Code of Conduct & Ethics Policy

Purpose

This Code articulates the ethical and professional standards that everyone who works for or acts on behalf of The ESG Institute Limited ("the Company") must uphold. It consolidates the core requirements contained in our Diversity, Equity & Inclusion (DEI), Anti‑Bribery & Corruption (ABC), Bullying & Harassment, Safeguarding, Information‑Security, Health & Safety, Environmental, Privacy and Whistleblowing policies. Compliance safeguards learners, clients, colleagues, the public and the Company’s reputation.

Scope

The Code applies worldwide to all directors, officers, employees, workers, agency staff, contractors, consultants, secondees, interns, volunteers and any third parties who represent the Company or have access to its information or premises. Observance is a contractual obligation and a condition of engagement.

Values and Guiding Principles

  • Integrity – act honestly and transparently, keep promises, declare mistakes and correct them quickly.

  • Respect & Inclusion – treat everyone with dignity and courtesy, value diverse backgrounds and perspectives, foster psychological safety.

  • Responsibility & Accountability – own the consequences of decisions, steward resources wisely and follow through on commitments.

  • Excellence – pursue evidence‑based practice, innovation and continuous improvement in learning and consulting services.

  • Sustainability – consider long‑term environmental and social impacts in strategies and daily actions.

Professional Behaviour

Carry out duties competently, diligently and in accordance with relevant laws, regulations, professional codes and Company policies. Maintain the qualifications, licences and continuing professional development (CPD) necessary for your role. Refrain from any conduct—on or off duty—that could bring the Company into disrepute or undermine trust in our services.

Equality, Diversity & Inclusion

We are committed to equality of opportunity and to eliminating discrimination, harassment and victimisation. All Personnel must:

  • Make decisions on recruitment, assessment, promotion, pay and project allocation solely on merit and objective criteria.

  • Use inclusive language and materials in all training, consultancy and marketing outputs.

  • Provide reasonable adjustments for colleagues or learners with disabilities, including accessible formats and flexible delivery.

  • Challenge discriminatory jokes, slurs, stereotyping or micro‑aggressions—whether face‑to‑face, online or in teaching content—and report serious or repeated incidents.

  • Undertake mandatory DEI training and refresh it at least every two years.
    Managers must analyse team diversity metrics annually, identify any under‑representation and implement positive‑action measures permitted by law.

Bullying, Harassment and Safeguarding

Bullying or harassment—verbal, physical, visual or cyber—is unacceptable. This includes persistent criticism, exclusion, sexual advances, threats, offensive remarks or the distribution of inappropriate material. All Personnel must:

  • Treat everyone with courtesy; respect personal boundaries.

  • Intervene early to stop unacceptable behaviour or seek help if intervention is unsafe.

  • Record and report any incident of bullying, harassment or exploitation via the Grievance Procedure or directly to HR.
    When working with children or adults at risk, follow the Safeguarding Policy: verify identity, obtain informed consent for images or data, avoid lone working, maintain professional boundaries and escalate any disclosure or suspicion of abuse to the Designated Safeguarding Lead within two hours.

Anti‑Bribery, Gifts and Hospitality

Bribery and facilitation payments are strictly prohibited. You must not offer, give, request or accept anything that could influence—or appear to influence—a business decision.

  • Gifts & hospitality thresholds – up to £50 (line‑manager approval); £50–£150 (Compliance Officer approval); over £150 (CEO sign‑off and discouraged). Cash, vouchers, personal discounts and lavish entertainment are banned.

  • Recording – declare all gifts, hospitality, sponsorships, and charitable donations in the Gifts & Hospitality Register within five working days.

  • Third parties – ensure agents, consultants and resellers sign ABC clauses and pass due‑diligence checks before engagement.

  • Facilitation payments – if you face coercion (e.g., at a border checkpoint), pay only if life, liberty or health is at risk, obtain a written receipt where possible and report the incident to the Compliance Officer immediately.

Conflicts of Interest

Conflicts arise when personal, financial or other interests could impair, or be perceived to impair, impartiality. Examples include secondary employment, family or intimate relationships in the supply chain, shareholdings in client organisations, or outside directorships.

  • Declare potential conflicts using the Conflict‑of‑Interest Disclosure Form as soon as they arise and renew annually.

  • Refrain from decision‑making or influencing procurement or assessment where a conflict exists until mitigations (e.g., recusal, divestment) are approved in writing by the Company Secretary.

  • Managers must maintain a local conflicts register and review it quarterly.

