AQUAGIB CODE OF CONDUCT

Introduction

The mission of AquaGib Limited is to be recognised as Gibraltar’s leading utility through the provision of efficient and sustainable water services.

We believe in doing the right thing and in being open and truthful with those who depend on us.  We will always aim to do what we say and we will and keep environmental and social issues at the heart of our thinking.  Our performance is scrutinised by many external observers, including our regulators, and we will always maintain integrity and honesty.

We provide essential services in the areas in which we work and we accept the high levels of responsibility which this carries.  We are committed to:

  • providing continuous supplies of high quality drinking water;
  • protecting and enhancing the natural environment;
  • supporting our employees to develop their potential in a great place to work;
  • working in partnership with our communities to provide sustainable solutions;
  • delivering a return to our shareholders;
  • meeting our responsibilities and developing our reputation as a corporate citizen and;
  • complying with the letter and spirit of the law.

To help us meet these wide-ranging responsibilities, we have adopted this Code of Conduct.  We will endeavour to adhere to the Code in all our activities and will carefully monitor our performance. We will also ensure our contractors comply with our Code of Conduct or share their own, which must be of an accepted standard. We will review the Code regularly.

Our Code of Conduct

We will strive to comply with this Code of Conduct.

1. Relationships

1.1 Our relationships with our employees, customers, regulators and other stakeholders are important to us and are taken into account in our decision making.

1.2 We act ethically, lawfully and with integrity, honesty and with fairness in all our relationships.

1.3 We are careful how we handle information we receive in the course of our business.  If the information is confidential or sensitive we do not disclose it, except where we are legally required to do so or with the express permission of the individual or stakeholders to whom it relates.  We comply with our obligations under data protection legislation.

1.4 We apply strict rules when giving or accepting gifts or hospitality.

1.5 We communicate our policies, achievements and prospects regularly, clearly and in plain English to our employees and stakeholders.  We do not make excuses if something goes wrong.

1.6 We will form lasting long term relationships with organisations that share a common vision of environmental, economic and community enhancement.

2. Customers

2.1 We recognise that the services provided by our operating business, AquaGib Limited, are essential to the health and wellbeing of our customers.  We will provide these services to a very high standard, ensuring they meet or exceed all applicable legal and regulatory standards.

2.2 Our overriding objective is to meet the needs of our customers.  To do this well, we will: improve customer service and reduce overall customer complaints; and provide good value for money.

2.3 We describe our services and products accurately in our communication materials.

2.4 We aim to recover debts swiftly and efficiently to prevent additional costs being    imposed on our paying customers.  However, we try to help customers who have difficulty paying their bills and we offer a variety of options to make payments easier.

2.5 We consult our customers regularly through appropriate channels which includes undertaking yearly customer opinion surveys of the services that we provide.

3. People

3.1 We require our employees to comply with our overriding principle of acting ethically, lawfully and with integrity, honesty and fairness and, in particular, to comply with our Bribery and Corruption Policy, appended to this Code of Conduct.

3.2 We recruit and develop talented and committed employees, regardless of age, gender, disability, race, religion or sexual orientation.

3.3 We equip our people with the right skills for their current job and their development.  We ensure our people have the information, tools and skills to contribute to both efficiency and customer service.

3.4 We seek to lead effectively, developing leadership skills both in current and potential people managers.

3.5 We seek to achieve and maintain high levels of performance and motivation.

3.6 We protect and enhance the health wellbeing of employees through proactive management of risks to health and safety, the encouragement of a sensible work/life balance and participation in occupational health programmes.

3.7 We pay our employees fairly and recognise them for their achievements and contributions. 

3.8 We encourage open feedback throughout the organisation and to protect employees who wish to voice concerns about any behaviour or decisions which they believe to be unethical. 

4. Environment

4.1 We take a proactive approach to environmental matters.

4.2 We assess the environmental and social effects of our significant developments and seek sustainable and innovative solutions to mitigate adverse environmental impact and to enhance the environment where this is practicable.

4.3 We encourage conservation and pay particular attention to environmentally sensitive areas.

4.4 We seek to reduce our consumption of natural resources and our emissions to air, land and water.  In particular, we aim to minimise energy consumption and use self-generated renewable energy where possible. 

4.5 We are assessing, and will respond to, the impact of climate change.

4.6 We use resources in a sustainable manner and in procuring materials; goods and services take account of their environmental, social and economic impact.

4.7 We are reducing the amount of waste we produce.  We dispose of the waste that is produced in a responsible manner.

4.8  We are open to work with organisations that focus on environmental conservation and enhancement.

5.  Competitiveness and Reputation

5.1   We will respond to the challenges of a developing market through our competitiveness and reputation.

5.2   We promote innovation and enterprise across the Company.

5.3   We benchmark our performance against relevant comparators to drive continuous improvement.

5.4   We contribute to Gibraltar’s economic performance.

5.5   We are a valued contributor, partner and/or leader within the community we serve.

6. Finance

6.1 We aim to provide an appropriate return for our owners and meet our obligations to providers of debt finance by ensuring our business generates an appropriate level of profit and is sustainable.

