Caring about the detail…
Jolliffe & Co LLP seeks to be a good corporate citizen in all aspects of its operations and activities. To this end we have brought together a series of operating principles under the broad heading of Corporate Social Responsibility (CSR) to serve as a guide to employees in all aspects of their work for the partnership. The principles cover all areas of the partnership’s operations and have been developed with reference to the relevant codes of corporate governance and best practice, including the revised Combined Code and international statements and guidelines such as the UN Universal Declaration of Human Rights and the OECD Guidelines for Multinational Enterprises. Taken together, these principles form our CSR policy.
The policy can be divided into six main areas:
01. Ethical Business Conduct
We value the principles of accountability, honesty and integrity in all aspects of our business. Our policy is to conduct our business in a manner which ensures:
– fair treatment of all employees and clients
– transparency of our business policies and practices
– high standards in all matters relating to health, safety and the environment
– ethical business practices throughout our operations
We recognise that the involvement of our employees is key to the future success of the business and we have for many years adopted a policy of keeping employees fully informed on all matters affecting them. We have consistently operated a remuneration strategy that recognises both corporate and individual performance. We are also committed to best practice in employment matters, recognising the role this plays in attracting and retaining staff.
To succeed in delivering the best possible service to our clients, every employee isexpected to adhere to the group’s core values and to uphold them in the workplace. Employees are expected at all times, to exercise the highest ethical judgement and comply with laws applicable to their duties.
02 Policies Specific to Employees
Compliance with Codes and Regulations
In addition to the partnership’s internal operating principles employees shall adhere to all national laws and regulations and codes of practice relevant to their profession. These will include the guidelines to codes of conduct of the PRCA.
In the event that an employee discovers a breach of partnership policy there is a facility for him/her to report that breach in confidence either via his line manager or via an anonymous email address sent directly to the managing partner. The managing partner has a duty to investigate fully the detail behind such a report and as part of the investigation will not normally make reference to the anonymous report. Maliciously motivated reports for which there is no real basis for making a report are not welcomed and may result in disciplinary action being taken against the employee making the accusation.
The partnership requires that employees avoid at all times any situation which may involve a conflict of interest between the employee and the partnership. Employees are expressly prohibited from accepting other paid employment, including directorships in other companies, without the consent of the managing director. In general, this does not apply to charitable work or relationships with non-profit organisations unless this has the potential to impact on the employee’s normal duties.
Dealing with Customers, Stakeholder and External Parties
The partnership is committed to the provision of accurate information and fairness in all its dealings with customers, stakeholders, officials and any other external party having direct business with the group.
Every employee shall respect any information which is confidential to the partnership including, but not limited to, trade secrets, confidential knowledge or any information concerning the process or invention used by the partnership. Breaches of confidentiality may be cause for disciplinary action.
We are committed to complying with the current data protection principles established by the 1995 EU Directive on Data Protection and the 2016 General Data Protection Regulation. This commitment applies throughout the partnership and in all countries in which it operates. If the partnership conducts business in a jurisdiction where stricter rules apply, then it will comply with those rules as a matter of course. All employees and agents of the partnership are responsible for ensuring compliance with the policy. Information collected may be accessible throughout the partnership but will not be disclosed to any third party in a form which identifies the individual concerned. It will not be used for marketing purposes without the individual’s consent and will not be sold to third parties. Upon request, an individual will be informed of the existence, use and disclosure of his or her personal data and will be given access to that data to confirm its accuracy or amend it as appropriate.
Dealing for clients will be undertaken in an order and manner which is unquestionably fair for the client. The buying and selling of equities, for example, will not prejudice any party and should be administered within the compliance regulations governing trading operations.
The partnership actively works to deter malpractice in its workplace, with specific attention to activities involving confidentiality. The partnership has detailed procedures for staff to follow in order to ensure observance of these principles. The Compliance Database contains guidance on the value of gifts which may be given (or accepted) by staff to (or from) counterparts in the industry, the frequency with which those gifts may be made (or accepted) and how they should be recorded.
The partnership has confidentiality contracts in place for all employees and with all parties for whom it is handling sensitive information.
