Business Code of Conduct

Revision 3

Policy Statement

As a global organisation operating in a highly regulated market, Ideagen follows industry best practices and recognises the importance of having a clear set of guiding principles and codes which promote and support the Company Values (https://www.ideagen.com/company/values).  This document is geared towards giving our Customers and stakeholders full transparency in the way we conduct our business. If you are a Supplier or Contractor of an Ideagen group entity, we require that you accept the contents of this Code of Conduct by either signing to accept you will conduct your Services in accordance with it or accept that you have sufficiently similar policies and practices in place (copies of which may be required).

Compliance with Laws

Ideagen strives to observe industry best standards of personal and business ethics, to comply with all applicable laws and regulations across the countries in which it operates. As a Supplier or Contractor, you agree to comply with all applicable laws and best practices.

Anti-Bribery, Corruption and Anti-Money Laundering

Ideagen is committed to ethical conduct and integrity in its business activities globally, and requires its Suppliers and Contractors to comply with the same. Ideagen takes a ‘zero-tolerance’ approach to bribery and corruption. These include implementation of an AML/Sanctions software toolkit for identifying potential issues for review by Ideagen’s MLRO with anybody which Ideagen deals with (e.g. customers or suppliers). Please refer to the Anti Bribery and Corruption Policy which is available on request. 

Ideagen is not a business which is regulated by the MLR in the UK or the BSA in the USA. Therefore, as a responsible business, Ideagen has adopted a risk-based approach to its processes for anti-money laundering and counter-terrorism funding which is based upon the money laundering and terrorist funding risks identified in its risk assessment. Irrespective of its status under the MLR or BSA. Ideagen remains bound by the Proceeds of Crime Act 2002 (POCA) and by certain sections of the Terrorism Act 2000 in the UK. Ideagen is required to take pro-active steps in the event that it becomes aware that any business it deals with may be involved in criminal or terrorist activity. Ideagen has implemented its Anti-Money Laundering Policy and Procedures (available on request) in order to comply with these obligations, and perform checks on new customers, suppliers and partners prior to doing business with them.

Human Rights & Modern Slavery

Ideagen is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that it and its supply chains are free from slavery and human trafficking and requires its Suppliers and Contractors to comply with the same. Please see the Slavery and Human Trafficking Statement here for full details: https://www.ideagen.com/slavery-and-human-trafficking-statement

Employees

Our employees are provided with an inclusive working environment in which they feel respected and valued, and in which they are able to make the best use of their skills, free from discrimination and harassment. 

We employ only workers who meet the minimum applicable legal age requirements, and comply with all child labour laws, irrespective of local practice. 

We set employees’ working hours and pay in compliance with all applicable laws, and perform the appropriate right to work checks prior to offering employment. We do not discriminate against employees on the grounds of race, nationality, gender, sexual orientation, gender identity, marital status, religion, political belief, disability or age. 

We have grant-funded Nottingham Forest Community Trust for five years to build and deliver our community education ‘Think Big’ programme with us. This is for disadvantaged young people in Nottingham and Nottinghamshire. The mission of this is ‘Motivating young people to be excited by Tech - inspiring them to think big about future employment in the Tech industry’. The programme is for young people in secondary mainstream, SEND secondary and alternative provision. We have committed to an increasing number of apprenticeships each year for five years for beneficiaries of this programme. We have a Think Big Ambassador programme. 45 of our UK colleagues have committed to this to be role models from the tech industry who will link with schools to support young people from disadvantaged communities in their career planning and career imagining. We have a ‘women in tech’ programme with Nottingham Girls Academy. This is specifically to encourage young women into tech. This includes curriculum linked learning, activity in school and visits to our office.

Our Employee Code of Conduct sets out the expectations of our employees when performing their daily tasks on behalf of Ideagen, and our Employee Assistance Programme supports our employees to perform their daily tasks in the best possible environment. 

Relevant Policies: Employee Code of Conduct, Equal Opportunities Policy, Whistleblowing Policy – all of which are available on request.  Ideagen requires its Suppliers and Contractors to have policies and practices in place to ensure its Employees are provided with an inclusive and safe working environment. 

Environmental

The Science Based Target initiative has validated that the science-based greenhouse gas emissions reductions target(s) submitted by Ideagen Limited conform with the SBTi Criteria and Recommendations. We are Streamlined Energy and Carbon Reporting (SECR) Compliant which means we report energy and carbon emissions in our annual report.   At present we have ISO14001 and ISO45001 certifications which cover our Head Office and our Kuala Lumpur office. Please refer to the Environmental Policy and Health & Safety Policy for our commitment to both these areas. 

Ideagen recognises and accepts responsibility to provide a safe and healthy working environment and to prevent injury and ill health for all employees, sub-contractors and visitors who attend Ideagen's premises. It is the policy of Ideagen to foster a positive health and safety culture throughout the Company because we believe that high standard of health and safety are a moral and commercial pre-requisite. For more information, please see our Environmental Policy, https://www.ideagen.com/environmental-policy. 

Quality and Information Security 

In addition to the above certifications Ideagen  also holds ISO 27001 and ISO 9001.  These relate to the Informaiton Security and Quality Management Systems.  Our in-house Compliance Team are experienced in ISO certifications and offer audit services across the Group at least annualy or as required.   Continuous improvement is championed by the team and a culture of raising standards as we grow is embedded as a result. 

As well as a number of certifications, we regularly engage with industry groups and are active members of several organisations to ensure we keep up to date.  Representatives from our Risk & Compliance team perform continual internal audits against the various in-scope items, including our ISO certifications (e.g., Compliance, Information Security, Environmental etc) and compliance with applicable data security and data protection and privacy requirements, laws and regulations. Any items highlighted through audits are logged and tracked to completion, with annual external audits upholding our various certification. Ideagen requires its Suppliers and Contractors to have mature quality and information security practices in place. 

For more information see our Certifications and Memberships page: https://www.ideagen.com/company/certifications-and-memberships 
Please see our Privacy Policy here: https://www.ideagen.com/privacy-policy.
Please see our Data Protection Policy here: https://www.ideagen.com/data-protection-policy 

Contracts and SLA 

Each of our business relationships, whether with customers, suppliers or partners, are governed by robust contractual terms which are carefully reviewed by our In-house Legal Team. We have policies and procedures in place to ensure that our business relationships are protected by terms and subject to SLAs which reflect the requirements of everything we do, and requires its Suppliers and Contractors to comply with the same.

Review and Revision

This Code of Conduct shall be reviewed and updated regularly by the policy owner at least once a year.  Any revisions which includes material changes will need to be signed off by the Risk & Security Working Group prior to being published.  It may be subject to review by an auditor external to Ideagen if required to ensure that it remains appropriate in the light of any relevant changes to the law, organisational policies or contractual obligations.

For case studies please visit our website: https://www.ideagen.com/resources/casestudies 
To contact us, please click here: https://www.ideagen.com/company/contact-us