1.0 Code of Ethics
We aim for high ethical and environmental standards, both within Coalesce and throughout our supply chain. Our people and our suppliers are required to operate in an ethical, legally-compliant and professional manner. We require all our suppliers, whether engaged to provide services to us directly, or through us to our clients, to commit to our Code of Ethics (“Code”) and to promote the same high standards in their supply chains.
The Code covers commitments against corrupt practices and commitments to ethical and environmental standards. The Code is based on statutory requirements and internationally recognised standards set out in the UN Universal Declaration of Human Rights and the International Labour Organisation Conventions.
This Code relates to our global operations and forms part of our approach to corporate responsibility at Coalesce. The Code is mandatory for all suppliers engaged by us. It exists to protect the relationship between Coalesce, our Clients and our Suppliers and to help us maintain the high standards we expect.
1.1 Coalesce’s Ethical Standards:
• We aim to protect Coalesce people from exposure to, or the appearance of, participation in collusive or unethical practise.
• We recognise the legitimate interests of all parties and operate our procedures in good faith.
• We do not accept or give gifts, hospitality or entertainment which might affect, or which are intended to affect, business judgement. This prohibition applies equally to cash gratuities, goods and services, in kind or at preferential rates.
• Coalesce people do not accept gifts, hospitality or entertainment outside the scope of their employment which might affect, or which is intended to affect, their judgement on a matter that is within the scope of their employment. This prohibition applies to cash gratuities, personal discounts, gift vouchers, loans, favourable terms on any product or service intended for personal use, share options, to name just a few.
• We only accept hospitality offered in a business context, and this must be offered on a reciprocal basis.
• We do not seek to influence business decisions by offering gifts, hospitality or entertainment or by any other inappropriate means.
• We are committed to complying with all anti-bribery and anti-corruption laws applicable to our business, including the English Bribery Act 2010 and the US Foreign Corrupt Practices Act.
• We respect the confidentiality of our Clients’ and Suppliers' information and we expect our suppliers to keep confidential all aspects of our relationship.
1.2 Commitments Against Corrupt Practices:
We expect that you/your organisation:
• work and will, in all your dealings with Coalesce, work to the highest standards of professional competence and integrity;
• operate in a fair and equitable manner;
• aim to protect your people from exposure to, or the appearance of, participation in collusive or unethical practise;
• recognise the legitimate interests of all parties and, in all your dealings with Coalesce, act in good faith;
• do not accept or give gifts, hospitality or entertainment which might affect, or which are intended to affect, business judgement. This prohibition applies equally to cash gratuities, goods and services, in kind or at preferential rates;
• shall procure that your people do not accept gifts, hospitality or entertainment outside the scope of their employment which might affect, or which is intended to affect, their judgement on a matter that is within the scope of their employment. This prohibition applies to cash gratuities, personal discounts, gift vouchers, loans, favourable terms on any product or service intended for personal use, share options, to name just a few.
• will only accept hospitality offered in a business context, and only if offered on a reciprocal basis;
• do not seek to influence business decisions by offering gifts, hospitality or entertainment or by any other inappropriate means;
• do not and will not offer or give any Coalesce person any personal gift, hospitality or entertainment which might affect, or which is intended to affect, the business judgement of that Coalesce person. This prohibition applies to cash gratuities, personal discounts, gift vouchers, loans, favourable terms on any product or service intended for personal use, share options, to name just a few;
• are committed to complying with all anti-bribery and anti-corruption laws applicable to your business, including, where relevant, the English Bribery Act 2010 and the US Foreign Corrupt Practices Act; and
• respect the confidentiality of our information and keep confidential all aspects of our relationship.
1.3 Commitments to Ethical Standards:
Our Commitments to Ethical Standards are covered in our Slavery & Human Trafficking policy (see 2.0 below). We expect that everyone with whom we engage adheres to those Global standards.
1.4 Supplier Commitments to Environmental Standards:
Compliance with all environmental laws: As a supplier or potential supplier to Coalesce, we expect you to comply with all national, European Union or International laws in relation to the environment.
Environmental Efficiency: We are committed to proactively managing and reducing the impact of our business on both the local and global environment and to increasing its environmental sustainability.
We expect you to have in place and apply policies and processes to continuously identify and act on opportunities to:
Reduce your business’ resource consumption including:
2.0 Modern Slavery Policy
2.1 Coalesce Management Consulting Limited and its global subsidiaries (“Coalesce”) are committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
2.2 Coalesce is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
2.3 All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
2.4 Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to either the Director of Operations or the Group Finance Director.
2.5 Reports surrounding these issues are taken extremely seriously by the Directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
2.5.1 Removing that organisation from our preferred supplier list
2.5.2 Passing details to appropriate law enforcement bodies.
2.6 We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
• The effectiveness of enforcement against suppliers who breach policies
• The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
• The level of modern slavery training and awareness amongst our staff.
2.7 As part of our efforts in this area, we publish a modern slavery statement on an annual basis.
2.8 We would also recommend reading this in conjunction with our other policies, including our:
• Code of Ethics
• Corporate Responsibility Policy
• Anti-Bribery & Corruption Policy
• Whistle-blowing Policy
This policy was adopted on 01 March 2021 after being agreed by the Board of Directors. It is to be reviewed annually.