6.2 We prepare accounting statements on a timely basis and in accordance with applicable accounting standards.

6.3 We maintain adequate accounting records which are sufficient to show and explain the company’s transactions and disclose with reasonable accuracy at any time the financial position of the Company.

7. Regulators

7.1 We recognise the importance of AquaGib Limited maintaining positive relationships with its main regulators:  the Gibraltar Environment Agency and the HM Government of Gibraltar.

7.2 We communicate openly, honestly and promptly with our regulators and ensure that appropriate care is taken in the submission of information to them 

8. Suppliers

8.1 We will build lasting relationships with suppliers, advisers and contractors, to encourage loyalty and flexibility on both sides.

8.2 We expect our suppliers to act ethically, lawfully and with integrity, honesty and fairness, and we will use these criteria in the selection of suppliers.  Where the supply chain includes international providers of goods or services, we will require these suppliers to meet or exceed international standards covering employment, environmental and social issues.  In all cases we will work with our suppliers to manage the environmental and social impact of our operations.

8.3 We will pay suppliers on time and according to agreed terms.

9. Local Community

9.1 We will serve the community, not only by providing our services efficiently and at a fair price, but also by providing employment opportunities and enhancing the community in which we operate.

9.2 We encourage employees to participate in community and civic affairs through our Employee Recreation Committee.

9.3 We support the community in which we operate and in other areas, we are focused on supporting sustainable projects that make the area that we serve a better place in which to live, work and invest.  Charitable donations, educational and cultural contributions are made within a policy which is set and reviewed by the Managing Director.

9.4 We publicly report on our achievements on our website or through other methods as appropriate.   

10. Corporate Governance and Risk

10.1 We will adhere to sound principles of corporate governance.

10.2 We operate a robust system of internal risk assessment and control to safeguard the Company’s assets and take reasonable steps for the prevention and detection of fraud and other    irregularities. This enhances the efficiency of our operations and the reliability of internal and external reporting, as well as assisting us to comply with laws and regulations.

10.3 We effectively manage risk through the AquaGib / NWG risk model.

11. Law and Political Parties

11.1 We comply with all applicable law and regulatory standards.

11.2 We comply with our obligations in relation to direct and indirect taxes and maintain a professional relationship with the tax authorities.

11.3 We do not favour any one political party over another.  We do not make donations to political party funds or political candidates, although we may incur expense (within strict limits) in ensuring that we have regular and appropriate contact with all of the main parties.

12. Compliance and Verification

12.1 The Managing Director is responsible for initiating and supervising investigation of all reports of breaches of this Code and ensuring that appropriate disciplinary action is taken when required.

12.2 AquaGib Limited will appoint on an as required basis the Finance and Business Support Director/Company Secretary and one of the Directors in the Senior Management Team, to audit compliance with this Code and report to the Managing Director, any practice they discover in the course of their work which appears to breach it.

12.3 We protect employees who make us aware of contravention of our Code of Conduct. 

12.4 We monitor and report, as appropriate, on performance against our corporate responsibility policies.

12.5 We respond quickly and accurately to stakeholder’s questions on environmental and corporate responsibility issues.

Signed by Derek Cano, Managing Director AquaGib Limited:

Dated:   1st September 2014

Appendix to Code of Conduct

AQUAGIB LIMITED BRIBERY AND CORRUPTION POLICY

 1. Scope

This policy applies to all permanent and temporary employees of AquaGib and its subsidiaries and associates, worldwide.

Wherever we can do so; we will require (and we will, otherwise, encourage) the application of the principles underpinning this policy amongst our contractors, suppliers and joint venture partners.

This policy will be implemented in conjunction with the rules and procedures on giving and accepting gifts and hospitality communicated to employees of the company.

2. Policy

One of our values is to behave ethically. We therefore, do not engage in bribery or any form of unethical inducement, or payment including facilitation payments and ‘kickbacks’ and we strictly prohibit our employees and contractors from so doing. All employees are required to avoid any activities that might lead to, or suggest, a conflict of interest with the business of the company. Employees must comply with the rules and procedures on giving and accepting gifts and hospitality applicable to AquaGib.

We will uphold laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific business practices.

3. Responsibilities

The Managing Director is the board director with primary responsibility for implementing this policy and for reporting annually to the AquaGib Board of Directors. If any instance of bribery or corruption is identified, we will take remedial steps immediately.

4. Training and Communications

We will communicate this policy and relevant guidance to employees across the company, through our established internal communication channels. We will also communicate this policy to our suppliers, contractors and business partners and wider stakeholders. Managers, employees and agents will receive relevant training on how to implement this policy in the scope of their employment with the company.

5. Raising Concerns and Seeking Guidance (Whistle Blowing)

Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage through the Finance and Business Support Director/Company Secretary, the Managing Director or any other Board Director.

Employees will receive the full support of the company when refusing to pay a bribe, even if it may result in the Company losing business.

6. Monitoring and review

The Finance and Business Support Director/Company Secretary will review the implementation of this policy in respect of its suitability, adequacy and effectiveness and will periodically report the results of this process to the Managing Director who will make an independent assessment of the adequacy of the policy and the need to disclose any material non-compliance.