OUR CODE
OF ETHICS
What Intertek expects of you
OUR CODE OF ETHICS
CONTENTS
Introduction 3
Our relationship with our employees and our environment 4
Equal Opportunity 4
Human Rights 4
Health & Safety 4
Bullying, Harassment, Discrimination and Misconduct 4
Environmental & Corporate Social Responsibility 4
Our commitment to integrity 6
Integrity 6
Bribery and Corruption 7
Conflicts of Interest 7
Gifts and Hospitality 8
Political and Charitable Contributions 8
Insider Dealing 8
Our relationship with customers, partners and the marketplace 10
Working with our Customers 10
Partners, Contractors, Agents, Intermediaries and Suppliers 10
Fair Marketing and Anti-Trust Competition 10
Export, Import and Trade Controls 10
Our obligation to protect our assets, confidential information, shareholders
and reputation 12
Protecting our Assets and Resources 12
Confidentiality 12
Our Shareholders 12
Public and External Communications 12
Seeking guidance and reporting concerns or breaches of the Intertek Code
of Ethics 14
2
INTRODUCTION
INTRODUCTION
Our Mission and Values statement clearly declares that we act with integrity, honesty and
respect. We must always ensure that we live out those values every day.
One of our primary business objectives is to help our customers meet quality standards for
virtually any market in the world and protect them against risk by ensuring compliance with
local, national and international laws. The accuracy and validity of reports and certificates that
we provide and maintaining the trust and confidence of our customers, their customers and
others impacted by our work, are therefore important factors which contribute to our success.
Our reputation is built on the integrity and know-how of our people, so we do not tolerate
unethical behaviour by our employees, contractors, agents or anyone acting on our behalf.
To protect our business and our employees, this Code of Ethics sets out the principles
and rules that govern our business conduct. It helps anyone representing the Company to
understand what is expected of them and ensures that we always act responsibly and with
integrity.
The global business environment has become increasingly complex in recent years. The
Code of Ethics outlines what you must do to comply with local laws and regulations and
incorporates the International Federation of Inspection Agencies (IFIA) principles of Integrity,
Confidentiality, Conflicts of Interest, Anti-Bribery and Fair Marketing.
All those working for or on behalf of Intertek are required to sign our Code of Ethics upon
joining the Company or before commencing work on our behalf. It is the responsibility of each
Intertek employee or person acting on Intertek’s behalf to understand and apply the Intertek
Code of Ethics in their own job role, their part of the business and location.
Failure to comply with the Code of Ethics may expose Intertek, its employees, customers or
others to serious harm and may also damage the business and reputation we have all worked
hard to earn. We could also be exposed to financial penalties and even imprisonment of
individuals in serious cases of misconduct.
Intertek is committed to maintaining a culture where issues of integrity and professional
ethics can be raised and discussed openly. This is why we provide hotline facilities for all
employees, contractors and others representing Intertek, to enable confidential reporting of
suspected misconduct or breaches of the Code.
This guide should answer any questions or concerns you may have about our Code of Ethics.
However, if you should need further guidance, please contact your line manager or Regional
Compliance Officer for further information.
3
OUR CODE OF ETHICS
OUR RELATIONSHIP WITH
OUR EMPLOYEES AND OUR
ENVIRONMENT
Equal Opportunity with relevant local legislation and guidelines Environmental & Corporate Social
We believe that all Intertek employees in any area in which we operate. Responsibility
should have equal opportunity of We continually seek to minimise risk to The nature of the work that Intertek does
employment, fair reward and career our employees, clients and others who for its clients has a direct benefit in reducing
advancement on the basis of ability, may be affected by our operations and harm to the environment and tackling
performance, necessary qualifications and our procedures are regularly monitored by climate change. In our own operations, we
conduct. We recognise and harness the value our compliance team to ensure that they are committed to minimising our impact on
that individuals of different backgrounds are being properly applied in practice. Our the environment through reducing energy
and capabilities bring to our business. Our internal policies require quality, health, safety consumption at our sites, utilising renewable
diverse workforce helps us to understand, and environmental (QHSE) incidents to be energy sources, implementing ‘green’
communicate and trade with our vast client recorded, reported and investigated, with waste management practices, minimising
base through their understanding of local QHSE representatives being responsible travel, undertaking carbon offsetting and
issues and cultures. for the investigation of incidents and operating quality management systems.