3.0 Coalesce Anti-Bribery and Corruption Group Compliance Statement
‘A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly…’
Coalesce operates a zero, no tolerance approach towards all forms of bribery, corruption and unethical behaviour. As a professional recruitment consultancy Coalesce is committed to applying the highest standards of ethical conduct and integrity whilst conducting its business activities. Our stance on bribery, corruption and unethical behaviour is woven into our culture, procedures and our policies and we operate a transparent business ethic to ensure honest and fair competition in our industry, protection of our reputation and protection of those more vulnerable.
Coalesce’s Anti Bribery, Corruption and Unethical Behaviour Policies apply to all Coalesce employees, temporary contractors/consultants and any companies that we operate with on a subcontract / third party basis.
Coalesce’s Board of Directors and Senior Management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery in accordance with (and which includes but is not limited to) the Foreign Corrupt Practices Act of 1977 (FCPA) (as amended) which prohibits payment of any money or anything of value to a foreign official, foreign political party (or official thereof), or any candidate for foreign political office for the purposes of obtaining, retaining, or directing of business; The OECD Anti-Bribery Convention which is designed to reduce corruption in developing countries and across international business transactions; and the Bribery Act 2010 which repeals all previous statutory and common law provisions in relation to bribery and instead, replacing them with the crimes of bribery, being bribed, the bribery of foreign public officials, and the failure of a commercial organisation to prevent bribery on its behalf.
Coalesce has designed and implemented firstly, a blanket policy which covers every area of our business and secondly, is further tailor-made to the specific business units / employees and temporary contractors that represent or are acting on behalf of Coalesce. Coalesce’s Anti Bribery, Corruption and Unethical Behaviour Policy has been issued together with policies on gifts and corporate hospitality outlining our parameters in respect of Bribery, Corruption and Unethical Behaviour and is reviewed and re-issued annually.
Employees, temporary contractors/consultants and any companies that we operate with on a subcontract/third party basis are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. A breach of these Policies by employees or temporary contractors/consultants will be treated as grounds for disciplinary action which may result in a finding of gross misconduct.
The success of the Coalesce’s Anti Bribery, Corruption and Unethical Behaviour Policy encourages employees and temporary contractors/consultants to report to the Legal Department, any suspected bribery in accordance with the procedures set out in Coalesce’s Policies. In respect of subcontractors and third parties, employees and temporary contractors/consultants are also encouraged to report any suspicious activity to the Legal Department, in which Coalesce’s Board of Directors will support any individuals who make such report in good faith.
4.0 Whistle-blowing Policy
This procedure outlines the process to follow for a Discloser when reporting a perceived wrongdoing within Coalesce Group of Companies, including something they believe goes against the core values of Coalesce and the Coalesce Group of Companies Code of Conduct. These include the principles of; integrity, objectivity, accountability, openness, honesty, leadership and impartiality.
• Whistle-blowing - where an individual who has concerns about a danger, risk, contravention of rules or illegality provides useful information to address this. In doing so they are acting in the wider public interest, usually because it threatens others, impacts on public funds or breaches local or international law. By contrast, a grievance or private complaint is a dispute about the individual’s own position and has no or very limited public interest.
• Discloser – this is the person who is the whistle-blower. They might be an employee, an Coalesce Board Member, a contractor, a third party or a member of the public.
• Designated Officer - this is the person, appointed by the Board, with overall responsibility for maintaining and operating this whistle-blowing policy. They will maintain a record of concerns raised and the outcomes (but will do so in a form that does not endanger confidentiality) and will report to senior decision makers as necessary. The Designated Officer is the Group Finance Director
• Attributable Concern – something the Discloser has been asked to do, or is aware of, which they consider to be wrong-doing and is in the public interest.
Coalesce is committed to creating a work environment with the highest possible standards of openness, probity and accountability. In view of this commitment, we encourage Disclosers with serious concerns about the work of Coalesce to come forward and voice their concerns without fear of reprisal. Disclosers should note that where the concern is one that might fall under Coalesce’s staff or work force policies on equality and diversity or harassment and bullying or other staff policies, they should consider using the reporting mechanisms for those other policies first. If a member of the public or third party believes that their complaint fits the description of a ‘attributable concern’, they may report their concerns through the whistle-blowing policy procedure.
4.4 Policy Statement
Coalesce acknowledges that Disclosers may often be the first people to realise that there may be something seriously wrong within the organisation.
This policy aims to:
• Encourage people to feel confident about raising serious concerns and to question and act upon their concerns without fear of victimisation or harassment;
• Provide avenues for Disclosers to raise those concerns and receive feedback on any action taken;
• Allow Disclosers to take the matter further if they are dissatisfied with Coalesce’s response; and
• Reassure all Disclosers, employees in particular who may have specific concerns about their position and employment status in Coalesce, that they will be protected from possible reprisals or victimisation if they have a reasonable belief that they have made any disclosure in the public interest.
