Business Ethics Policy
1.1 M&E Global, LLC (“the Company”) is committed to the practice of responsible corporate behaviour.
1.2 Through its business practices the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents.
1.3 Further the Company is committed to protecting the rights of all those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company.
1.4 The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form.
1.5 This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.
2.1 The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman, or degrading punishments; and any attempt to control or reduce freedom of thought, conscience, and religion.
2.2 The Company will ensure that all its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.
2.3 The Company will not enter any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.
3.1 The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.
3.2 No worker should be discriminated against based on age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status, or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.
3.3 No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment because of joining, or failing to join, any such organisation.
3.4 Workers should be aware of the terms and conditions of their employment or engagement from the outset. Workers must be made aware of the wage that they receive, when and how
M&E Global, LLC, 63480 Ironwood Rd., South Bend, Indiana 46614, USA. Tel: +1 (574) 806-6580
it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum.
3.5 The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.
4.1 The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order help achieve this aim. Copies of the Environmental Policy are available from the Business Manager
4.2 As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.
5.1 The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers, and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.
5.2 To help preserve and strengthen these relationships the Company has developed a Corporate Hospitality and Gifts Policy, which provide rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. Copies of the Corporate Hospitality and Gifts Policy are available from the Business Manager
5.3 All officers, employees and representatives of the Company are expected to act honestly and within the law.
6.1 Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given.
6.2 The Company will always ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 2023) in force from time to time.
The Company, its officers, employees, and representatives are committed to ensuring that no act or omission which is within their power and which would have the effect of deliberately, negligently, or recklessly misleading the shareholders, creditors or other investors in the Company occurs.
8.1 The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards.
8.2 The Company will investigate the ethical record of potential new suppliers before entering
M&E Global, LLC, 63480 Ironwood Rd., South Bend, Indiana 46614, USA. Tel: +1 (574) 806-6580
into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.
8.3 The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy.
9.1 The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the FCPA.
9.2 Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment.
9.3 All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy available from the Commercial Director
9.4 Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy available from the Business Manager
9.5 The Company uses its reasonable endeavours to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with FCPA.
9.6 If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.
9.7 Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.
M&E Global, LLC is committed to providing a quality service in a manner that ensures a safe and healthy workplace for our employees and minimizes our potential impact on the environment. We will operate in compliance with all relevant environmental legislation, and we will strive to use pollution prevention and environmental best practices in all we do.
We will endeavor to:
§ Integrate the consideration of environmental concerns and impacts into all our decision making and activities.
§ Promote environmental awareness among our employees and encourage them to work in an environmentally responsible manner.
§ Inform our employees about environmental issues that may affect their work.
§ Reduce waste through re-use and recycling and by purchasing recycled, recyclable, or re- furbished products and materials where these alternatives are available, economical, and suitable.
§ Promote efficient use of materials and resources throughout our facility including water, electricity, raw materials, and other resources, particularly those that are non-renewable.
§ Avoid unnecessary use of hazardous materials and products, seek substitutions when feasible, and take all reasonable steps to protect human health and the environment when such materials must be used, stored, and disposed of.
§ Purchase and use environmentally responsible products accordingly.
§ Strive to continually improve our environmental performance and minimize the social impact and damage of activities by periodically reviewing our environmental policy in light of our current and planned future activities.
Equality and Diversity Policy
Our belief is that our success is a direct result of the experience and quality of our employees. We are, therefore, committed to focusing our employment procedures and practices on maximising the potential of each unique individual. We believe this is best achieved by developing our employees’ talents, whilst recognising their differences.
By treating people fairly and equally and by accepting and embracing their diversity, we can also improve our market competitiveness, foster innovation, enhance our corporate social responsibility and create an inclusive and positive working environment for all employees.
It is the policy of the Company that no person acting on our behalf shall discriminate in any situation against another individual or group, directly or indirectly, because of age, sex, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief and sexual orientation.
These principles apply to recruitment selection, training, promotion, transfer, pay and benefits and performance appraisal procedures, in addition to all terms and conditions of employment.
This Policy covers all M&E Global LLC and employees, regardless of position or status, plus contractors, subcontractors, and recruitment Candidates.