Intertek’s employment policies and practices implementing corrective actions. Employees Our Environmental Policy is implemented
operate within a framework which reflects a are encouraged to report incidents and offer by country managers at a national level
culture of merit where decisions are based suggestions for QHSE improvements. in compliance with local guidelines and
on the individual’s ability to perform in regulations.
Bullying, Harassment, Discrimination
relation to the needs of the business. These Supporting the communities in which we
and Misconduct
policies complement and conform to local operate is important to Intertek. We expect
Intertek requires its employees to respect
and national laws, regulations and codes our employees to respect the communities
everyone they work with and does not
of practice. We act to apply all employment in which they live and work and we support
tolerate abuse, bullying or harassment in
policies and practices, including recruitment, and encourage their involvement in
any form. Inappropriate sexual advances
promotion, reward, working conditions charitable and community activities.
and unwelcome physical contact is wholly
and performance management, in a way
unacceptable. Discrimination based on
that is informed, fair and objective. Our
gender, age, ethnicity, religion, nationality,
Inclusion & Diversity Policy acts to eliminate
disability, sexual orientation, social origins
discrimination so that all our employees
and associations, political affiliations and
are treated fairly and feel respected and
union membership, will not be tolerated
included in our workplaces.
by Intertek. Recruitment, promotion and
Human Rights employment-related decisions will be based
Intertek is committed to respecting the on performance and merit as well as other
United Nation’s (UN) convention on Human job-related factors.
Rights and the International Labour If you are found to have abused, bullied,
Organisation’s (ILO) eight core conventions harassed or discriminated against a fellow
on fundamental human rights; those being: employee you will be liable to disciplinary
non-discrimination; forced labour; child action, including dismissal. Any employee
labour; freedom of association and collective engaging in work related criminal activity will
bargaining; harassment; working hours; be dismissed, and may be reported to the
benefits and wages; leave; and employee appropriate authorities. Any cost of defence
contracts and letters. will be borne by the employee.
Health & Safety Intertek does not tolerate working under
Intertek considers the health, safety and the influence of alcohol or illegal drugs while
welfare of its employees, clients and third at work. Use of alcohol or drugs or being in
parties connected with its business to be of any way intoxicated whilst in the workplace
paramount importance. We aim to provide could lead to health and safety risks, as well
a safe and healthy working environment as affect your ability to perform your job.
and ensure that our employees have the Employees found to be intoxicated or using
information and resources to perform alcohol or drugs whilst working will face
their duties safely. We are committed to disciplinary action, including dismissal.
maintaining high standards and complying
4
SEEKING GUIDANCE AND REPORTING CONCERNS OR BREACHES OF THE INTERTEK CODE OF ETHICS
Our employees and our environment - what Intertek
expects of you
• Treat your colleagues and your neighbours with courtesy, dignity and respect.
• Work in a safe and responsible manner.
• Never be under the influence of alcohol or illegal drugs at work.
• Respect your environment and use materials and energy efficiently and safely.
• Report any breaches of the above to your line manager, your Regional Compliance Officer or
via the Intertek Global Hotline.
5
OUR COMMITMENT
TO INTEGRITY
Our responsibility is to conduct all business contracts with Intertek. Criminal violations
according to the highest professional and committed by employees outside of their
ethical standards and practices. Intertek’s employment will be taken very seriously by
work shall be carried out in an independent Intertek and may lead to consequences such
and impartial manner, using appropriate as disciplinary sanctions and even dismissal
methods and procedures and in accordance in serious circumstances.
with local and international laws. Intertek prides itself on the integrity and
Intertek does not tolerate corruption high quality of its services and all employees
and bribery. It is important that Intertek’s must carry out their work to those
employees, contractors, agents, joint venture standards. Customers value our integrity
partners and distributors as well as those and expect us to remain impartial. Data, test
third parties conducting business with results and other material facts shall be
Intertek, fully understand Intertek’s zero reported by Intertek in good faith, will not
tolerance of corruption. be improperly changed and shall correctly
Intertek’s Anti-Bribery Guidance, including present the actual findings, professional
Gifts, Hospitality and Entertaining policy, opinions or results obtained. The falsifying
is available from your line manager or at or manipulation of evaluations, testing
Intertek.com/investors/governance. processes, quality assurance surveys and
reports, will not be tolerated and will lead to
Integrity disciplinary action including dismissal.
