Code of Ethics
- General Policy
- Purpose of Code of Ethics
- Principles of Code of Ethics
- Guidelines regarding gifts and hospitality
General Policy
It is the policy of the CIE Group to maintain its high reputation for ethical behaviour and fair dealing in the conduct of its business.
In many cases decisions as to what is ethical or fair are clear cut and will be obvious to any reasonable person. In some situations, however, there may be circumstances where an element of doubt or ambiguity arises. To help in those circumstances and to protect and guide individual employees of the CIE Group, it is necessary to have a written code of ethics.
It is not possible to provide for every situation in the code of ethics. If there is doubt about the probity of any particular situation, the Head of Group Procurement must be consulted about that situation by the individual concerned.
Purpose of the Code of Ethics
The purpose of the Code of Ethics is to offer guidance to CIE Group employees in their business conduct.
The Code of Ethics applies to all the employees of the Group. Employees who are engaged in the purchasing of goods or services, the placement of contracts or the approval of payments to or by the Group must have particular regard to the terms of the Code.
Principles of the Code of Ethics:
The guiding principles of the Code of Ethics can be summarised under four headings:
- Integrity
- Confidentiality
- Legality
- Disclosure of interest
Integrity
Each employee of the CIE Group is expected to observe the highest standards of honesty and integrity in all his/her business dealings.
To this end, as
an employee, one must:
- refuse bribes, gifts or hospitality which may affect one’s ability to make independent judgement, and report any such approaches in writing to one’s superior
- avoid misrepresenting one’s position or being ambiguously misleading
- reject any business practice which might reasonably be deemed to be improper
- not abuse one’s position in the Company for personal gain
Confidentiality
Every employee in the CIE Group owes a duty of confidentiality to the Group. Employees are required to ensure that business information which they obtain by reason of their employment is not mis-used, whether by suppliers, their competitors or competitors of the CIE Group.
In order to protect such information, employees are required to:
- ensure that such information is properly safeguarded
- exercise due care in communicating such information
- avoid using such information for personal gain.
Employees are reminded that the Transport (Re-Organisation of Coras Iompair Eireann) Act, 1986, includes a specific duty not to disclose confidential information. Breach of this statutory duty is an offence.
Legality
In order to ensure compliance in one’s business dealings with the laws of Ireland, employees are required to:
- fulfill all regulatory and supervisory obligations imposed on CIE
- co-operate with relevant regulatory and supervisory bodies
- avoid false, inaccurate or mis-leading entries in record
- ensure that taxation and welfare legislation is upheld
- ensure one’s actions comply with relevant contractual obligations
- encourage effective and fair competition at all times
- comply with the Group purchasing and tendering procedures and with prescribed levels of authority for sanctioning any relevant expenditure
- avoid engaging in any illegal or criminal activities
Disclosure of Interest
All employees of the CIE Group are required to disclose in writing to the Head of Group Procurement, through their superiors, details of any conflict of interest which might affect their impartiality in carrying out their duties as soon as they become apparent, including:
- any interest, shareholding or possible conflict of interest an employee has with any firm or organisation from which the CIE Group purchases supplies, works or services, or through whom the CIE Group proposes to sell property or services
- any outside employment or business interests in conflict or potentially in conflict with CIE’s business
- any interest of an employee’s immediate family which could involve such a conflict of interest
Where a conflict of interest situation could arise for an employee, he/she must desist from dealing with the contract giving rise to that situation, and may not attempt in any way to influence the Company decision on the matter.
Guidelines regarding Gifts or
Hospitality
It is customary for many suppliers to offer gifts, hospitality or entertainment to named employees with whom they have contact as a result of business dealings.
Gifts
Employees may accept gifts from suppliers to or contractors who have worked for the CIE Group , provided:
- the gift is unsolicited
- the gift is one of very small intrinsic value (eg diary, calendar, bottle of wine/spirits etc)
- the value of such gifts accepted in a year from any one source do not exceed €100
- the gift is disclosed to that employee’s immediate superior
In all other cases, the gift should be returned to the sender, with a note advising that acceptance would be contrary to Group policy. Details of returned gifts must be notified at once to the recipient’s superior
Sponsorship requested on behalf of a club or society within the CIE Group from suppliers or contractors to CIE must not exceed in any year €500 total value of sponsorship from such supplier or contractor unless the approval in writing of the Group Chief Executive is obtained.
Hospitality
Modest hospitality (including sporting events and golf outings) may be accepted, provided:
- the frequency and scale of hospitality is not more than CIE might be expected to give in return
- the number of CIE staff availing of the hospitality is kept to a minimum
- invitations do not include the provision of travel or overnight accommodation and availing of the hospitality does not identify the CIE Group in a public way with any particular supplier or contractor.
Note: Breaches of the Code of Ethics will be regarded as a breach of discipline and will be dealt with in accordance with the disciplinary code by the Group Chief Executive or Chief Executives of the subsidiaries, as appropriate.