Business Conduct and Ethics

Harlow Stewart Limited (“we,” “us,” or “our”) is dedicated to upholding the highest standards of ethical conduct in all our business operations. This Business Conduct and Ethics Policy outlines the principles that guide our actions and expectations for all employees, directors, officers, and representatives.

1. Commitment to Ethical Conduct

We are committed to operating with integrity, transparency, and accountability. This policy serves as a framework to help maintain high ethical standards in our daily activities, ensuring compliance with all relevant laws and regulations.

2. Compliance with Laws and Regulations

We expect all employees to fully comply with relevant laws, regulations, and company policies. It is each employee’s responsibility to understand the legal requirements pertinent to their role. If there is any uncertainty, employees are encouraged to seek guidance to ensure full compliance.

3. Integrity and Fair Dealing

We conduct our business with honesty, fairness, and respect for all parties involved. Employees must avoid conflicts of interest and promptly disclose any situation that could be perceived as such. We are committed to fair competition and steer clear of any activities that may be deemed anti-competitive or unethical.

4. Confidentiality and Data Protection

Protecting confidential information is paramount. Employees must not disclose sensitive information to unauthorized individuals. Personal data must be handled responsibly and in strict compliance with data protection laws, including the UK GDPR. Sensitive information should be securely stored and only shared on a need-to-know basis.

5. Anti-Bribery and Corruption

We strictly prohibit any form of bribery or improper payment. Employees must not offer, give, solicit, or accept bribes under any circumstances. Any suspected instances of bribery or corruption should be reported immediately to the appropriate internal authorities.

6. Workplace Conduct and Respect

We are committed to fostering a work environment where everyone is treated with respect and dignity. Discrimination, harassment, and bullying are not tolerated. We actively promote diversity and inclusion, ensuring that all employees feel valued and respected.

7. Environmental Responsibility

We are dedicated to conducting our business in an environmentally sustainable manner. Efforts should be made to minimize waste, conserve resources, and reduce our environmental impact across all operations.

8. Health and Safety

Maintaining a safe and healthy work environment is a priority. Employees must adhere to all health and safety regulations and company policies, reporting any concerns or incidents immediately to ensure swift action is taken (see Health Safety and Environment policy).

9. Use of Company Resources

Company resources, including time, materials, and information, should be used responsibly and only for legitimate business purposes. Misuse or theft of company assets is strictly prohibited.

10. Financial Integrity

We require that all financial records are maintained with accuracy, completeness, and transparency. Employees must follow accounting standards and internal controls to prevent fraud or financial mismanagement. Any suspicious financial activities should be reported to the relevant authorities without delay.

11. Reporting and Whistleblowing

We encourage the reporting of any unethical behavior, violations of laws or company policies, and other concerns. Whistleblowers are protected from retaliation, and their reports will be handled confidentially and investigated promptly to ensure appropriate actions are taken.

12. Implementation and Compliance

It is the responsibility of every employee to understand and adhere to this policy. Compliance is essential for maintaining the trust and confidence of our stakeholders, including customers, employees, and the community.

Conclusion

Adhering to this Business Conduct and Ethics Policy is vital to upholding the trust placed in us by our stakeholders. We are committed to maintaining the highest ethical standards in all our business dealings and interactions.