Saville Assessment Code of Conduct
Letter to colleagues
At Saville Assessment, our values inform what we aspire to and how, collectively, we act to make these aspirations a reality. We are Professional in how we deliver our solutions and services to our clients: We value People, collaborating and communicating actively and with respect to others. We are Pioneering and seek progress for our business, growing through drive, innovation and incremental improvement.
That's why our Code of Conduct ("Code"), is so important. It guides all we do and details the behaviors each of us is expected to model making Saville Assessment the best company we can be for the benefit of all our stakeholders.
We encourage you to read and reflect on the Code, even if certain sections may not apply to your role. If you have questions, or if ever you need to report a Code violation, please speak with your manager or use one of the other resources listed in this document; they are available to help you.
By following the provisions of the Code, we demonstrate to our clients, colleagues, shareholders and communities that we take pride in doing business with our values as our foundation.
The Code on a Page
- Our company is in business to provide the best services and solutions to our clients. That's our purpose and it's what your job is all about here, directly or indirectly.
- Always operate with honesty, integrity, and fairness in everything you do.
- We operate completely above-board all of the time. No bribes, no kickbacks, no winks, no nods, no verbal sleight-of-hand, no under-the-table dealings. It's simple. Just think about whether you'd be comfortable explaining your actions to the entire world on the front page of a global newspaper. If you're in doubt, reach out to your manager, human resources or a member of the management team and talk about the situation. All of those people are there to help you do the right thing.
- In all of our dealings with people, business partners and third parties (including suppliers), we insist that they also operate with honesty, integrity and fairness and operate completely above-board. Their behavior in working with us and on our behalf reflects on us.
- Do you have a confidentiality or non-compete agreement with a former employer? Honour it. That's part of your integrity.
- In the marketplace, we talk about the value we deliver to meet client needs, not disparagingly about our competitors.
- If you see something, say something. Speak up to your manager, human resources or a member of the management team. We don't tolerate retaliation, so provided you report something in good faith, regardless of whether it turns out to be an issue, you will be protected.
- You'll deal with a lot of private and confidential information here. Keep it private and confidential. Only share confidential information on a need-to-know basis, even inside the company. That includes information about your fellow colleagues and our clients.
- We provide objective, unbiased advice to our clients. That's one of the reasons they hire us. A conflict of interest is any situation where we are involved in multiple interests, one of which might call our objectivity into question with regard to another. A conflict of interest, or even the appearance of a conflict of interest, can cause you and the company big problems. If you think you, or the company in a particular situation, have a conflict of interest, human resources or a member of the management team. They will help you deal with it.
- Insider trading is trading in financial securities on the basis of material, non-public information. It is also against the law. You may have access to inside information of Saville Assessment or of a client during the course of your work here. Don't trade on that information. And don't give it to your family, or your friends, or anyone else outside of Saville Assessment without authorisation.
- We comply with the laws in the countries where we operate, international laws such as sanctions and export control legislation, our Code and our policies supporting the Code. It's part of your job here to know them and follow them. If you have questions about any of them, talk to your manager, human resources or a member of the management team. They'll guide you in the right direction.
Table of Contents
- 1. Introduction: The Saville Assessment Code
- 1.1 Why We Have a Code
- 1.2 Who Must Follow the Code?
- 1.3 Our Responsibilities Under the Code
- 1.4 Complying with Laws and Regulations
- 1.5 Additional Information
- 2. The Saville Assessment Values
- 3. The Importance of Speaking Up
- 3.1 Where (and When) to Ask Questions and Discuss Concerns
- 3.2 Investigations and Consequences of Misconduct
- 3.3 Saville Assessment's Non-Retaliation Commitment
- 4. Doing the Right Thing for Our Clients and Partners
- 4.1 Quality Service and Solutions
- 4.2 Fair Sales and Marketing Practices
- 4.3 Complaints
- 4.4 Global Competition Laws
- 4.5 Competitive Information About Others
- 4.6 Regulated Business
- 4.7 Unauthorised Practice of Law
- 4.8 Intellectual Property and Copyright
- 5. Doing the Right Thing for Our Fellow Colleagues
- 5.1 Inclusion and Diversity at Saville Assessment
- 5.2 Workplace Health, Safety, and Security
- 6. Doing the Right Thing for Our Company
- 6.1 Conflicts of Interest
- 6.2 Giving and Accepting Business Gifts, Events/Entertainment and Hospitality
- 6.3 Anti-Bribery and Corruption Guidelines
- 6.4 Sanctions, Trade Restrictions and Export Controls
- 6.5 Money Laundering and Counter-Terrorist Financing
- 6.6 Tax Evasion Anti-Facilitation
- 6.7 Company Assets and Information
- 6.8 Social Media
- 7. Doing the Right Thing for Our Shareholders
- 7.1 Accurate Books and Records
- 7.2 Inside Information and Securities Trading
- 7.3 Audits and Investigations
- 7.4 Handling External Inquiries
- 8. Doing the Right Thing for Our Communities
- 8.1 Participation in Our Communities
- 8.2 Combating Human Rights Violations of Slavery and Human Trafficking
- 9. Exemptions and Waivers
- 10. Code or Policy Queries
- 11. Acknowledgment
- About Saville Assessment
1. Introduction: The Saville Assessment Code
1.1 Why We Have a Code
Our Code is a guide and reference for Saville Assessment colleagues to support day-to-day decision making. It is also a tool to encourage discussions of ethics and to improve how we deal with the ethical dilemmas and grey areas that are encountered in our everyday work. References to "colleagues" throughout this Code should be read as inclusive of all directors and colleagues of Saville Assessment. Saville Assessment Ltd, together with all of our subsidiaries and affiliates, is referred to collectively as Saville Assessment or the "company".