Intertek expects all its employees, sub-
contractors, agents and intermediaries to Intertek also expects all employees and
carry out any work for and on behalf of subcontractors, agents and intermediaries
Intertek in accordance with and respecting to be properly qualified to carry out their
all countries’ laws and internal Intertek work for the Company. Falsification or
Policies. Criminal violations committed in misrepresentation of qualifications by
the course of undertaking Intertek business employees will result in disciplinary action,
is unacceptable, and will result in the including dismissal; sub-contractors, agents
termination of the employees’ employment and intermediaries may have their contracts
or sub-contractors, agents or intermediaries’ with Intertek terminated.
OUR COMMITMENT TO INTEGRITY
Bribery and Corruption These rules do not just apply to Intertek
Intertek does not tolerate or engage in employees, but also to contractors, agents
bribery or corruption in any form, in any of or anyone else acting on behalf of Intertek.
the countries in which it operates. Bribery is They must not offer, make or receive any
the offering, giving, receiving or requesting bribes during the course of doing business
of any item(s) of value to another person, in order to gain a business advantage or
directly or indirectly, to induce that person to favourable treatment. Using third parties to
act improperly or to reward them for improper indirectly pay bribes would also be unlawful
performance. Improper performance is and lead to liability for you and Intertek.
performance that breaches expectations of
good faith, impartiality or obligations of trust.
In a business context, a bribe can be an
Example
inducement or reward offered, promised, given Employing a contractor or agent to provide
or received to obtain or retain a business money, gifts or hospitality to third parties or
advantage. It applies to both private corruption public officials to win their business would
(i.e. bribery of persons working in other amount to bribery.
commercial organisations)
and public corruption (i.e. bribery of domestic You might be told that making certain
or foreign government officials). types of payments or gifts “is how business
Please be aware that government officials in is done” in a certain country but it is
some countries could include employees of nevertheless against our Code of Ethics. If
some companies if those entities are owned anybody within or outside Intertek asks you
or partially owned by a government. They to pay or receive a bribe, you must refuse
can also include doctors and other medical and immediately report such conduct to your
professionals in many countries. Particular care line manager or your Regional Compliance
must be taken when dealing with government Officer.
officials and their family and close associates, If you are involved in bribery or corruption in
and you should ensure that your conduct does any form you will be subject to disciplinary
not amount to, or is perceived to amount to, action and dismissal, and you could well face
a bribe. legal and criminal proceedings and even
imprisonment. Please note that your actions
may also result in both civil and criminal
Example liability for Intertek.
Offering or paying money to a client who is Conflicts of Interest
tendering for business or to a public official A conflict of interest arises when an
as part of a public procurement process to employee’s personal relationships, external
win a contract could amount to a bribe. interests or activities could interfere with
their judgment, objectivity, independence or
A bribe also includes ‘facilitation’ or ‘grease’ loyalty to Intertek. We require employees to
payments which are payments to expedite or avoid conflicts of interest, or the appearance
secure performance of a routine governmental of one, at all times, to ensure the quality of
action. Alternatively, think of it as paying a our business decisions and the integrity of
public official extra for simply doing their job. the person and Company.
Such payments are not acceptable, and are Conflicts of interest can arise in many ways.
illegal in many countries. The only exception Examples of unacceptable conduct include:
to this rule is if your health, safety, or life is in • Committing Intertek to conduct any
imminent danger. In such an emergency, you company business with a member of
must comply with Intertek’s Anti-Bribery Policy their direct family or relationship partner
and try to speak to either your line manager, without higher approval. Where any
or your Regional Compliance Officer to get Intertek employee wishes to commit
approval before making the payment. If you Intertek to conduct such business, then
cannot, because of the immediate pressure a request must be made for approval by
you are under, then you must immediately the relevant Executive Vice President
report the payment to your line manager or (EVP) or Group functional head. Any such
Regional Compliance Officer as soon as you request must clearly state the reasons
are in a position to do so. for the proposal to award work to a
related party. Existing arrangements will
be allowed to continue, and are covered
Example by the requirement to declare related
Paying a public official a small amount of party transactions for EVP approval at
money to process your VISA application year end (see below);
more quickly could amount to a bribe.