Confidentiality and Data Protection

Protect Company and client information classified as Internal, Confidential or Restricted.

  • Share only on a need‑to‑know basis and via secure channels (encrypted email, SharePoint with MFA).

  • Apply appropriate retention and deletion rules per the Data‑Retention Schedule.

  • Conduct Data‑Protection Impact Assessments (DPIAs) for new projects involving personal data.

  • Sign Non‑Disclosure Agreements (NDAs) before accessing sensitive third‑party information.

  • Report any unauthorised disclosure or suspected personal‑data breach immediately using the Incident‑Reporting Procedure.

Use of Company Assets and IT Systems

Company assets—laptops, phones, software licences, vehicles—must be used responsibly and primarily for business purposes.

  • BYOD (bring‑your‑own‑device) is allowed only with prior IT approval, installation of mobile‑device management (MDM) software and compliance with encryption requirements.

  • Software must be sourced from authorised app stores or the Company software catalogue; pirated or unlicensed tools are forbidden.

  • Cloud services outside the approved list (Microsoft 365, Teachable, Stripe, Eventbrite) require CISO approval and a security assessment.

  • Social‑engineering awareness: verify caller identity, avoid sharing credentials, and escalate suspicious requests.

  • Lost or stolen devices must be reported within one hour; IT will initiate remote wipe and incident response.

Accurate Records and Reporting

Maintain records that are complete, legible, timely and truthful.

  • Financial entries must align with International Financial Reporting Standards (IFRS) and the Company’s Finance Manual.

  • Timesheets must reflect actual hours worked; falsification is gross misconduct.

  • Expense claims require original receipts, clear business purpose and submission within 30 days.

  • Learning assessments and certificates must reflect genuine learner performance; altering grades or attendance for commercial reasons is prohibited.
    Misreporting may constitute fraud and will be referred to law‑enforcement authorities.

Communications and Social Media

Public statements—press releases, conference talks, LinkedIn posts—must be factual, respectful and consistent with the Company’s brand.

  • Only authorised spokespeople may speak to journalists or issue official statements.

  • Include a disclaimer when expressing personal views online: “Opinions are my own and not necessarily those of The ESG Institute.”

  • Do not share confidential material or learner personal data.

  • Refrain from posting discriminatory, harassing or defamatory content or endorsements of extremist views.

  • Obtain the Company’s permission before using the Company logo.

Health, Safety & Well‑being

Everyone must:

  • Follow risk‑control measures detailed in local risk assessments, including ergonomic workstation set‑up for home workers and safe‑driving rules for business travel.

  • Wear personal protective equipment (PPE) where required (e.g., site visits).

  • Report hazards, accidents, near misses and work‑related stress symptoms promptly to the HSO.

  • Participate in mandatory training (fire safety, first aid, manual handling).
    Managers must review workloads, encourage regular breaks, offer flexible working, and signpost mental‑health support (Employee Assistance Programme, Mental‑Health First Aiders).

Environmental Responsibility

Support the Company’s target to achieve net‑zero operational emissions by 2035. Practical actions include:

  • Choose low‑carbon travel (train over plane) and consolidate trips where feasible.

  • Switch off lights, equipment and HVAC when not in use; enable power‑saving modes.

  • Minimise printing; default to double‑sided and black‑and‑white.

  • Segregate waste and recycle according to local facilities; avoid single‑use plastics.

  • Select suppliers with credible environmental credentials and require them to meet the Supplier Code of Conduct.

Raising Concerns (Speak‑Up)

If you witness or suspect misconduct, legal breaches or violations of this Code:

  1. Raise it with your line‑manager or the Compliance Officer, or

  2. Mail mail@the-esg-institute.org, or

  3. Though the contact form on our website.

Concerns may be raised anonymously. The Company will acknowledge receipt within five working days, keep you informed, protect your identity as far as practicable, and prohibit any form of retaliation. Malicious or knowingly false reports may themselves lead to disciplinary action.

Non‑Compliance and Disciplinary Measures

Breaches of this Code or related policies will be investigated in line with the Disciplinary Procedure. Sanctions may include verbal or written warnings, suspension, demotion, repayment of losses, summary dismissal, termination of contracts, civil action for damages and referral to law‑enforcement or regulatory bodies. Disciplinary decisions will consider intent, impact, prior conduct and cooperation during the investigation.

Review

This policy is to be reviewed every two years, or earlier if there are significant changes in law or our operations.

Latest update: June 30, 2025.

This Policy is non‑contractual and may be amended at the Company’s discretion.