Updated 8 November 2018
Improper activity is any activity by the Company or by a Gough Group employee in the course of his/her employment or by a contractor to the Gough Group in the course of his/her engagement which:
- violates any law or regulation, or
- constitutes theft, fraud, harassment, bribery, misuse of assets or corruption, or
- could pose a significant threat to the health and safety of employees or the public, or
- could pose a significant threat to the environment, or
- could result in the ethics or integrity of the Gough Group being brought into question, or
- is a conflict of interest that gives rise to behaviour which disadvantages the Company.
If in doubt as to whether something constitutes improper activity, the best course of action is to report it.
Reporting Improper Activity
Where you know that improper activity is occurring or has occurred or where you have reason to suspect it is occurring or has occurred, we ask that you contact one of these people without delay:
Keith Sutton, Chair
Phone – 027 442 0049
Liz Ward, Group Chief Executive Officer
Phone – 027 619 8824
What Will Happen After your Report is Made?
After receipt of the information, the Chair or the Group CEO (as appropriate) will initiate an investigation into the matter. Where you request it, you will be kept informed of progress.
It is extremely important that, following your report, you do not speak to anyone else about the matter, as to do so could jeopardise the investigation.
Updated: 8 November 2018