7
OUR CODE OF ETHICS
• Directly or through relatives, friends or hospitality should be made to a government • Group CEO approval for individual
intermediaries, acquire an interest in official or their partner, family or close donations of between £5,001 to
a supplier, a client or a competitor of associates without the express approval of £10,000, and maximum cumulative value
Intertek, except for the acquisition of Intertek’s Group Head of Legal. of up to £50,000 per annum for the
shares of a client, supplier or competitor Group; and
on a public stock exchange, unless • Group Board approval for donations over
limited to an extent which does not grant Example £10,001.
significant influence over the affairs of Taking a client or public official out to lunch
Once individual donations are over £10,001,
the client, supplier or competitor and during a competitive tender process could be
or cumulative donations have reached over
which does not make the employee perceived to be or could amount to a bribe.
£50,001, such contributions are subject
unduly dependent on its financial Providing a public official with free travel to additional due diligence by Regional
fortunes or be subject to any potential and accommodation in order to win or retain Compliance Officers.
undue influence of the client, supplier or business could amount to a bribe.
competitor; No contributions are permitted that may be
used to create an improper advantage for
• Hold any position (such as an employee,
Reasonable and proportionate hospitality Intertek or amount to, or be perceived to,
officer, director, trustee or advisor) with a
and promotional, or other business amount to a bribe.
competitor or client;
expenditure which seeks to improve Insider Dealing
• Authorise or take any part in the the image of Intertek, or to present its
recruitment process of members of their Insider dealing is where any confidential,
products and services, or establish cordial pricesensitive knowledge and data is used
direct family or relationship partner. This relations, is recognised as an established
applies to new hires only. In the case of to provide an unfair advantage when buying
part of doing business and would not and selling shares of a publicly traded
existing family members already working amount to a bribe. Gifts and hospitality
for Intertek, and in the case of any staff company (which includes Intertek). Some
with commercial (private) business Intertek employees will have access to
joining Intertek through acquisition, then partners are acceptable, provided you
this clause does not apply; and inside information which could be used for
comply with Intertek’s Gifts, Hospitality inappropriate personal gain; for example,
• Trade in Intertek shares in violation of and Entertaining policy (as contained purchasing shares based on non-public
any laws, regulations or Intertek policies in Intertek’s Anti-Bribery Policy), which information. Intertek is firmly committed
governing the purchase or sale of such explains the limits on spending, approval to supporting fair and open trading of
shares. Employees must declare their processes and other requirements. All gifts securities and Intertek employees are
interest to Intertek’s Group Company and entertainment expenses must be prohibited from dealing in shares based on
Secretary as soon as they become aware properly documented. inside information.
that their personal interests conflict with Intertek’s business decisions must never
those of Intertek. Protecting the interest It is a criminal offence to deal in Intertek
be influenced by gifts or hospitality. shares (or other company shares) on the
of relatives or friends may potentially Intertek employees may not accept gifts
conflict with the interests of Intertek. basis of inside information or to help
in connection with their employment somebody else to do so. Insider dealing is
You must abstain from a decision-making or Intertek business unless permission
process if you have a conflict of interest unlawful and will lead to disciplinary action,
is received from their line manager and including dismissal, and could ultimately
or you might be perceived to have one, Regional Compliance Officer in accordance
unless you obtain the prior consent result in legal or criminal proceedings
with the Gifts, Hospitality and Entertaining including imprisonment. Intertek’s position
of your line manager and Regional policy as contained in Intertek’s Anti-
Compliance Officer. is reinforced by clear internal guidelines on
Bribery Policy, and documented. share dealing.
Where Intertek employees wish to Political and Charitable Contributions
participate in political activities for the As an organisation we seek to maintain
benefit of society, such as taking on a role political neutrality and do not fund political
in public office, then prior approval will be or religious processes, individuals or
required from their line manager or Regional organisations. This principle applies also to
Compliance Officer, if there is a conflict our employees, intermediaries and agents
of interest between that role and their in the course of their employment with
employment with Intertek. Intertek.
