respect and must not be used for personal gain. All data is handled in a way that meets the requirements of data protection laws.

Suppliers

We will seek mutually beneficial relationships with suppliers. As such, we will settle accounts promptly and efficiently. Contracts agreed with suppliers must be honoured.

Gifts and Improper Payments

Gifts of money, goods, services or other favours must not be asked for or accepted. Small tokens and reasonable hospitality may be accepted provided they do not place a staff member under any obligation and will not be misconstrued. Any gift or hospitality of more than a token value must be reported to the SMT to determine if it may be accepted and staff must comply with any other gift/hospitality rules in the company. Staff and their family should not accept anything that could damage the reputation of MBSL.

Bribery, Corruption and Fraud

Bribery involves one person offering a financial or other advantage to another in return for some improper favour or advantage; fraud involves criminal deception by someone designed to gain a financial advantage and corruption refers to a wide range of different corrupt activities, such as extortion, dishonesty and abuse of office. Corruption may include activities which would also amount to fraud or bribery.

We have introduced policies and procedures designed to tackle these activities and more detail is set out below.

We are committed to acting professionally, fairly and with integrity in all our business dealings. Bribery and corruption damage business and we will have no part in such activity.

It is of fundamental importance that we do not enter into, or condone, any action that is contrary to legislations or its stated policies or practices.

Compliance with Laws

All our dealings must be in compliance with all relevant legislation at all times. We cannot accept circumstances where any employee allows a situation to arise where our company may not be in full compliance with all applicable laws.

Expenses

Policies and forms for the claiming of expenses are established in our Office Policies and Procedures manual. Any attempt to claim expenses for which individuals are not entitled will be thoroughly investigated and deliberate actions will be treated as fraud.

Preventing Money Laundering

People who are involved in criminal activity, such as bribery, fraud or trafficking narcotics may attempt to launder money through apparently legitimate businesses in order to use the funds from their criminal activity and reduce suspicion. Under law, acceptance or processing of money gained through criminal activity is illegal.

We will deal only with reputable clients who are involved in legitimate business activities and whose funds are derived from legitimate sources. Our people are asked to raise concerns in accordance with the policy set out in our Office Policies and Procedures.

Competition

Anti-competition laws prohibit agreement between competitors to fix prices, limit supplies or act dishonestly in any other way. We are committed to free and open competition and we will compete vigorously, but honestly, while complying with all relevant competition and anti-trust laws.

Political Contributions

We will not make political contributions. Political contributions can include cash, gifts, sponsorships, donations or benefits in kind and no employee should knowingly make a political contribution on behalf of the company.

Company records

All books and records are be kept in accordance with applicable laws and according to proper accounting standards, fully reflecting receipts and expenditures. This is to ensure the financial information we use within the company is accurate and reliable.

Corporate Responsibility

We are committed to minimising any potential negative environmental impacts and maximising the positive. Our Corporate Responsibility Statement sets out minimum expectations and standards around managing our environmental impact, supporting community and charitable work, managing our responsibilities as an employer and maximising the positive impacts we have on the world of business.

Intellectual Property and Moral Rights

We retain the moral rights in, and ownership of, all intellectual property that we create unless agreed otherwise in advance with our clients. In return we respect the moral and intellectual copyright vested in our clients' intellectual property.

Quality Assurance

We maintain the quality of what we do through constant ongoing review with our clients, of all aims, activities, outcomes and the cost-effectiveness of every activity. We encourage regular review meetings and provide regular progress reports.

Professional conduct

We conduct all of our activities professionally and with integrity. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients.

Fees

Our fees are always competitive for what we provide, which is a high quality, tailored, specialised service. As such we do not generally offer arbitrary discounts; generally a reduction in price is only enabled by reducing the level or extent of services to be delivered. That said, we always try to propose solutions which accommodate our clients' available budgets and timescales. Wherever possible we agree our fees and basis of charges clearly in advance, so that we and our clients can plan reliably for what lies ahead, and how it is to be achieved and financially justified.

Payment

We aim to be as flexible as possible in the way that our services our charged. We make no attempt to charge interest on late payments, so we expect payments to be made when agreed. Our terms are generally 30 Days.

Duty of Care

Our actions and advice will always conform to relevant law, and we believe that all businesses and organisations, including MBSL, should avoid causing any adverse effect on the human rights of people in the organisations we deal with, the local and wider environments, and the well-being of society at large.

Conflict of Interest

Due to the sensitive nature of our services, we will not provide a service to a direct competitor of a client, and we generally try to avoid any dealings with competitor companies even after the cessation of services to a client.

Privacy

We are committed to protecting any personal information we obtain through the course of doing business and our people should understand the basis of legal rules surrounding the protection of data and how it may apply to them in their role.

Specifically our staff must:

protect customer data and should not share it with any third parties;

protect personal information relating to co-workers, suppliers or business partners;

keep any such information secure.

When dealing with personal information, staff must ensure every business decision is based on sound judgement and not personal information that could result in suggested discrimination.

Privacy While Using Company Resources

We monitor the use of email and the internet. Our policies set out in our Office Policies and Procedures manual guide our staff when using internet services and monitoring is in place to ensure that neither the company nor individuals are put at risk through inappropriate use. Such monitoring will always comply with legislation and is always disclosed to new employees at induction.

Services should always be used in a way that will not compromise employees or the organisation. Common sense and good judgement should be applied at all times.

Reporting a Problem

MBSL has committed to ensure all of our people have a route to highlight any instance of unethical behaviour. This may be handled differently but the options include:

grievance policies to ensure grievances are properly heard and where appropriate acted upon;

access to directors to enable any employees to discuss concerns with fellow staff members leadership team.

Any issues raised will be treated in the strictest confidence.

Annual Declaration

In order to ensure that the Code of Ethics has been fully embedded within the company and to facilitate good business practice and corporate governance, an annual Code of Ethics Declaration is required to be completed by all staff.

The declaration asks employees to disclose any relevant business interests, benefits, responsibilities outside of MBSL, relationships with professional advisors and relatives or business associates employed by the MBSL.

Completed declarations are required to be submitted to the Company Secretary who will review the information provided to ensure that employees and/ or the company are not exposed to any potential ethical issues. Information provided in the declarations will not be published.

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