Our Code is meant to complement our existing standards, policies and rules, not to substitute for them, and so it contains references to company policies and procedures. These policies and procedures are accessible to all colleagues in the Saville Assessment SharePoint folders. Our company will continue to create and update policies as needed. As individuals, we are each responsible for reviewing and complying with these.
1.2 Who Must Follow the Code?
Our Code applies to all members of the Saville Assessment community. That means that all Saville Assessment colleagues, as defined above, must comply with its provisions. In addition, all others working with Saville Assessment, such as contractors, temporary workers, third parties, agents and suppliers must comply with the principals contained in the Code.
1.3 Our Responsibilities Under the Code
At Saville Assessment, we are committed to conducting our business with honesty, integrity and fairness, no matter where we operate. Therefore, each of us must review the Code on a regular basis and incorporate its standards into our daily work. We must also remain alert to conduct that may conflict with the Code, as well as situations that may lead to illegal, unethical or inappropriate conduct. If you observe possible violations, you have a responsibility to report what you know.
Those in management positions at Saville Assessment have additional responsibilities for ensuring ethical conduct. If you are a manager, you should lead by example, using your own behaviour as a model for other colleagues. You are expected to foster a culture of Compliance and be alert to actual or potential violations of the Code, company policies or the law.
Managers should also encourage open and honest communication. Being a manager at Saville Assessment means taking action when ethical issues are brought to your attention and supporting colleagues who raise concerns in good faith. In carrying out these responsibilities, managers should feel free to seek advice from the management team.
1.4 Complying with Laws and Regulations
Saville Assessment will conduct its business in accordance with the applicable laws and regulations of the countries where the company does business. As appropriate, the company will report criminal violations to the appropriate authorities for possible prosecution and will investigate and address, as appropriate, non-criminal violations.
This Code cannot describe all the laws of every country in which we operate. We are each, however, responsible for complying with the laws of the countries where we conduct business. When there is any doubt about the legality of a matter, you should refer to the Code or other policies, or contact a member of the management team.
In addition, Saville Assessment is responsible for providing full, fair, accurate, timely and understandable disclosure in reports and documents it files with, or submits to, regulatory bodies and in other public communications.
1.5 Additional Information
Please note that our Code is not a promise of continued employment or service. It may be modified and changed at any time by Saville Assessment at the company's sole discretion. Where local country laws contain mandatory requirements that differ from the provisions of our Code, those requirements will prevail for colleagues working in those countries.
2. The Saville Assessment Values
There are three key values that come from our research and they shape the way we do business as Saville Assessment. They are:
- Professional - we maintain the highest standards in our assessments, technology and our delivery, ensuring highly-scalable assessment solutions are available to our clients in their assessment applications (Hire, Build and Lead). We act with integrity and lead the assessment industry with high-quality psychometrics that provide our clients with solutions which improve their talent management outcomes; we underpin our assessments with excellent science.
- People - we work together to provide the right solutions for our clients and each other, we listen, we are responsive and we show support, respect and consideration to others. We communicate well with each other, our investors, stakeholders and most of all with our clients. We show expertise and pragmatism.
- Pioneering - we push to grow our business and create impact through ambition. We challenge ourselves, look for new opportunities and better ways of working. We explore, change, innovate and improve and we provide new upgraded assessment solutions and technology that meets our clients' changing needs.
Ethical Decision-Making Model
This Code provides an outline of general requirements imposed by applicable laws and prudent business principles and sets certain standards of conduct to which you are expected to adhere. It does not cover every possible situation or set of circumstances you may face in your career at the company.
You should use good judgement in every situation and apply the principles and policies underlying this Code to all of your activities. The Ethical Decision-Making Model provides a framework that includes three inquiries to guide the exercise of your judgement.
3. The Importance of Speaking Up
3.1 Where (and When) to Ask Questions and Discuss Concerns
If you have a question about the Code, company policy or the law, always seek guidance. There are a number of resources available to assist you. Feel free to contact any of the following resources with questions, concerns or reports:
- Your manager
- Human Resources
- A member of the management team
If you observe possible violations of the Code, company policy, or applicable law, you have a responsibility to report it to one of the resources listed above.
Efforts will be made to maintain confidentiality, as consistent with Saville Assessment's strong policy in this area.
3.2 Investigations and Consequences of Misconduct
Our company will review and respond to all reports. Where appropriate, reports will be referred to the management team, and an investigation will be conducted under its direction to ensure an independent process pursuant to our investigation protocols. If the company determines that an individual has violated our policies or the Code, it will take appropriate action which, in serious cases, could lead to termination of employment (for company officers and colleagues). Depending on the extent of any violation, Saville Assessment may take other appropriate measures, including initiating legal action or notifying governmental authorities and regulators.
