Ethical Policy

POLICY STATEMENT
This policy document sets out our charter for ethical business conduct. It is supported by a range of internal policies, which are either incorporated into employee contracts of employment, or are published on the Group intranet. In addition The Albany Group has a set of Values, which underpin its commitment to ethical activities and behaviour of its people. Our competencies, which are used in the review of employee performance, define the required standards of ethical behaviour.

SCOPE
The Group Board as a whole is responsible for ethical standards and principles, which apply to all directors and staff.

EFFECTIVE DATE
The Group Board adopted this policy on 1 July 2006.

PRINCIPLES
The Albany Group is committed to:

• Recognising our responsibilities to all our stakeholders-shareholders; customers; employees; suppliers, sub-contractors and business partners; society and the communities throughout the world in which we operate.


• Dealing with these groups fairly, and at a minimum, in accordance with our contractual obligations to them.

In support of this we:

• are committed to free and fair competition and will compete strongly but honestly, comply with competition law, and abide by the requirements of our regulators.


• will not make corporate donations to any political party.


• expect our employees to exercise care in giving or accepting gifts, or hospitality, to ensure that they do not allow themselves to reach a position whereby they might be deemed by others to have been influenced in making a business decision as a consequence.


• prohibit the payment of bribes.


• will not pay introduction commission to individuals working for a third party company without agreement in writing from the Directors of that company.


• hold personal and corporate information in a sensible and secure manner and employees are expected to guard against careless or inadvertent disclosures of information, which may damage our business or that of our customers or suppliers.
• advise employees they should avoid conflicts of interest and make them aware that their actions should be objective and based on the best interests of The Albany Group.


• advise our employees not to use the resources of The Albany Group for any purpose other than to conduct our lawful and proper business.


• expect our employees to conduct themselves in a way which is not likely to bring The Albany Group into disrepute.

The Albany Group recognises it is in the interest of both employees and the organisation to encourage an atmosphere of openness between management and staff. We encourage all individuals to raise any concern that they may have about the conduct of others in the business or the way in which the business is run, as set out in the Group's Whistleblowing policy.

POLICY COMPLIANCE
Breaches of this policy and its principles will be dealt with under the Company's disciplinary procedure. Significant or consistent breaches will be deemed as gross misconduct and may result in summary dismissal.