Gifts and Hospitality We require that any charitable contributions
Anything of value such as gifts, hospitality, or sponsorships are given appropriately
loans, fees and charitable or political and do not create, or might be perceived to
donations, can amount to a bribe. This create, an improper advantage for Intertek,
can include paying school fees, travel and conflicts of interest or indirectly support
accommodation expenses and providing political or religious processes. Charitable
credit to third parties to win or retain contributions require the prior approval
business. of management in accordance with the
Gifts and hospitality should never be used following limits:
to induce or influence improper behaviour. • EVP approval for individual donations of
Particular caution should be taken when up to £5,000, and maximum cumulative
dealing with government officials. It is value of up to £25,000 per annum;
Intertek’s policy that no offer of gifts and/or
8
OUR COMMITMENT TO INTEGRITY
Our commitment to integrity - what Intertek
expects of you
• Carry out all work in an independent and impartial manner, in accordance with local and
international laws.
• Never falsify or misrepresent your own qualifications, or manipulate reports or test results
in the course of conducting Intertek business.
• Do not offer money, gifts or hospitality indirectly or directly to influence (or which may
appear to influence) a business decision.
• Do not offer payments, gifts or hospitality to government officials without the express
approval of Intertek’s Group Head of Legal.
• Ensure any gift or hospitality complies with Intertek’s Gifts, Hospitality and Entertaining
policy, never exceeds the prescribed value limit and is properly documented.
• Do not use third parties to pay bribes to win business.
• You should not be involved in business decisions where you have (or might be perceived to
have) a conflict of interest.
• You should not be involved in decisions involving the recruiting, managing or appraising of
a friend or relative without prior approval from your line manager or Regional Compliance
Officer.
• You should not, on behalf of Intertek, contract with businesses in which your friends or
family are involved, without obtaining the prior approval of your line manager and Regional
Compliance Officer.
• Do not spread rumours or false information about companies, mislead the financial market
or seek to manipulate share prices in any way.
• Do not make a donation to a political or religious organisation on behalf of Intertek.
• Always seek the necessary approvals as set out in this Code before making a charitable
contribution.
• Do not make a charitable contribution because you are seeking to win or retain business.
• You should not use confidential information you have obtained through your employment
with Intertek for personal gain.
• Do not buy or sell shares in Intertek or in any other company if you have non-public or
confidential information about those shares.
• Report any breaches of the above to your line manager, your Regional Compliance Officer or
via the Intertek Global Hotline.
9
OUR CODE OF ETHICS
OUR RELATIONSHIP WITH
CUSTOMERS, PARTNERS AND
THE MARKETPLACE
Working with our Customers We conduct thorough independent transferring goods, technology, software or
We are committed to supporting the needs investigations of intermediaries before services across international borders. If you
of our customers and helping to add value engaging with them and have processes in are in doubt as to whether you are acting
to their business. At all times we ensure place to ensure that improper payments are in compliance with the law, you must ask
that we work together in a fair and honest not channelled through intermediaries. We a Regional Compliance Officer of Intertek
manner and in a way that upholds Intertek’s provide all intermediaries with a copy of our or the Group Head of Legal for advice.
commitment to good ethics. Code of Ethics and require them to commit Intertek will provide accurate and truthful
We avoid dealing with customers which we to those principles. information to customs authorities.
know to be involved in bribery and conduct Where appropriate, we provide training for You must be aware of boycotts or sanctions
due diligence when evaluating major agents, intermediaries and sub-contractors concerning countries where we operate
prospective customers. The appropriateness on our ethical requirements and will monitor or might operate. A boycott is where
and extent of due diligence shall be their compliance with our Code of Ethics. one country refuses to do business with
determined by risk analysis, in accordance Fair Marketing and Anti-Trust another and prohibits others from doing so.
with Intertek’s due diligence policy when Sanctions are coercive measures adopted
Competition
dealing with intermediaries (as contained by a country or group of countries, such as
Across the many countries Intertek
within Intertek’s Anti-Bribery Policy). Where the United Nations or European Union, taken
operates in, we are committed to acting and
possible, our agreements with customers against another state or individual(s) in order
competing in a fair and open manner in the
allow us to terminate the agreement should to produce a change in their behaviour. If
marketplace. As such, we strive to present
it create a breach of our Code of Ethics. you become aware of sanctions or boycotts
the Company accurately and avoid marketing
We make our Code of Ethics available to involving countries or individuals with whom
our services in a way that is misleading.