If you are asked to provide documents (including electronic documents) or testimony as a witness during any internal investigation, you are required to cooperate. A colleague who fails to comply with a reasonable request for information during an investigation is subject to appropriate disciplinary action, up to and including termination of employment.
3.3 Saville Assessment's Non-Retaliation Commitment
Please keep in mind that Saville Assessment will not tolerate retaliation against anyone who, in good faith, reports a violation of company policy or the Code. Anyone who does so is subject to appropriate disciplinary action, up to and including termination of employment. Making a report in good faith means you have reasonable grounds for believing that the information provided indicates that a violation of Saville Assessment policy or the law has occurred, is occurring, or may occur in the future. A colleague may be disciplined up to and including the termination of their employment for a report that is not made in good faith.
If you report about a matter where you yourself may have committed a violation, your report will not eliminate the potential for internal disciplinary proceedings against you in relation to that violation, although the company will take into account the fact that you have voluntarily raised the matter in any actions that may follow.
4. Doing the Right Thing for Our Clients and Partners
4.1 Quality Service and Solutions
Our reputation depends on the integrity of our people and the quality of our services and solutions. That is why we are honest in presenting our skills and capabilities in proposals. We use our best efforts in delivering on our commitments. Each of us is individually responsible for the quality of our professional services. Where required, we are also responsible as individuals for maintaining relevant professional credentials and licenses.
4.2 Fair Sales and Marketing Practices
At Saville Assessment, we compete aggressively to be a leader in our global market. However, we must not violate the law or make statements that might harm our reputation for integrity and fair dealing. We are all responsible for conducting ourselves and our business in a fair, ethical and legal manner.
It's our responsibility to make sure that the information we share with clients and prospects about our solutions and services is fair, factual and complete. We must not make deceptive or misleading statements in order to win or maintain business. We must provide objective and impartial advice in the interests of our clients.
Likewise, we must not make false or misleading statements about the services and solutions of a competitor. We win business with integrity, not by putting down our competitors.
We should use reasonable endeavours to obtain from new clients and prospects the information we need to understand their needs and requirements and ensure that they are made fully aware of the extent of any role Saville Assessment will take in any transaction, including Saville Assessment's and the client's obligations both to each other and to other parties involved.
Information provided to our clients must be done so in a timely and comprehensive manner, enabling clients to take balanced and informed decisions.
At Saville Assessment we do everything we can to ensure our clients receive the service that represents their best interest. However, we recognise that sometimes our services may not meet expectations. Therefore, we have adopted complaints procedures and colleagues are required to follow such procedures so that clients' complaints can be dealt with properly.
4.4 Global Competition Laws
To compete lawfully and with integrity, we must also observe competition, trade regulation and antitrust laws. If you violate these laws, both you and Saville Assessment may face civil and criminal liability, including severe fines and imprisonment.
While competition laws can be complex, they generally forbid entering into agreements with competitors that may restrain trade, such as price fixing, bid rigging or dividing or allocating markets, territories or customers. Keep in mind that agreements can be formal or informal, even a handshake or a note on a cocktail napkin about these matters could be considered an improper agreement. In particular, you must always avoid the following topics of discussion and prohibited agreements when interacting with competitors:
- Pricing, including terms and conditions of service
- Responses to requests for proposals or bids
- Specifics of the company's agreements with any client
- Dividing or allocating markets, including the allocation of particular clients or geographic areas
Competition laws also generally prohibit entering into formal or informal agreements with suppliers or customers that may restrict competition. In particular, you may never:
- agree to boycott a client or supplier
- assist a client in entering into any anticompetitive exchange or agreement
- agree with any client or third party that redistributes any Saville Assessment products or services to charge a minimum price or to set a maximum discount
- agree with a client that Saville Assessment will not accept assignments from the client's competitors, without first consulting with the management team
- provide Saville Assessment services to clients with any conditions that the client will not do business with a Saville Assessment competitor, without first consulting with the management team.
Additionally, you should not make a purchase from a vendor conditional on the vendor's engagement of Saville Assessment to provide services without first consulting the management team.
4.5 Competitive Information About Others
In addition, you must take special care when participating in industry groups or professional or trade associations that include competitors. In these situations, you must avoid making any statements or taking any actions that could violate or appear to violate antitrust laws.
Gathering information about the marketplace, including information about our competitors and their services, is proper and permissible if we obtain and use such information lawfully. You are expected to respect other companies' information that is confidential or proprietary. You should never request or use another party's proprietary or confidential information without explicit permission.
If you are offered confidential or proprietary information that you believe may have been obtained improperly, you must immediately inform your manager or the management team. This is especially important for Saville Assessment colleagues who were formerly employed by a competitor.
Certain types of confidential information, including U.S. federal government "source selection" information, must be kept confidential under U.S. federal procurement integrity laws. Colleagues involved in U.S. federal procurements are expected to know and comply with requirements governing access to such information. Similar laws and regulations may apply to work with governmental agencies of other countries. You should consult with the management team if you have questions about whether information is subject to these laws or for advice about these situations.
