1.1 Giving and Offering Improper Payments: Orderly Limited prohibits any employee from providing, offering, or authorising anything of value to any government official or private party (such as vendors, suppliers, contractors, or clients) for the purpose of obtaining or retaining business or securing any improper advantage. This includes payments to representatives of private commercial enterprises.
A “government official” includes any person acting in an official capacity for any foreign government, agency, or department, including employees of government-owned enterprises and international organisations such as the United Nations and the Red Cross.
1.2 Requesting and Receiving Improper Payments: Employees are strictly prohibited from receiving or requesting anything of value from third parties, such as vendors, suppliers, contractors, or clients. This prohibition applies to both direct and indirect transactions.
No employee will face disciplinary action for refusing to engage in bribery, regardless of any potential adverse impact on business outcomes. Violations of anti-bribery laws can result in severe penalties, including fines and imprisonment for those involved.
All financial transactions must be recorded accurately and in reasonable detail in Orderly Limited’s books and records. The creation of undisclosed or unrecorded accounts is prohibited, and personal funds must not be used to bypass this policy.
Orderly Limited is prohibited from using third-party agents to make corrupt payments on its behalf. We require that all third-party agents acting on our behalf are thoroughly vetted, comply with anti-bribery laws, and understand that they are prohibited from making or receiving bribes.
The term “third-party agents” includes entities or individuals acting on our behalf, such as agents, contractors, consultants, corporate service companies, payroll providers, advertising agencies, and law firms.
Employees and stakeholders are encouraged to report any concerns or suspicions regarding bribery or corruption through our Whistleblower Policy. All reports will be treated confidentially and investigated promptly.
5.1 Scope and Coverage: This policy applies to all employees, contractors, consultants, officers, interns, and agency workers. It outlines the procedures for reporting dangerous, unlawful, or unethical activities, ensuring that such concerns are addressed swiftly and effectively.
5.2 Types of Concerns: Concerns that may be raised include suspected criminal activities, health and safety risks, environmental damage, breaches of anti-bribery and corruption policies, and failures to comply with legal or regulatory obligations.
5.3 Confidentiality and Anonymity: While we encourage open reporting, we also respect the anonymity of whistleblowers. We will take all reasonable steps to protect the identity of individuals who prefer to remain anonymous and ensure the confidentiality of the reported concerns.
5.4 Protection for Whistleblowers: Orderly Limited is committed to protecting whistleblowers from reprisals. Individuals raising concerns in good faith will not face any adverse consequences, even if the investigation does not substantiate their concerns. We also protect whistleblowers from retaliation by others, with disciplinary actions against those who threaten or mistreat whistleblowers.
5.5 External Whistleblowing: While we encourage internal reporting, we recognise that there may be exceptional circumstances where external reporting to regulators or independent organisations is necessary. Whistleblowers may contact independent bodies such as Public Concern at Work for guidance.
5.6 Media Involvement: Involving the media can complicate investigations and is generally discouraged. Any unauthorised contact with the media regarding whistleblowing concerns will be treated as a serious disciplinary matter.
5.7 Reporting Procedure: Employees should first report concerns to their manager. If this is not appropriate, concerns should be directed to HR. Anonymous reports can be submitted via an anonymous form available through HR, although direct reporting is preferred for thorough investigations.
Orderly Limited values and respects all reports made in good faith and is committed to maintaining a safe, ethical, and compliant work environment.
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