all customers so that they understand you do business, you must immediately seek
In accordance with fair market practices, legal advice from a Regional Compliance
the principles with which we operate, and we do not engage in discussions regarding
are transparent and responsive to our Officer or the Group Head of Legal.
pricing, contractual terms, market allocations,
customers’ requests for information to Failure to comply with export, import
division of territories or customers, or
verify Intertek’s corporate, ethical and social or trade controls could lead to civil
discuss competitive bid processes with
responsibility credentials. and criminal sanctions for you and the
competitors. Intertek does not engage in
Partners, Contractors, Agents, Company, including substantial fines. You
any understanding or agreements with
could also face disciplinary proceedings
Intermediaries and Suppliers competitors with the effect of biasing or
including dismissal, and potential
We reinforce our Code of Ethics with our improperly influencing the markets in which
imprisonment if criminal proceedings are
partners who include contractors, sub- it operates. Anticompetitive practices are
brought against you.
contractors, correspondents, agents, unacceptable. Intertek and its employees
intermediaries and suppliers. We conduct will not agree to fix price, or any elements of
due diligence on prospective partners, in price, with its competitors.
accordance with Intertek’s due diligence Price-fixing and bid-rigging are illegal.
policy when dealing with intermediaries, Involvement in such conduct will lead to
so that we appoint on merit, do not deal disciplinary action including dismissal, and
with those known to be involved in bribery could lead to legal or criminal proceedings,
and ensure that our relationship with them including imprisonment. It may also impose
follows the principles of our Code of Ethics. liability on Intertek leading to significant
All our business partners have access to our financial penalties.
Code of Ethics. Certain business partners,
such as agents and sub-contractors, are
Export, Import and Trade Controls
Intertek will comply with all applicable laws
given a copy of our Code of Ethics and are
concerning imports, exports and customs.
required to commit to those principles. Our
contractual terms allow us to terminate You must carefully consider and understand
our relationships with those partners who whether you are complying with applicable
breach our Code of Ethics. import, export or customs laws before
10
OUR RELATIONSHIP WITH CUSTOMERS, PARTNERS AND THE MARKETPLACE
Our relationship with customers, partners and the
marketplace - what Intertek expects of you
• Do not reach agreements either formally or informally with competitors over matters such
as pricing or elements of pricing (such as discounts or rebates), bid processes, whether to
compete in certain markets or pitch for certain customers’ business.
• Do not discuss confidential or commercially sensitive information with competitors.
• Do not use confidential information obtained from your previous employment for the
benefit of Intertek.
• Be aware of, and comply with, all applicable export/import and customs laws.
• Be aware of boycotts or sanctions concerning countries where we operate.
• Report any breaches of the above to your line manager, your Regional Compliance Officer or
via the Intertek Global Hotline.
11
OUR CODE OF ETHICS
OUR OBLIGATION TO PROTECT
OUR ASSETS, CONFIDENTIAL
INFORMATION, SHAREHOLDERS
AND REPUTATION
Protecting our Assets and Resources Policy with which all employees must comply. made by authorised personnel. If you are
We recognise the value of the ideas, The disclosure of Intertek’s confidential authorised to make public disclosures about
services, business processes and strategies information, except for its intended purpose, Intertek, you must ensure such information is
that Intertek generates. These help could damage the Company’s reputation and true, accurate and not misleading. Inaccurate
to differentiate us in the marketplace. affect its share price and thus cause harm to or misleading information made public could
Therefore, we strive to protect our own our shareholders. seriously damage Intertek’s reputation and
intellectual property and respect the Employees remain bound by these business, and may result in civil, criminal or
intellectual property of others. confidentiality obligations after leaving regulatory sanctions against the Company
Employees must not disclose, copy or use Intertek’s employment. We seek to protect and yourself as well as disciplinary action,
Intertek’s intellectual property except for its the confidentiality of Company, employee including dismissal.
intended purpose, and must apply the same and customer information. Personal opinions, with regard to religion,
degree of care when being exposed to our Our Shareholders politics or objectionable content, cannot
customers’ intellectual property. We manage our relationships with our be expressed in any manner where it could
Employees must use and protect Company shareholders in accordance with best appear to be attributable to Intertek. We
assets and resources under their control and corporate governance standards. We have have clear guidelines for employees on the
may not use these for personal benefit or to established channels with our shareholders use of social media and external forums and
perform work for an external party. through which we have open dialogue the possible disciplinary consequences.