If you are asked to sign a confidentiality agreement or third-party release to obtain information from a third party, you must contact a member of the management team. You may not sign this type of agreement without Legal review and approval.
4.6 Regulated Business
In some lines of business, the services we provide to our clients are regulated by governmental authorities. You are responsible for acquiring and maintaining any individual qualification and license necessary for you to perform such services and for complying with regulatory requirements. Consult your manager or a member of the management team if you have any questions or require assistance in complying with regulatory requirements.
4.7 Unauthorised Practice of Law
Since Saville Assessment is not a law firm, we must avoid the unauthorised practice of law to clients.
Qualified Saville Assessment colleagues may advise a client concerning the interpretation or application of laws or regulations as part of other consulting advice the company is providing to that client. However, the client should be advised that we do not provide legal advice and that they should consult their own Legal counsel. Keep in mind that we must not enter into client engagements where the primary purpose is to provide Legal advice.
4.8 Intellectual Property and Copyright
Saville Assessment uses a wide variety of products, publications and materials owned by third parties that are protected by intellectual property laws (such as copyright laws) and by various license, subscription and use agreements. We require others to respect our intellectual property rights, and we must respect the intellectual property rights of others.
Copyright laws in most countries prohibit the copying, distribution, use and display of a copyrighted work without the prior express permission of the copyright owner. Internal or external distribution of copyrighted material is never permitted without the appropriate permission. This includes posting material onto the intranet or onto network drives. The material covered by copyright includes web pages, copyrighted software, tools, databases, articles or other publications, artwork and video footage.
5. Doing the Right Thing for Our Fellow Colleagues
5.1 Inclusion and Diversity at Saville Assessment
Saville Assessment is committed to developing a diverse workforce and creating an inclusive, empowering environment for all colleagues. We want every colleague to feel they can bring their best selves to work every day. Our aim is to build a workplace that attracts the most talented people and enables them to develop to their fullest potential. We uphold the right to work in an environment that fosters courtesy and mutual respect, and we are committed to embedding our Inclusion and Diversity principles into everything we do. We also foster a workplace free of harassment, including harassment of a sexual nature.
We do not tolerate any form of discrimination or harassment in the workplace, or in any other work-related setting. This includes any harassment relating to race, colour, gender identity or expression, religion, sex, marital status, sexual orientation, age, disability, veteran status, ancestry, national origin or any other characteristic protected by law. Managers are responsible for implementing and enforcing this policy.
Harassing behaviours can vary, but in general, they all share the purpose or effect of creating an intimidating, hostile or offensive work environment. Harassing acts can include, for example, unwanted sexual advances (whether verbal, physical, or through body language or innuendo), threats of violence, racial slurs and/or racism and offensive jokes or remarks. The same is true of bullying, which includes humiliating, insulting, intimidating or isolating another individual.
Our company will not tolerate retaliation against anyone who, in good faith, reports discrimination or harassment or participates in an investigation of such reports. Anyone who does so may be subject to appropriate disciplinary action.
We must all respect each other's privacy by safeguarding our fellow colleagues' personal information. Our company is committed to protecting this information in accordance with all relevant privacy laws.
If we obtain any personal information about a colleague as part of our work for Saville Assessment, we must take special care to safeguard this information. In particular, we should not make statements about, or give references relating to, current or former Saville Assessment colleagues or employees of any related company without the approval of Human Resources. For example, routine reference checks by prospective employers should be referred to Human Resources. It may be appropriate, however, for a manager to discuss a current colleague's job qualifications and experience with a client if it is relevant to our work for the client.
Prior employment obligations
We must comply with any non-competition, non-solicitation and confidentiality obligations we have undertaken as part of our employment relationship with Saville Assessment. It is also important for us to comply with similar obligations we may have to former employers.
5.2 Workplace Health, Safety, and Security
Our greatest asset is our colleagues, making safety and security one of our top concerns. That is why we must all comply with applicable health, safety and environmental rules and regulations, as well as all posted safety procedures.
Preventing workplace violence
Because we are committed to health, safety and security, we insist on maintaining a workplace free of violence. Violence includes threats, intimidation or attempts to instil fear in others. If you know of or suspect incidents or threats of workplace violence, immediately report your concerns to your manager or another company resource.
Our company is also committed to providing a safe, productive and drug-free environment. We must never be under the influence of illegal drugs or abuse alcohol or any other substance when on the premises of Saville Assessment. This rule applies at any other location where we are acting on behalf of our company.
6. Doing the Right Thing for Our Company
6.1 Conflicts of Interest
A conflict of interest is any situation where different parties have different and potentially competing interests. At its most basic, a conflict may result in Saville Assessment putting its own interests ahead of those of its client or putting one client ahead of another. In some instances, it may be an individual colleague putting their interests ahead of the client.
A situation may be an actual conflict (the situation gives rise to a tangible conflict), a potential conflict (the situation does not currently give rise to a conflict, but a change of circumstances may alter this) or a perceived conflict (a conflict hasn't arisen, but the circumstances are such that it appears as though there may be a conflict.
Every colleague is expected to avoid any outside activity, financial relationship or relationship that presents a conflict of interest or the appearance of one.
