Think Tank™ Consulting has an established Business Ethics Policy as outlined below:
- Our approach to being a good corporate citizen
- Our standards of business practice
- Our approach to corporate governance
- Out commitments to our employees
- Our employees’ commitments to Think Tank Consulting
1. OUR APPROACH TO BEING A GOOD CONSULTING ORGANIZATION
THINK TANK™ CONSULTING is committed to being a responsible consulting organization, taking account of the economic, social and environmental impact of our consultancy and aiming to maximize the benefits and minimize any negative impact of our global operations.
THINK TANK™ CONSULTING will support the principles of the United Nations Universal Declaration of Human Rights and we are committed to upholding these principles in our policies, procedures and practices. Respect for human rights is and will remain integral to our operations.
We will endeavor to work with business partners who conduct their business in a way that is compatible with our policies of respect for human rights and ethical conduct. We will work with clients to ensure that contractual requirements do not infringe human rights.
We will take measures to ensure that the work of our employees does not compromise internationally accepted human rights conventions, whilst recognizing and respecting the diversity in local cultures across the different countries in which we operate.
We will conduct our consultancy with respect and consideration for the environment. We strive to minimize our environmental impact through the management of waste, vehicle emissions and energy consumption.
THINK TANK™ CONSULTING will be fully committed to supporting and assisting the communities in which we operate through a variety of means including charitable fund-raising, sponsorship of community projects and voluntary work by employees. We will conduct our consultancy with respect and consideration for the good of local communities, taking steps to minimize any disturbance as a result of our operations. We will also serve local interests by providing good employment opportunities and effective services and products.
2. OUR STANDARDS OF BUSINESS PRACTICE
We are committed to high ethical standards in our consultancy dealings to ensure the integrity of our employees and our organization is maintained.
Bribery and corruption
THINK TANK™ CONSULTING is resolutely opposed to bribery and corruption in whatever form it may take. Gifts or entertainment may only be offered to a third party if they are consistent with customary business practice in the relevant territory, are modest in value and cannot be interpreted as inducements to business. Where there is doubt, guidance should be sought from the relevant service line head or directly from CEO. No financial or other inducements should be given to third party organizations or to individuals from such organizations in any circumstances, including government agencies and representatives.
Rendering of the Firm’s services and obtaining of services from third parties is made solely on the basis of quality, performance, and/or for the benefit of the organization, and never on the basis of giving or receiving inducements in the form of payments, gifts, entertainment or favors or in any other form.
Employees should not accept gifts, money or entertainment from third party organizations or individuals where these might reasonably be considered likely to influence advisory transactions. Gifts, other than trivial ones with a low value, should be returned. In a culture where such an action might cause offence, the gift should be declared to the firm and, if practical, donated to an appropriate charity.
Treatment of Clients
Mutual trust and confidence between THINK TANK™ CONSULTING and our clients is vital. All employees should strive to consistently deliver service excellence and value for money, meeting clients’ expectations and anticipating their changing requirements.
THINK TANK™ CONSULTING will always compete vigorously, but in a fair and ethical way. Competitive success is built on providing service excellence. Competitors should not be disparaged. When in contact with competitors, employees will avoid discussing confidential information and no attempt will be made to improperly acquire competitors’ trade secrets or any other confidential information. Employees must not discuss fee strategies or undertake any arrangements or practices which would conflict with the laws applicable to the business concerned.
3. OUR APPROACH TO CORPORATE GOVERNANCE
THINK TANK™ CONSULTING is committed to protecting the interests of its partners & associates through compliance with the relevant legal and regulatory environments and careful management of consultancy risks.
Compliance with the law
THINK TANK™ CONSULTING will comply fully with all relevant national and international laws and will act in accordance with local guidelines and regulations, including those which are industry specific, governing our operations.
It is the responsibility of all managers to ensure that they are aware of all local laws and regulations which may affect the area of the consultancy in which they are engaged, including tax and exchange controls.
Accounting standards and records
All accounting documentation must clearly identify the true nature of business transactions, assets and liabilities in conformity with relevant regulatory, accounting and legal requirements. No record or entry may be false, distorted, incomplete or suppressed.
All reporting must be accurate and complete and in compliance in all material respects with accounting policies and procedures, as outlined in the Finance Manual. Employees must not materially misstate or knowingly misrepresent management information for personal gain or for any other reasons.
THINK TANK™ CONSULTING may be required to make statements or provide reports to regulatory bodies, government agencies or other government departments. Care should be taken to ensure that such statements or reports are correct, timely and not misleading. Senior management must be made aware of any sensitive disclosure before it is made.