Use of Partnership Information / Assets
Employees shall use the partnership’s computer systems, internet and intranet, and email systems for business use. Any employee found to have disclosed confidential information, been abusive or malicious in using these facilities, or misusing the systems in any way may face disciplinary action. The partnership strictly prohibits the use of its intranet, internet or email systems for acquiring, producing or disseminating pornography or similar material, including the use of abusive language or offensive images.
The Partnership has a detailed formal disciplinary procedure.
03 Policies Specific to the partnership
It is the partnership’s policy not to make contributions for political purposes. However, employees are not hindered from being politically active in their own time using their own resources.
The partners meet regularly to review financial performance and strategy and has a formal schedule of matters reserved for its decision, which includes the setting of partnership goals, objectives, budgets and other plans. In particular, the Partners regularly receives reports on the partnership’s corporate social responsibilities and they have identified the relevant risks to the partnership’s short and long term values, more on which is contained later in this document.
Internal controls are designed to cover all risks to achieving the partnership’s objectives including all business, operational, financial and compliance risks. The internal controls are designed to manage, rather than eliminate, risk of failure to meet business objectives and to provide reasonable, but not absolute, assurance against material misstatement or loss. The system of internal control is embedded within the day to day operations of the partnership and a strong control culture is combined with clear management responsibility and accountabilities for individual controls.
At least once a year a formal risk control report is prepared. This includes a summary of significant risks, key internal controls, the work of the monitoring functions and findings arising during the period. In addition, a report on the partnership’s social, ethical and environmental (SEE) issues is prepared.
Staff retention and corporate reputation are identified as significant risks to the partnership’s short and long term value. Directors are keenly aware of the importance of these issues and are committed to ensuring that any risks are assessed and minimised.
The Community Investment Programme has two main components, charitable giving and support for a wide variety of local and national organisations. The partnership is an active sponsor of several sportsmen and sportswomen, and a supporter of business groups and chambers of commerce in several of the cities where the partnership operates. The partnership also has a policy encouraging staff to donate their time to local causes and will accommodate reasonable requests for time away from the office to engage in community activities.
At the commencement of each fiscal year the managing partner will agree an amount which should be allocated to donations to charity and support for good causes. The partnership will aim to grow this core amount over time and, depending on the profitability of the partnership, may make specific one-off donations.
Our active involvement in charitable work creates a channel for feedback on the partnership’s activities which helps to shape policy in this area.
Activities in the Community
Since the partnership was founded it has grown and diversified. For some time now we have been engaged with the business community through the chambers of commerce and national and local charities, schools and educational authorities and we have links to various universities.
In addition, we sponsor a wide range of activities in the community. These range from sponsorship of individual men and women, to sponsorship of events – sporting, the arts, music, and educational. Information on these activities will be reported periodically on the partnership’s website.
We encourage employees to be active in the community in their own right and to this end operate a flexible working policy which permits staff to use a certain amount of working time each year to devote to charitable activities.
Benefits of Community Involvement
As the partnership becomes more involved in the community the partnership may be invited to propose or participate in new projects. Staff will be updated on these activities on a regular basis and will be given the opportunity to propose new ventures.
04 Fair Employment Practices
The partnership is committed to providing equal opportunities to and fair working practices for all workers and job applicants.
In formulating employment policy the partnership has been guided by the relevant legislation in the United Kingdom. A separate document covers this. The policies are periodically reviewed and updated, when appropriate.
05 Workplace Health & Safety
The partnership aims to provide each employee with a safe place to work. All partnership locations are required to abide by local health and safety regulations and each must submit on a regular basis to health and safety testing for accreditation where needed. In formulating policy the partnership has been guided by the relevant legislation in the United Kingdom. A separate document covers this. The policies are periodically reviewed and updated, when appropriate.
The group records all accidents and/or near misses and investigates these to determine if preventative action is required to prevent further accidents.
06 Environmental Policy
The partnership understands that its activities affect the environment and the communities in which we operate. We believe that we have a responsibility to identify and manage these impacts as effectively as possible. We are committed to continually improving our environmental performance and moving towards best practices in corporate sustainability. A separate document covers this. The policies are periodically reviewed and updated, when appropriate.