If you think that you or Saville Assessment might have a conflict of interest, or the appearance of a conflict of interest, in a particular situation that requires assistance, you should contact your manager or a member of the management team.
Common ways conflicts of interest could arise are:
Saville Assessment is committed to providing its clients with services that are impartial and objective. To ensure that our clients' interests come first at all times, we must be careful when considering any assignment that may involve, or may appear to involve, a conflict of interest. We should identify and manage any actual or potential conflict of interest through disclosure to the client(s) and other means; this is vital to Saville Assessment's reputation and success.
Personal and family conflicts
You must avoid situations where you, or a family member, have an interest, financial or otherwise, in any business, property or other obligation that could affect or even appear to affect your obligations to Saville Assessment and its clients.
A conflict can arise just as easily when members of your family hold certain positions, engage in specific activities or pursue opportunities that conflict with our company's best interests. In general, your family members include spouses or domestic partners, children, stepchildren, parents, stepparents, siblings, in-laws, and any other household members.
Our company does not prohibit all outside employment. However, your duty to Saville Assessment is to ensure that outside employment does not interfere with your job responsibilities or performance. Before agreeing to any outside employment, you must seek approval from your manager.
In any case, you must not accept outside employment with a Saville Assessment competitor or with a client that you serve on behalf of the company. Outside employment will also not be permitted if it would compromise the company's confidential information or that of any client.
Participating on the board of directors of another entity may enhance your professional skills but can also lead to conflicts of interest. To avoid potential conflicts of interest in this area, colleagues may not accept an appointment as a director of an outside entity without prior approval from the management team. If your outside directorship is approved, you must not use the company's name in connection with your activities. In particular, you must not provide any advice or services that could be construed to be services provided as a Saville Assessment colleague.
Service as a director of a charity, a community organisation or a private club that is not a client, though not likely to raise any conflict of interest concerns, still requires disclosure and approval.
Avoiding conflicts of interests also means you must not compete with Saville Assessment or take for yourself or your family member's business opportunities that you learned about as a result of your position within the company. These opportunities belong to the company.
You should discuss with the management team any situation where your business interests or opportunities (or those of an immediate family member) may conflict with those of the company. They will ensure appropriate steps are taken to avoid or manage the actual or potential conflict of interest, including notifying the board, if applicable.
6.2 Giving and Accepting Business Gifts, Events/Entertainment and Hospitality
You may not exchange gifts, entertainment or hospitality with a client, supplier or other business relationship if it would influence, or could appear to influence, your or their objectivity, judgement, independence or integrity. Similarly, you may not accept payment or any other benefit to endorse any product or service, including those of a client or supplier.
Common business practices, such as providing meals, entertainment or modest gifts to a current or prospective client, are important for building solid relationships. These activities may be appropriate in the normal course of business, provided they are consistent with good practice, the amounts involved are not excessive or extravagant and good judgement is exercised in providing them. You should refer to the Saville Assessment Anti-Bribery & Corruption - Gifts, Events/Entertainment & Hospitality procedures and the monetary thresholds that require Compliance approval be obtained. You must never make a payment or provide a gift or entertainment that, if publicly disclosed, would embarrass you, the recipient or the company. As discussed in the following section, there are additional considerations and requirements that apply to giving gifts or entertainment to government or state-owned entity employees and public officials who may pose higher risk.
Keep in mind that gifts of cash may never be accepted or given. Also, colleagues may not accept a personal discount from clients or suppliers that is not generally available to the public or offered under an established discount program. All personal gifts or payments that are offered to you for consulting services, published materials, speeches and other services and products by virtue of your employment at the company must be declared and remitted to the company. Saville Assessment will reimburse colleagues for reasonable and necessary business-related entertainment expenses provided the expenses are properly documented (supported by an appropriate materials), have a legitimate business purpose and are in keeping with the Code and the company's other policies, procedures, standards and reputation.
You must also comply with any policies, rules or procedures applicable to colleagues in your line of business or geography. Some lines of business may have more restrictive rules relating to gifts or entertainment. Your manager will advise you if there are any rules that apply to you.
6.3 Anti-Bribery and Corruption Guidelines
We conduct our business with integrity, honesty, fairness and transparency, and we never engage in bribery or employ corrupt practices. This means you must never offer bribes, gratuities, kickbacks, or other inducements in any form (payment, loan, promise, employment, etc.) to anyone in order to influence their decisions to use the company's services. In addition, you must not work with a Third Party who may engage in this type of activity generally and never retain a Third Party to engage in this type of activity on our behalf.
Just as you must not offer a bribe, you must not accept one either. If any unethical or illegal payments are requested of you by anyone, or if you believe someone is engaging in conduct that violates Saville Assessment's Anti-Bribery & Corruption policy, contact your manager or a member of the management team immediately.
In addition to prohibiting commercial bribery, many countries have enacted laws that specifically prohibit bribing government or state-owned entity employees and public officials. And special care and attention is required when interacting with these individuals. Some of these laws apply anywhere in the world, for example, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. Saville Assessment's business is global and subject to these anti-bribery laws in all countries where we do business. While our company realises that business conduct can differ markedly in various countries, we are committed to complying with all applicable anti-bribery laws.
