Ethics Policy

 

Overview

TLB Services is committed to operate all its activities within the letter and spirit of the laws and regulations governing its business, employees, data contributors and authorised users.

This policy details the standard of conduct and the professional behaviour we must at all times adhere to.

Scope

This Ethics & Conduct Policy applies to all employees, authorised users and data contributors of TLB Services and must be complied with at all times.

Objective

The objective of this policy is to prescribe the requirements for complying with this Ethics & Conduct Policy, which has been implemented, by employees, authorised users and data contributors.

All employees, authorised users and data contributors must at all times conduct themselves in accordance with all professional regulatory standards that TLB Services is subject to. This policy will describe the controls in place to ensure compliance with this standard.

Ethics and conduct policy framework

 

  1. TLB Services will ensure compliance with its ethics policy by conducting its business in accordance with each standard within the policy and not conducting any activities that may constitute a contravention of any of the standards.
  2. The Ethics policy is incorporated into the ethos and day to day running of all our operations, and periodic risk assessments/gap analysis of our activities compared to the standard will be carried out. This will identify any shortcomings and/or any contraventions of the standard.
  3. Where any potential actions might contravene the Ethics & Conduct Policy, a full evaluation will be carried out to consider whether the potential action would be a breach of the policy and if appropriate compliant action will be taken.
  4. TLB Services has adopted a framework to evaluate all ethical decisions. This framework must be documented, including details of the names and job titles of the individuals who were involved in the final decision together with the dates of the discussion. The framework to be followed in this process is:
  • Recognising an Ethical Issue: To identify the specific ethical aspect of the issues at hand and the conflict with the Ethics Policy.
  • Consider the Parties Involved: Identify the various individuals and groups who may be affected by the action/decision. Who may be harmed or benefit by the decision.
  • Gather all the Relevant Information: Prior to taking any action, ensure that all pertinent information has been obtained and all potential sources of information have been consulted.
  • Formulate Action and Consider Alternatives: Evaluate the decision-making options by considering the Ethics Policy and the rights of those individuals involved.
  • Consider the options predominantly in ethical terms rather than in legal or commercial terms. As a course of action that may be legal or commercially viable may not necessarily be ethical.
    • Our Ethics & Conduct Policy.
  • Make a decision and Consider it: Following a review of the information and the options available to determine the appropriate course of action to address any conflict with the Ethics Policy.
  • Act: Implement the course of action.
  • Reflect on the Outcome: Evaluate the outcome of the decision taken and the consequences of the same. Reviewing both intended and unintended consequences.
  1. Employees, Data Contributors, Authorised Users
  2. Employees are provided with an initial induction and on-going training to ensure compliance with our ethical policy and values. The employees will sign an acceptance form to confirm training and acceptance of these core values and their obligations to maintain the same. These will form a part of the employment contract.
  3. Employees are actively encouraged to report any potential conflicts or violations of the ethical code to management.
  4. Data Contributors and Authorised users will have to enter into service contracts which will emphasise their obligations under the ethical policies of TLB Services.
  5. TLB Services will periodically review performance and conduct of employees, data contributors and authorised users to ensure compliance with the ethical code.
  6. Any failure by employees to abide by the ethical policies of TLB Services and/or fail to report any potential conflicts will result in immediate disciplinary action.
  7. Any failure by a Data Contributor or Authorised User to abide by the ethical policies of TLB Services and/or fail to report any potential conflicts will result in immediate termination of the contractual relationship.

TLB Services will undertake an annual review of the Ethics & Conduct Policy and the accompanying framework to ensure its effective operation across the business.