Aims:
§ To ensure equality, diversity and inclusion in the workplace and community
§ To offer fair treatment in every aspect of the working life in M&E Global LLC, from our written procedures through to every decision made
§ To promote a culture where each employee, colleague and candidate is treated with respect and dignity and recognises the value that a diverse workforce can bring
To achieve these aims, M&E Global LLC commits to the following:
§ Ensure that the principles of this Policy are embedded in all procedures of our business
§ Provide awareness training and guidance to all employees to ensure M&E Global LLC commitment to diversity is known and understood.
§ Challenge and investigate discriminatory behaviour including enforcing disciplinary procedure when this is considered necessary
§ Support all staff in promoting equality and diversity across our business, including candidates and clients
§ Communicate and regularly review any initiatives identified and ensure access for all, implementing when deemed suitable as a part of our Continuous Improvement programme
§ Support the communities in which we live and work to ensure that we are involved, accessible and socially responsible
§ Work with external groups and advisory bodies to keep up to date with market practice and how issues are dealt with.
Recruitment (Internal)
M&E Global LLC recruitment and selection procedure is based solely on the necessary and justifiable job requirements and the individual’s suitability.
Job profiles are drawn up and used for every post. Where posts are advertised externally, consideration is given to the most appropriate outlets to ensure that a wide range of potentially suitable applicants have the opportunity to apply.
Selection methods, including interviews, are conducted in accordance with documented and standardised procedures and checklists, designed to ensure that discrimination forms no part of the recruitment process. The objective is to make each appointment or client introduction on the grounds of selecting the most suitable candidate for the post.
All M&E Global LLC staff are given the opportunity to take part in both job specific training and have an individual Performance Plan designed to promote their opportunities and career advancement.
M&E Global, LLC(“Company”) is a US based defense sub-contractor serving the needs of large corporations that in turn serve as Prime contractors to government. Our HQ is in the US and with an affiliate office in the United Kingdom. In all cases, from all locations, we aim to act in accordance with internationally recognized human rights standards, integrating them to the way we operate globally.
Our Human Rights and Modern Slavery Policy applies to all Company staff and we expect our suppliers to respect and adhere to this policy.
The following statements outline our position with respect to human rights and modern slaver
M&E Global, LLC (“the Company”) is a US based defense sub-contractor serving the needs of large corporations that in turn serve as Prime contractors to government. We operate globally, our HQ being in the USA and with a affiliate office in the UK.
Our Vendor Code of Conduct outlines the way in which we and our suppliers behave and interact with each other. Our standards are high and positioned to meet those of our clients and in turn we expect our suppliers to respect and adhere to this policy to ensure that all Company stakeholders follow best practice with respect ethics and conduct as outlined below.
1.1 The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.
1.2 The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.
1.3 The Company will not enter into any business arrangement with any person, company or organization which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organization’s activities.
2.1 The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.
2.2 No worker should be discriminated against on the basis of age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.
2.3 No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organization.
2.4 Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum.
2.5 The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.
3.1 The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order help achieve this aim. Copies of the Environmental Policy are available from the Commercial Director
3.2 As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.
4.1 The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.
4.2 In order to help preserve and strengthen these relationships the Company has developed a Corporate Hospitality and Gifts Policy, which provide rules and guidelines concerning the conduct of its officers and employees aimed at minimizing the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. Copies of the Corporate Hospitality and Gifts Policy are available from the Commercial Director
4.3 All officers, employees and representatives of the Company are expected to act honestly and within the law.
5.1 Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given.
5.2 The Company will at all times ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 1998) in force from time to time.
The Company, its officers, employees and representatives are committed to ensuring that no act or omission which is within their power, and which would have the effect of deliberately, negligently or recklessly misleading the shareholders, creditors or other investors in the Company occurs.
7.1 The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards as outlined in this Code of Conduct.
7.2 The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.
7.3 The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Code of Conduct.
8.1 The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010.
8.2 Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment.
8.3 All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy available from the Commercial Director
8.4 Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy available from the Commercial Director
8.5 The Company uses its reasonable endeavors to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010.
8.6 If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.
8.7 Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.
M&E Global, LLC
Corporate Office