Intertek respects third party intellectual and actively seek their feedback on our
property. Using unlicensed software, using objectives, strategy and performance
or reproducing copyrighted materials without throughout the year.
authorisation or knowingly breaching a valid Intertek Group plc is listed on the London
patent is prohibited. It could lead to civil Stock Exchange and is bound by disclosure
proceedings being brought against Intertek. obligations to the market. We seek to make
If you infringe third party intellectual all our communications precise, accurate and
property rights you could face disciplinary transparent to our shareholders, investors,
action, including dismissal. the market and other stakeholders.
Confidentiality Public and External Communications
Our employees are required to maintain the Employees are not permitted to speak on
confidentiality of Intertek and customer behalf of Intertek or disclose any information
information and the personal data of regarding Intertek to the media, financial
colleagues. community or public on behalf of the
Sensitive and confidential information Company without specific authority to do so.
includes, but is not limited to, information Our employees are required not to disclose
that is not publicly available, is used, or discuss any sensitive or confidential
controlled or owned by Intertek and information relating to Intertek’s financial
concerns Intertek’s technology, business, performance or business outside of work.
products, services and finances. Confidential Insider dealing, as explained on page 8, is not
information also includes, but is not limited tolerated by Intertek.
to, information that is not publicly available Because Intertek Group plc is a publicly listed
about Intertek’s staff, customers, suppliers, company on the London Stock Exchange,
distributors, agents, joint venture partners it is legally obliged to make certain public
and shareholders. disclosures about its financial performance
Intertek complies with data protection and and business. External communications
privacy laws in the countries in which it by employees need to follow Intertek’s
operates and has a Global Data Protection corporate guidelines and can only be
12
OUR OBLIGATION TO PROTECT OUR ASSETS, CONFIDENTIAL INFORMATION, SHAREHOLDERS AND REPUTATION
Our obligation to protect our assets, confidential
information, shareholders and reputation - what Intertek
expects of you
• Do not speak to the media, financial community or the public on behalf of Intertek unless
you have permission to do so.
• Any authorised communications made on behalf of Intertek must be true, accurate and not
misleading.
• Do not misuse somebody else’s personal or confidential information or intellectual property.
• Protect Intertek’s confidential or sensitive information, and assets and resources.
• Do comply with local data protection and privacy laws.
• Report any breaches of the above to your line manager, your Regional Compliance Officer or
via the Intertek Global Hotline.
13
OUR CODE OF ETHICS
SEEKING GUIDANCE
AND REPORTING
CONCERNS OR
BREACHES OF THE
INTERTEK CODE OF
ETHICS
If you have any doubts about the meaning We encourage you to report your concerns
of Intertek’s Code of Ethics, are concerned before a possible breach of the Code occurs
about whether somebody has contravened and you should never cover up wrong-doing
it, or you become aware of, or suspect a or ignore those concerns. Turning a blind eye
violation of the Code, you are encouraged to a problem can makes things worse.
to contact either your line manager or your Whilst all information you provide will
Regional Compliance Officer. be kept confidential, you may prefer to
If you are uncomfortable raising any make contact initially on an anonymous
concerns or queries, or reporting breaches basis. In such a case, we would then need
or possible breaches of the Code to your to work with you to develop a means of
line manager or Regional Compliance officer, communication that enables us to provide
you can instead contact the Intertek Global you with feedback and/or to ask further
Hotline which is operated by an independent questions about your query or concern,
third party contractor. Details of the regional if required. However, Intertek would
Hotline phone numbers can be found on the discourage you from voicing your concerns
Group intranet and on the Company website anonymously, as this would make it more
and displayed in all Intertek office locations. difficult to investigate or answer any query;
For on-line direct reporting of a compliance and there would be less chance of you being
breach, go to www.intertekhotline.com. able to avail yourself of certain protections
Employees should note that this Code provided by law if needed.