Under anti-bribery laws, you must:
- never give or offer anything of value to a government or state-owned entity employee or public official to influence any decision in their official capacity
- never pay anyone if we believe that any portion of the payment will be given or offered to any government or state-owned entity employee or public official on our behalf
- never offer or give a financial or other advantage to induce another person to improperly perform in one of their functions in their position of trust and responsibility, or as a reward for improper performance
- take care that payments to agents, consultants, lawyers and other similar parties are not channelled to government or state-owned entity employee or public officials
- obtain prior approval from the management team before providing any gift, entertainment or hospitality to a government or state-owned entity employee or public official. Ensure that any gift, entertainment or hospitality is properly and transparently recorded in the appropriate company accounts.
Government officials include any officer or employee of a Government Entity or a state-owned enterprise, or any candidate for political office, regardless of the person's rank or seniority within the organisation, including members of the person's immediate family.
Anti-Bribery & Corruption laws also require Saville Assessment to keep accurate records of business transactions. Failing to do so can be a separate offence under Anti-Bribery & Corruption laws, even if no bribery or corruption occurs.
Working with Third Parties
We all know that certain payments can violate anti-corruption laws. Payments to or through Third Parties pose a higher risk; the company can be held responsible for a Third Party's actions if they engage in bribery and corruption when performing services on behalf of the company. Colleagues must, before starting to work with a Third Party, follow the company procedures to assess and mitigate the risk posed by Third Parties and obtain the required approvals.
What are some red flags we should be aware of when dealing with Third Parties?
- A request to be paid in cash, in another name, or to an address in another country
- An agent demanding an unusually high commission for a transaction
- Any agent or salesperson who says they are working directly with a government official to give our company the contract (remember, government or state-owned entity officials and employees may pose higher risk)
6.4 Sanctions, Trade Restrictions and Export Controls
We must comply with sanctions, trade restrictions and export controls imposed by all governments in the areas we do business. These restrictions prohibit us from doing business with certain countries, companies or individuals. Breaches of these laws are a criminal offence in most countries in which Saville Assessment operates and can expose Saville Assessment and colleagues to serious consequences: prosecution, extradition, imprisonment, fines and exclusion from financial markets, as well as reputational damage.
A sanctioned country touchpoint is any direct or indirect link to a sanctioned country, however remote or small. Examples include providing services to an entity based in a sanctioned country.
We are also required to comply with export controls that prohibit or restrict the export or re-export of specified goods, services and technology.
6.5 Money Laundering and Counter-Terrorist Financing
Many countries in which Saville Assessment operates have laws or regulations that prohibit money laundering and terrorist financing. Saville Assessment does not condone financial crime and views preventing the company and colleagues being involved in money laundering or terrorist financing as an integral feature of how it conducts business.
Money laundering is often complicated and hard to identify or detect. Undertaking due diligence is a key control to mitigate the risk of Saville Assessment becoming involved in money laundering or terrorist financing. Saville Assessment colleagues must always follow their "Know Your Client" processes to ensure they know and understand their client and their client's business, prevent Saville Assessment from being part of any transaction involving proceeds of crime or intended to be used to commit or fund terrorist acts, and to help them spot suspicious activity.
Colleagues who have suspicion or knowledge of money laundering or terrorist financing must report it immediately by following the applicable internal reporting process.
6.6 Tax Evasion Anti-Facilitation
Saville Assessment is committed to conducting business with honesty, integrity and fairness and has a zero-tolerance approach to tax evasion and the facilitation of tax evasion.
All colleagues in companies owned and/or controlled by Saville Assessment are prohibited from seeking to evade tax on behalf of Saville Assessment and must not aid, abet, counsel or help anyone to evade tax (including clients, suppliers or Third Parties). This prohibition extends to all Saville Assessment colleagues, wherever they are located and whichever country they operate in.
Saville Assessment will not work with individuals or organisations who do not share our commitment to prevent tax evasion and the facilitation of tax evasion in their work for or on behalf of Saville Assessment. We will also not work with or recommend individuals or organisations if we know or suspect that, by working with or recommending them we would enable them to evade tax or facilitate the evasion of tax by others.
All colleagues and business leaders have a responsibility to help detect and prevent tax evasion, and the facilitation of tax evasion in Saville Assessment or by its associated persons and should report any concerns to business leaders.
Colleagues should read the Tax Evasion Anti-Facilitation guidance, which provides examples of unacceptable behaviours and possible tax evasion. The guidance also informs colleagues of what they should do if they suspect tax evasion and/or its facilitation.
6.7 Company Assets and Information
Safeguarding Saville Assessment assets (both tangible and intangible property) is crucial to our success. We all have a duty to use Saville Assessment assets for legitimate purposes and to protect them from loss or unauthorised use.
We also have a duty to safeguard our information. As Saville Assessment colleagues, we have access to a broad array of confidential and proprietary information about our company, including:
- information about our business
- professional practices
- colleague information
- business plans
- products and services
- pricing and marketing
- research and development
This information enables us to achieve our mission of contributing to our clients' success. It must be used only for the exclusive benefit of Saville Assessment. If you have any doubt about what may be confidential information, speak with your manager or a member of the management team.