Care must also be taken when making statements to the media that information given is correct and not misleading. Enquiries from the media should be referred to firm CEO and statements should only be made by designated spokespersons.
Policies and procedures
THINK TANK™ CONSULTING recognizes that there are risks associated with carrying out any consultancy activities. Management is responsible both for ensuring that policies and procedures are in place to manage risks and for complying with those policies and procedures. Employees should ensure that they are aware of the risks associated with their activities and that they comply with policies and procedures in place to manage those risks.
4. OUR COMMITMENTS TO OUR EMPLOYEES
THINK TANK™ CONSULTING is committed to optimizing individual and consultancy performance through employing the best people at all levels and creating an environment in which they want to and are able to contribute fully to the Firm’s success. To achieve a working environment in which team spirit and commitment to the goals and values of THINK TANK are maintained, the firm will ensure that individual employees are treated fairly and with dignity and respect.
In dealing with our employees, we will act in compliance with national regulatory requirements and employers’ obligations to employees under labor or social security laws and regulations must be respected.
Harassment can be defined as unwanted behavior, which a person finds intimidating, upsetting, embarrassing, humiliating or offensive. Conduct involving the harassment (racial, sexual or of any other kind) of any employee is unacceptable. Should an employee believe that he or she has been harassed the matter should be raised with the relevant Human Resources Manager who will arrange for it to be investigated without delay, impartially and confidentially.
Equal Employment opportunity
We value all our employees for their contribution to our business and their opportunities for advancement will be equal and not influenced by considerations other than their performance, ability and aptitude. Employees will also be provided with the opportunity to develop their potential and, if appropriate, to develop their careers further with the Firm.
Health & safety
THINK TANK™ CONSULTING places the highest priority on promoting the health and safety of employees whilst at work.
Terms of employment
THINK TANK™ CONSULTING and its employees will work towards creating permanent long-term relationships. Employees will be paid for and work hours at least as favorable as the terms established by national legislation or agreements or industry standards.
Pre-employment screening and selection
In order to protect the interests of our employees and clients, and because of the nature of our consultancy, THINK TANK™ CONSULTING will apply rigorous pre-employment screening and selection techniques.
5. OUR EMPLOYEES’ COMMITMENTS TO THINK TANK™ CONSULTING
Employees must avoid situations where appearance of consultancy impropriety exists, even though the circumstances might not otherwise specifically violate this code of conduct or where specific laws or regulations do not apply.
Employees must not make use of confidential information obtained through their employment for personal gain, nor disclose such information to any third party during or after their employment. ‘Confidential information’ is either information that has been specifically described as being confidential or is otherwise obviously confidential from the surrounding circumstances.
The term “confidential information” does not include information in the public domain or information which the individual concerned is required by law to disclose.
Conflicts of interest
Every employee has a duty to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of the Firm, or which divides his or her loyalty to the Firm. Any activity which even appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not unethical or improper, does not compromise integrity and is not detrimental to the reputation and standing of the firm.
This Business Ethics Policy must be adopted by all service lines as a minimum standard and issued to all THINK TANK™ CONSULTING Service Line Heads. It will be published on our website and incorporated into future employment contracts where applicable. It will be monitored as part of THINK TANK™ CONSULTING Compliance Processes. The policy will be reviewed annually. Where THINK TANK™ CONSULTING associates already have their own published ethics policies, these must be reviewed against this Firm Policy to ensure they meet the same minimum standards.
Staff complaints and suggestions
Staff can expect that the Firm will give due consideration to their constructive suggestions and will provide a considered and objective review of genuine concerns and complaints. Such concerns include fraud, misrepresentation, theft, harassment, discrimination and non-compliance with regulations, legislation, policies and procedures.
Concerns must be investigated impartially so that the employee’s rights are protected. Employees who have concerns about potential unethical behavior should advise their local Human Resources or Service Line Head in the first instance. Employees may do this anonymously if they so wish. To ensure that confidentiality is maintained, employees should not discuss such concerns with colleagues or other third parties, unless specifically authorized or unless it is a legal requirement.
If the employee is dissatisfied with the response to the concern which he or she has raised, or if the concern relates to a matter of exceptional gravity or sensitivity, he or she can contact CEO.
We will monitor, on a regular basis, compliance with this ethics policy, using information reported and ongoing management reporting.
Adherence to Policy
Since THINK TANK™ CONSULTING aims to maintain high ethical standards in carrying out its consultancy activities, practices of any sort that are incompatible with the Firm’s principles and policies are not tolerated. Strict adherence to these principles and supporting policies is a condition of employment in the Firm. Any action by an employee, which deliberately or recklessly breaches this ethics policy, may result in disciplinary action and where appropriate, criminal proceedings will be instituted.