of Ethics and the approval and reporting Any allegations concerning breaches of the
procedures referred to throughout are not Code will be investigated quickly and fairly
a substitute for but should be followed in by the Company. Details of the investigation
tandem with the formal Human Resources will be kept confidential and only shared on
procedures when dealing with employment a strict need-to-know basis, unless we are
issues as available from HR and set out on legally obliged to provide details as part of
the intranet. a criminal or regulatory investigation or civil
Customers, agents, contractors, or third proceedings.
parties who are aware of or suspect any Intertek appreciates that reporting concerns
breaches of the Code, or have any questions or wrong-doing is not an easy decision. But
about it, should contact Intertek’s Group please rest assured, you will not face any
Head of Legal at either of the following: repercussions for raising concerns or wrong-
doing that you believe are in the best
interests of the Company to know about.
We guarantee that you will be provided
Telephone : +44 20 7396 3400
with the full protection and support of the
Company for acting correctly, and in the
Post: Intertek Group plc
event that anyone harasses or treats you
33 Cavendish Square
unfairly because of your actions, those
London, W1G 0PS
individuals will face disciplinary action,
UK
including dismissal.
14
SEEKING GUIDANCE AND REPORTING CONCERNS OR BREACHES OF THE INTERTEK CODE OF ETHICS
When Intertek expects you to speak out
• If you witness or are aware of unsafe working practices.
• If you witness or are aware of inefficient provisions of services and products that may damage
the environment.
• If you believe a work colleague is under the influence of alcohol or illegal drugs at work.
• If you suspect, witness or are aware of a work colleague being intimidated, harassed,
discriminated against or subject to other inappropriate treatment in breach of this Code.
• If you become aware that Intertek is using child labour or is complicit in any human
rights violations.
• If you are unsure about any aspect of Intertek’s Anti-Bribery Policy or the anti-bribery laws
where you are doing business.
• If you suspect or become aware of corruption or bribery as a result of any aspect of your work.
• If you suspect or are aware that Intertek or anybody associated with Intertek is
acting unlawfully.
• If you are unsure about any aspect of Intertek’s Anti-Bribery Policy in relation to gifts
and hospitality.
• If you are concerned that your conduct or somebody else’s conduct might be perceived as a
breach of this Code.
• If you suspect or become aware of corruption or bribery as a result of any aspect of your work.
• If you feel any matter might result in a conflict of interests that might influence or be perceived
to influence your decisions at Intertek.
• If you suspect or become aware that an Intertek employee has or may be perceived to have a
conflict of interests.
• If you suspect or become aware that an Intertek employee has been involved in insider dealing
or has misused confidential information.
• If you suspect or become aware of the fact that an Intertek employee has made a donation to
a political or religious organisation on behalf of Intertek.
• If you suspect or become aware of the fact that an Intertek employee has made a charitable
donation on behalf of Intertek without the necessary prior approvals.
• If you believe Intertek is involved in or might be involved in anti-competitive practices or are
unsure whether Intertek is engaged in such behaviour.
• If you believe an Intertek employee is (mis)using confidential information belonging to
a competitor.
• If you become aware of Intertek’s confidential or sensitive information being misused
by or disclosed to third parties (outside a legitimate purpose), or personal information is
being misused.
• If you suspect or become aware of unauthorised, inappropriate or unlawful communications.
• If you suspect or become aware of behaviour that might harm the Company’s reputation
or financially.
• Before entering into any business relationship with businesses in which your friends and/or
relatives are involved and you should seek approval, in any event before doing so from your line
manager or Regional Compliance Officer.
• Report any breaches of the above to your line manager, your Regional Compliance Officer or via
the Intertek Global Hotline.
We guarantee that you will be provided with the full protection and support of the
Company for acting correctly.
15
ITK-COE-v1.2_15062017
Intertek Group plc Documents referenced in the Intertek Code of Ethics:
33 Cavendish Square • Anti-Bribery Policy
London
• Environmental Policy
W1G 0PS
UK • Guide to Social Media Use
• Health & Safety Policy
• Inclusion & Diversity Policy
+44 20 7396 3400 • Labour & Human Rights Policy
intertek.com/ethics The above can be obtained from the Intertek Group intranet and are
available upon request.