The following Code of Business Conduct (“the Code”) has been approved by the Board of Directors of Trimax Americas: 

The Group operates in many markets and countries throughout the world. In all instances, we respect national laws and industry codes of conduct.

We, the officers and staff of all companies in the Trimax Americas group (“the Group”), recognise our obligations to all who have a stake in our success including share owners, clients, staff, and suppliers;

Information about our business shall be communicated clearly, and accurately in a non-discriminatory manner and in accordance with local regulations;

We select and promote our people on the basis of their qualifications and merit, without discrimination or concern for race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability;

We believe that a workplace should be safe and civilised; we will not tolerate sexual harassment, discrimination or offensive behaviour of any kind, which includes the persistent demeaning of individuals through words or actions, the display or distribution of offensive material, or the use or possession of weapons on Trimax Americas or client premises;

We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol;

We will treat all information relating to the Group’s business, or to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain;

We will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, colour, sex, sexual orientation, gender identity or expression, age or disability;

We will not for personal or family gain directly or indirectly engage in any activity which competes with companies within the Group or with our obligations to any such company;

We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts this;

We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties;

We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business;

No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees, without the prior written approval of the Board.

We will comply with all applicable local laws and regulations, and any other laws with an international reach, such as the US Foreign Corrupt Practices Act, where relevant.

Actual or potential conflicts with this Code should be reported promptly to the Trimax Americas Company Secretary.

Complaint procedure

Any violation of this Code and, in particular, the policy prohibiting discrimination or harassment, should be reported immediately to the local human resource director or, where this position does not exist, the chief executive officer or other Senior Manager of the Operating Company. The staff member is also encouraged to raise the matter with the Trimax Americas Company Secretary. It is especially important that this complaint procedure is properly communicated to all staff.

In the event that a staff member feels unable to speak to any of these people, he or she may call the “Right to Speak” helpline (040-40800800 ext. 224) that each operating group has in place (with the exception of certain countries as a result of local legislation). Each operating company is responsible for communicating this helpline to their employees. Trimax Americas’ Director of Internal Audit or the Trimax Americas Company Secretary can also supply the information.

All situations will be treated confidentially and will be promptly investigated. If the result of the investigation indicates that corrective action is called for, such action may include disciplinary measures up to and including termination of the employment of the offender.

Display of the Code of Business Conduct and complaint procedure

The Code and the complaint procedures should be communicated to all staff and should be posted prominently in each operating company office.

Annual confirmation of compliance

The Senior Management including heads of departments and any other significant department at each Operating Company are required to sign an Annual Certificate of Compliance with the Code of Business Conduct.

The Trimax Americas Company Secretary must receive a list of all those individuals at the Operating Company who are required to sign the annual certificate of compliance with the Code of Business Conduct by no later than the end of August of each year.

The finance director of the Operating Company is required to collect and forward the signed forms together with details of any exceptions including any outstanding certificates to the Company Secretary’s department at Trimax Americas by no later than the end of September of each year.

Where circumstances change, which alter the responses given on the certificate, the Trimax Americas Company Secretary must be notified without delay.