Introduction
Bell Procurement Management (also referred to as ‘Bell PM’) is committed to maintaining high standards in the conduct of all its business activities. It expects and requires all its employees to become stakeholders in the commitment to meeting these standards.
These standards are borne out of the core principles and values that underpin our business, that of integrity, honesty, and openness so that our customers can rely on Bell PM’s One Version of Events ethos.
We appreciate and understand the commercial reality of our customer and that circumstances change. As a procurement partner, we operate in an agile and responsive manner so that we can always deliver value to our customers. Our commitment is to do all this in a friendly and engaging manner.
Purpose of this Code
In the spirit of transparency, and openness the Code of Conduct (“the Code”) is a public statement designed to help employees and others make informed, ethical decisions and to demonstrate our commitment to doing the right thing.
While this Code addresses a wide variety of topics, Bell PM relies on you to use your judgement, experience and above all common sense as it cannot, and does not, address every possible situation.
Operating in many countries, as we do, means there may be times when international or local laws, regulations, or customs present a challenge to applying the Code. Whenever there is a choice between applying the Code or adhering to the spirit of the Code and local customs, you are expected to apply the strictest standard and not follow customs that violate the Code. If in doubt, you are expected to seek advice before taking any action that may compromise yourself or Bell PM.
Bell PM’s reputation as an ISO certified, customer-centric, innovative, and agile business, focused on sustainability is integral to its ongoing growth and success. Please take the time to read this Code, keeping in mind that over time as Bell PM grows and evolves, this Code will necessarily evolve as well.
Who must follow this code?
Our Code applies to all Bell PM employees, officers, and members of the Board.
Business partners, including third parties, can have a direct impact on our reputation through their actions. For this reason, we want to work with business partners that share our values and expectations and encourage all our contractors and their employees to act in a way that is consistent with the Code. Where we find or believe that our business partners have breached the values in the Code, we will always take steps to preserve its integrity.
Each of us has a personal responsibility to incorporate, and to encourage each other to integrate, these principles into our work. All suggestions as to how this Code can be improved will be welcomed.
Our Expectations
Quality
We deliver our services and internal processes securely and in line with industry best practices, to provide prudent and commercially pragmatic solutions for our customers. We pride ourselves on our integrity and reliability and as a sound commercial partner on whom others can rely. To facilitate this, you should understand and manage risks well by:
- Conducting your work in a professional manner and in a way that follows our quality control standards and, where quality measures don’t exist, by defining them.
- Maintaining any professional registrations and certifications needed to ensure that customers receive the most competent and contemporaneous professional service.
- Continuing your own personal professional development by seeking to develop skills, learn new ones and further improve your understanding of your subject area. You can do this by taking advantage of Bell PM’s numerous learning options; and
- Not making promises or commitments that you or Bell PM cannot, or do not intend to, honour.
Buying responsibly
Bell PM supports industry-wide professional standards and encourages all buyers to adhere to the CIPS Code of Ethics and Professional Conduct 2022.
Bell PM’s team of Buyers has developed a reputation for working with our business partners in an honest, transparent, and ethical way, always respecting diversity, local cultures, and customs.
Our suppliers and business partners are essential to our ability to do business and meet our stakeholders’ expectations. That is why we choose carefully to seek to work with others who share the same approach as us.
Make sure you know and follow the Bell PM customer-related requirements that apply and communicate our policies and procedures regularly to suppliers.
Report to the Director, Procurement Services, or use the Whistleblowing procedure, any indications that a supplier or business partner is not complying with applicable laws or their contractual obligations.
Collaborate with suppliers to foster effective Integrated Management Systems and consider human rights, anti-bribery, and corruption policies in the relevant supply chain, as well as environmental and social performance as part of an evaluation of the supplier.
Ensure that the reports and records used to assess supplier’s performance are treated as confidential and not disclosed to any third party without the supplier’s written consent.
Fair competition
The international nature of the Bell PM business means that we are subject to a variety of laws and regulations around the world that prohibit anti-competitive practices. At a general level you must not communicate competitively sensitive information directly with any of our competitors or indirectly through an intermediary. This includes information like costs, prices, discounts, sales, terms of business. Information is more likely to be competitively sensitive if it is not public. Caution should be exercised when attending any trade association event to make sure you are not participating in any discussions that could be considered anti-competitive.
Under no circumstances should you agree with a customer, supplier, distributor, or reseller the price at which goods or services should be re-sold and any exclusivity arrangements or restrictions on re-sale into another territory or market should be subject to legal approval.
Competition and antitrust laws are complex. If you have any doubts or questions consult the Legal team.
If you have reason to believe that there may have been anti-competitive behavior, then you should make this known to your line manager unless that is not practical in which case follow the Whistleblowing policy and procedure.
Respecting international trade laws
We abide by the trade laws of all countries in which we operate including trade embargos, economic sanctions as well as import and export laws.
Most countries in which Bell PM operates impose a certain level of restriction on the movement of products across borders; this can often be a complex area with wider commercial and legal ramifications.
If you have any questions speak to your manager or the Legal team.
Preventing money laundering
Money laundering is the process of hiding the source and/or the provenance of funds or moving those funds from one person/organisation to another when there is a reasonable expectation that those funds have been obtained because of illegal activity. The process of making these funds appear legitimate is known as ‘washing’ and is also illegal. Laundered money often benefits organised crime groups and can even fund terrorism.
The law surrounding money laundering is necessarily stringent and covers individuals and organisations alike. You should familiarise yourself with our due diligence procedures.
If you have any questions always raise them immediately with your line manager and remember to never let the person or organisation in question know that you have concerns or that you have raised your concerns with your line manager.
Solicitation and distribution
Solicitation is any form of request for money, support or participation for products, groups, organisations or causes which are unrelated to our operations. Distribution means disseminating literature or material for commercial or political purposes.
We don’t allow solicitation and distribution in the workplace unless it is to seek support for a cause, charity or fundraising event sponsored, funded, organised, or authorised by Bell PM.
Political activity
In accordance and in compliance with applicable laws, Bell PM exercises its right and responsibility to make its position known on relevant issues. As an individual, you have the right to personally participate in the political process, including making personal political contributions. However, you need to make it clear that your personal views and actions are personal and not reflective of Bell PM.
Do not use company funds or resources to support any political candidate or party. Obtain approval before engaging in any lobbying activities.
Personal political activities can sometimes create a conflict with Bell PM. Talk to your manager if you or a close relative are planning to accept or seek a position in public office, or if any other political activity might have an impact on Bell PM or on your job.
Sustainability and environmental protection
Use your skills and expertise to deliver our services in a sustainable manner and to find opportunities to make a positive impact on the planet.
Encourage the use of local workforces, suppliers, and goods where feasible and appropriate.
Do not disrespect or deliberately ignore local customs or traditions.
Personal Declaration
Bell PM’s continued reputation and success depend, to a very large extent, upon all of us playing an active role in caring about our work, our customers, and our communities.
Be familiar with this Code, understand and comply with it.
Speak up when you see something you don’t think is right, when you have an idea, a question, or a concern.