We must not disclose our confidential or proprietary information to anyone outside Saville Assessment, except to the extent necessary for conducting our business. In some cases, we may require a client or third party to sign a confidentiality agreement before we disclose certain information. Always consult a member of the management team before making sensitive information available outside our company.
Your obligation to maintain the integrity and confidentiality of Saville Assessment information continues even after you leave the company. When you leave, you must not copy or retain any information or documents pertaining to Saville Assessment or its clients without the written permission of your manager.
Confidential client information
Our clients also entrust us with their confidential information. They expect us to hold personal information, documents and other data in the strictest confidence. Many of our assignments involve the use of personal data about individuals (including their compensation and health information) or access to confidential plans and business strategies. Any information that is not publicly available and is given to Saville Assessment by clients should be regarded as confidential. This information may not be disclosed except when properly authorised or legally mandated.
Under some circumstances, even the fact that we are serving a particular client is itself confidential. This information may not be disclosed publicly or, in some cases, beyond the individuals on the client team within the company. If applicable, you should consult with your manager or your designated Compliance business partner who will advise you if you are working on this type of confidential assignment.
In general, to comply with confidentiality obligations, we should:
- never improperly disclose or use information about a client, supplier or other business partner
- never discuss any confidential matters with third parties, including any specifics of the work we perform for clients or our recommendations unless authorised by the client (preferably in writing)
- never discuss client matters in public places, such as elevators, lobbies, restaurants, airplanes or trains, where the discussion may be overheard, or in public forums, such as blogs, social media websites, or other messaging platforms and apps, unless authorised
- exercise great care when taking or sending confidential information out of the office, whether electronically or on paper
- comply with the information security and data privacy policies and any client requirements relating to the handling of confidential information
- comply with any additional safeguards and procedures that may apply for certain projects such as mergers or acquisitions.
Financial information relating to a client or other business partner is especially sensitive. It should be considered confidential, except when its disclosure is approved in writing by Saville Assessment, the client or business partner. If such information has been publicly available in financial reports for at least two business days, it is also acceptable to discuss or disclose. If you have any doubt about what may be confidential information, speak with your manager or a member of the management team.
The use of passwords is intended to protect the security of the company's business. It should not be construed as conveying an expectation of privacy to individual users. All copies of documents or messages created, sent, received or stored on computers, the Internet and voicemail systems remain the exclusive property of Saville Assessment. Therefore, they are subject to monitoring and review as appropriate, in accordance with local Legal requirements.
Physical assets and company computer systems
Saville Assessment provides a wide variety of assets for us to use while conducting the company's business. We are responsible for ensuring that these assets are adequately protected and used only for valid company purposes. You may not use any company property for your own personal use or gain without prior management approval. Company property includes information, facilities, intellectual property, equipment, software or supplies that are owned, leased or otherwise in the company's possession. Limited personal use of systems and equipment is acceptable as long as it does not conflict or interfere with the company's business interests or operations and does not violate any company policies.
If you unlawfully remove any company property, you will be disciplined appropriately and may be subject to legal action. In the event your employment with the company is terminated, all originals and copies of Saville Assessment property and material in your possession or under your control must be returned to the company.
In the course of employment with Saville Assessment, you may help develop services, products, materials and other intellectual capital related to the company's business. Saville Assessment exclusively owns all intellectual property rights, including all copyright, patent and trade secret rights, to that work.
6.8 Social Media
Online social media provides us with a vast array of opportunities to communicate with our stakeholders and community at large. Social media includes posts, comments, check-ins, reactions, emojis, blogs, micro blogs, social networking sites, wikis, photo/video sharing sites, and chat rooms. Electronic messages are records of our communications that can greatly affect Saville Assessment's reputation. You must not give the appearance of speaking or acting on the company's behalf unless you are authorised to do so. Never post a social media link to a page that takes or solicits donations unless the charitable program and social media post has been officially approved by Corporate Social Responsibility.
If you believe you have witnessed the inappropriate use of Saville Assessment technologies or electronic communications on social media, or other public or private messaging platforms, notify your manager immediately.
7. Doing the Right Thing for Our Shareholders
7.1 Accurate Books and Records
For ethical, business and legal purposes, Saville Assessment records must be professionally prepared and properly managed. This means, in part, that our financial and accounting records must be accurate and complete. Books and records must also be kept in accordance with generally accepted accounting principles and with established finance and accounting policies. Never make false or misleading entries in any books or records.
Keep in mind that all transactions must be documented carefully and supported by a valid business purpose. For example, you must properly and accurately record your business expenses in Compliance with the applicable policies. You must also prepare and submit all client invoices in accordance with applicable client agreements. "Off the books" accounts may not be used to conceal or facilitate illegal or inappropriate payments.
In addition, you must not make any false or misleading statements to our accountants, auditors or any government officials or third parties (such as clients, suppliers, creditors or regulators). Similarly, you must not take any action to coerce, manipulate, mislead or fraudulently influence internal auditors. To promote compliance with full, fair, accurate, timely and understandable disclosure in public communications, certain senior colleagues are required to sign a management representation letter acknowledging their compliance with the above referenced policies.
