At OCAPI Limited, we believe in running and developing our business in a sustainable way. We believe that our business interests are best served by behaving responsibly towards all of our stakeholders; clients, staff, suppliers and the communities in which we operate.

We believe that we have a responsibility to adhere to the highest standards of behaviour and care.

Our Ethical Business Policy therefore sets out the universal standards of individual and collective behaviour that we seek to apply to all of our activities.

At OCAPI Limited we are proud of our values:

• Quality

  Outstanding quality and high standards in everything. We aim for perfection: well-designed, well-tested, on-time, on-budget.

• Customer focus

  Customers are our first priority. We understand our customers’ needs and add value, creating the best customer experience possible and prioritising solving customer problems.

• Leading expertise

  We stay at the forefront of technology, develop our knowledge and understand the latest technology trends, employ and develop the best experts.

• Strength in numbers

  We attract, motivate and develop the best team members, create a supportive, open and honest environment, work hard, have fun and smile. We treat others how we would want to be treated.

• Stable environment

  We create a reliable and safe environment for staff and customers, financially and contractually.

• Constant improvement

  We continuously improve our expertise, people, processes, develop our markets and customer relationships and optimise efficiency by finding ways to get the job done in the quickest, most effective way.

The general principles which underpin this policy align with these values.

Therefore, we will:

• Treat staff fairly and with respect for their dignity
• Implement policies and procedures to prevent slavery and human trafficking in all parts of our business, and within our supply chain.
• Deal with clients with integrity, offering good value, high quality advice and prompt redress if something goes wrong.
• Embrace the aspirations of our clients and the design team, making positive, enthusiastic and timely contributions and deploying the best available expertise in the design process.
• Conduct our relationships with suppliers with honesty, fairness and mutual trust.
• Be fair and honest in our dealings with Contractors, select them objectively and administer their contracts judiciously.
• Always specify products for projects rationally, acting solely in the client’s interest, in a way that is auditable.
• Comply fully with our legal obligations and aim to make a positive contribution to the sustainable development of the communities in which we work.
• Monitor ethical performance and produce regular reports giving a true and fair view of our affairs.

This policy aims to outline how we do business. We recognise that it would be impossible to produce a comprehensive set of rules that cover every situation that our people might encounter in the course of their work. Instead, this policy seeks to provide the framework within which we expect our people to operate, and some guidelines as to what may or may not be acceptable.

Where a particular activity is clearly at odds with our ethics as an organisation and is deemed to be unacceptable in any circumstances, this is made clear in this policy. As a general rule, we expect people to make sensible and informed judgements about whether a particular activity, approach or way of working is ethical and likely to be acceptable to OCAPI Limited, and to seek guidance from others within OCAPI Limited as required where they are unsure.

This policy should be read in conjunction with OCAPI Limited’s specific policies (which can be found in the Company Handbook) and which cover:

• Health, Safety and Welfare
• The Environment
• Diversity
• Equal Opportunities

OCAPI Limited’s business activity and our employees are subject to the laws and regulations of different countries, and of organisations such as the European Union. Each of us is responsible for knowing and following the laws that apply to us where we work.

This policy establishes principles for business conduct applicable to OCAPI Limited, regardless of geographical location. Where differences exist as a result of local customs, norms, laws or regulations, OCAPI Limited is expected to adhere to the principles and spirit of this policy and with local requirements.

Bribery and Corruption

The Bribery Act 2010 (the ‘Act’) was enacted on 8 April 2010 and its main provisions commenced in July 2011. Under the Act, the main offences are bribing another person, being bribed, bribing a foreign official, and a corporate offence of failing to prevent bribery. As a result of this Act, certain actions abroad, which were acceptable business practice, will now constitute offences in the UK if the person performing them abroad has a close connection to the UK or if the related corporate body is incorporated in the UK or carries out part of its business in the UK. Further, these offences will be judged according to an “expectation test”, which is what would the reasonable person in the UK expect in relation to the performance of the activity concerned (that is, not what behaviour is common in the place where the activity has taken place).

Anti-bribery and anti-corruption laws apply to all OCAPI Limited employees worldwide, and any bribery or corruption is always contrary to OCAPI Limited’s own standards of business conduct.

OCAPI Limited employees must not under any circumstances make or accept any offers of bribery (this is widely defined and includes offers of services, money, gifts or entertainment). If you are in any doubt regarding this, you should speak to a member of the Management Board. Any actual or suspected bribery must be reported to a member of the Management Board.

Any employee who is suspected to have breached our policy in this regard will be subject to a disciplinary investigation, which may lead to their dismissal from their employment. Any report by an employee of actual or suspected bribery will be treated in confidence and provided that any such report is made in good faith in support of OCAPI Limited’s commitment to zero tolerance towards bribery and corruption, the employee shall be protected from any reprisals in connection with their report.

Child or Forced Labour

OCAPI Limited is committed to the elimination of all forms of forced and compulsory labour, and to the effective elimination of child labour. Each OCAPI Limited employee is expected to be aware of and abide by these commitments, and to never personally hire child or forced labour. Employees should also be alert to any evidence of child or forced labour in operations linked to OCAPI Limited, and report them to the Management Board.

Anti-Collusion

OCAPI Limited will not collude with others (including contractors, suppliers or service providers) in the pricing or submission of tenders or services, nor will OCAPI Limited enter into any agreement with any other person or body that they shall refrain from participating in any competitive tender, submission or pre-qualification process.

Gifts and Entertainment

The exchange of gifts and entertainment can build goodwill in business relationships, but can also create improper influence or the appearance of improper influence. OCAPI Limited therefore provides detailed guidance for managers and staff, to help them determine whether gifts may be accepted.

Supervision of Others

Those who supervise others have additional responsibilities for maintaining compliance with this policy. They must commit to:

• Leading by example, promoting compliance and ethics in all of their behaviours.
• Making sure that those who report to them understand the requirements of this policy and have the resources to meet them.
• Monitoring compliance and ethics within their team(s), and taking appropriate action to address any shortcomings.
• Using reasonable care to monitor the behaviour or third parties acting on behalf of the OCAPI Limited to ensure that they behave in an ethical manner.
• Supporting employees who, in good faith, raise questions or concerns about ethical issues within OCAPI Limited.

Personal Responsibility

Everyone who works for OCAPI Limited has a responsibility to comply with the letter and the spirit of this policy, and to bring to the attention of management any suspected breach of the policy by another OCAPI Limited colleague. In considering whether to speak up about a suspected breach, employees should ask themselves some simple questions:

• Is the action legal?
• Does it comply with OCAPI Limited’s Ethical Business Policy?
• Is it in line with OCAPI Limited’s values?
• Does it expose OCAPI Limited to any unacceptable risks?
• Does it match the commitments and guarantees that we have made to others?
• How would it look if reported in the newspapers?
• Does it feel right?

As well as compliance with the policy, OCAPI Limited colleagues are expected to exercise good judgement and common sense, so that their actions never jeopardise our reputation as a responsible business.

Changes to our Ethical Business Policy

OCAPI Limited keeps its Ethical Business Policy under regular review. This Ethical Business Policy was last updated on 05 February 2020.