To ensure that Saville Assessment retains records required by law and necessary to its business, you must follow our Records Management policies applicable to your work. When litigation, an audit or an external investigation is pending or reasonably foreseeable, all relevant paper and electronic records (including current, archived and backed-up e-mail) must be preserved. These records must never be destroyed until the matter is closed. Any questions about the applicable records management policy should be directed to the management team.
In addition, you must generally avoid using WhatsApp, WeChat, or similar non-Saville Assessment-approved platforms to communicate about substantive business matters. If a client, vendor, or other third party insists on using such platforms you must re-direct such communications to an approved platform, or, if that is not possible, take steps to preserve all such communications.
7.2 Inside Information and Securities Trading
Insider trading - which is trading on the basis of material, non-public information - is strictly forbidden under the laws of many countries where we operate. These laws apply regardless of the value of the trading transaction. Securities laws impose serious penalties for insider trading, including fines and imprisonment. Some examples of inside information are information related to:
- Mergers and acquisitions
- Financial results or guidance
- New significant clients or products
- Senior management changes
- Expansion plans
- Significant cyber breaches
Insider trading prohibitions apply to trading in the securities of many companies, including clients, suppliers, partners and competitors. If you have material inside information about those companies, do not trade on the basis of this information.
Insider trading laws also apply to the sharing of material non-public information with friends or family. This is considered another form of insider trading. Even passing along a "tip" is unlawful and could subject you and the other party to severe fines or imprisonment.
7.3 Audits and Investigations
Since Saville Assessment is committed to complying with the law, we will cooperate with any reasonable request made in a government audit or investigation. In doing so, however, it is essential that we protect the legal rights of all who may be involved. If you receive a subpoena or other legal document relating to company business or Saville Assessment colleagues or clients, immediately contact a member of the management team.
7.4 Handling External Inquiries
From time to time, we may need to communicate with government agencies. However, we must never contact any such government agencies on the company's behalf without specific authority. We also should never communicate with a government agency on a client's behalf without that client's approval. A response to "service of legal process" (for example, subpoenas for documents, deposition notices, or interrogatory requests) can only be made after consultation with the management team.
In order to preserve our reputation for integrity, we also need to ensure that our communications with the public give an accurate and honest picture of our business operations, transactions and plans. It is important for us to speak about the company with one consistent voice. Therefore, you may not make public statements on the company's behalf unless you have been designated as a company spokesperson. If a member of the press requests information from you, even if the request is informal, please refer them to the marketing team.
8. Doing the Right Thing for Our Communities
8.1 Participation in Our Communities
We each make a positive difference in the communities where we live and work through our volunteer, charitable and political activities. Saville Assessment respects our freedom to take part in these activities.
However, just as we should not participate in personal political activities on company time, we also must not contribute Saville Assessment funds or resources to any political party, candidate or public official. "Resources" include office space, equipment and supplies or colleague work time to make telephone calls or prepare campaign materials. Any personal political contribution that you make must not be represented as coming from Saville Assessment.
In many countries where we operate, lobbying is subject to strict rules and regulations. These rules and regulations can be complex and difficult to interpret. You should not engage in any lobbying activity without the express permission of the management team.
8.2 Combating Human Rights Violations of Slavery and Human Trafficking
The United States, the United Kingdom, Australia and other countries prohibit slavery and human trafficking, with the United Nations defining human trafficking as "the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation."
The nature of our business as a provider of professional services to corporate clients means that we have a low risk for slavery and human trafficking violations. However, because a higher risk may exist in our supply chain, it is important that all colleagues are aware of the prohibitions against human trafficking and understand that the company will take appropriate action against any colleague, agent or subcontractor that violates those prohibitions. Company requirements relating to our vendors, including due diligence, onboarding and monitoring, tender processes and contracting requirements, are all intended to minimise the risk that our supply chain benefits from human trafficking. Please contact a member of the management team with any questions or to report any concerns.
9. Exemptions and Waivers
With respect to colleagues of Saville Assessment Ltd, any request for a waiver of or exemption from these requirements must be submitted to the management team or the board. In the event of an approved waiver or exemption involving the conduct of an executive officer or director, appropriate disclosure will be made to the company's shareholders, including the reasons for the waiver.
10. Code or Policy Queries
If ambiguity or uncertainty arises as to the meaning of any requirements contained in this Code or company policies, please refer to the management team.
Each colleague must understand and follow the Code, comply with its underlying principles and policies, and be familiar with the processes for reporting potential or actual violations. To ensure that you meet these obligations and comply with our standards of conduct, you must annually acknowledge that you have read, understand and will comply with the Code.
About Saville Assessment
Saville Assessment is a globally renowned provider of market-leading talent assessment products transforming how organisations Hire, Build and Lead their talent.
Founded in 2004 by the eminent forefather of psychometrics, Professor Peter Saville, the team includes some of the most respected Business and Occupational Psychologists in the industry.
Our award-winning suite of personality questionnaires, aptitude tests, situational judgement tests and talent analytics blend scientific expertise with digital innovation accurately predicting workplace performance and potential.
Learn more at:
Owner: Management Team
Last updated: 1 August, 2023.