4.5 What is an attributable concern?
If a Discloser is asked to do something, or is aware of the actions of another, which they consider to be wrongdoing, they can raise it using this procedure. The Discloser must have a reasonable belief that raising the concern is in the public interest.
A Discloser may decide to raise a concern under the whistle-blowing policy if they are aware of a situation that they feel:
• is against Coalesce’s procedures and protocols as set out in its code of conduct;
• falls below established standards of practice Coalesce subscribes to;
• amounts to improper conduct; or
• is an abuse of power for personal gain.
The types of matters regarded as a attributable concern for the purpose of this procedure include, but are not limited to, the following:
• Fraud or financial irregularity;
• Corruption, bribery or blackmail;
• Other Criminal offences;
• Failure to comply with a legal or regulatory duty or obligation;
• Miscarriage of justice;
• Endangering the health or safety of any individual;
• Endangering the environment;
• Improper use of authority; and
• Concealment of any of the above.
Disclosers should not raise malicious or vexatious concerns, nor should they raise knowingly untrue concerns. In addition, this procedure should not be used to raise concerns of a HR/personal nature, such as, complaints relating to a management decision or terms and conditions of employment. These matters should be dealt with using the relevant alternative procedure, equally, this policy would not apply to matters of individual conscience where there is no suggestion of wrongdoing by Coalesce but, for example, an employee or Coalesce Board Member is required to act in a way which conflicts with a deeply held personal belief.
The Public Interest Disclosure Act (1999) gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. Coalesce believes that no member of staff should be at a disadvantage because they raise a legitimate concern. Coalesce will not tolerate harassment or victimisation and will take action to protect Disclosers when they raise a concern in the public interest.
4.7 Raising a concern
If a Discloser experiences something in the workplace which they consider an attributable concern, it is important that the concern is raised as early as possible. Proof is not required at this point – it is for Coalesce to investigate. The Discloser must, however, have a reasonable belief that disclosing the information is in the public interest before raising a concern.
All concerns will be treated in confidence and every effort will be made to protect the Discloser’s identity if they wish to remain anonymous. However, at the appropriate time, it is possible that the Discloser will need to come forward as a witness for the matter to progress.
It is important to follow the correct procedure when raising a whistle-blowing concern. The following steps should be adhered to:
4.7.1 It is important that the concern is raised with the person best placed to deal with the matter, in most cases this will be the Designated Officer. However, the Discloser may want to raise the concern with someone they know and trust, such as their line manager who can raise it with the Designated Officer on their behalf.
4.7.2 If it is suspected that the concern may implicate the line manager in some way, then it could be raised with a more senior manager in the line management chain.
4.7.3 If the Discloser is unable to raise an attributable concern with a line manager or a senior manager or feel that it has not been adequately addressed, it should be raised directly with the Designated Officer.
4.7.4 Ultimately, the Discloser can raise their concern with Coalesce’s Group Managing Director.
4.8 Information needed to raise a concern
When raising a concern under the procedure, the Discloser should try to provide the following information:
• The background and reason behind the concern;
• Whether they have already raised a concern with anyone and the response; and
• Any relevant dates when actions related to the concern took place.
This information should demonstrate that there are reasonable grounds for the concern to be acted upon. It is important that matters are not investigated by the Discloser themselves. If applicable, personal interests must be declared from the outset.
4.9 How the concern will be handled
All investigations will be conducted sensitively and as quickly as possible. While Coalesce cannot guarantee that the outcome will be as the Discloser may wish, it will handle the matter fairly and in accordance with this procedure. Once a concern has been raised with either the line manager or Designated Officer, Senior Manager or Group Managing Director, a meeting may be arranged with them to determine how the concern should be taken forward.
Coalesce may decide to take the matter forward by a number of methods, including:
• An internal inquiry or other formal investigation;
• An internal or external audit;
• Referring the matter to the police;
• Referring the matter to another relevant authority for investigation.
Before a final decision is taken on how to proceed, or as part of the investigation, the Discloser may be asked to meet with those investigating their allegation. If a meeting is arranged, the Discloser may wish to be accompanied by a trade union representative, colleague or friend. The person who accompanies the Discloser should not be involved or have a direct interest in the area of work to which the concern relates. The meeting can be conducted over the telephone rather than face to face.
Within 10 clear working days of a concern being raised, Coalesce’s Designated Officer will write to the Discloser to:
• Acknowledge that the concern has been received;
• Indicate how they propose to deal with the matter;
• Give an estimate of how long it will take to provide a final response;
• Tell the Discloser whether any initial investigation or enquiry has been made;
• Tell the Discloser whether further investigation will be made, and if not, why not;
• Tell the Discloser how frequently Coalesce will keep them up to date on progress of the investigation.
The amount of contact between Coalesce and the Discloser concerned will vary depending on the concern raised, any difficult issues and any further clarity required. If necessary, Coalesce will seek further information from the Discloser.
Coalesce will confirm when the matter is concluded and, if appropriate, the outcome of the investigation, maintaining security and confidentiality for all parties as far as possible.
Throughout any investigation, the Discloser will still be expected to continue their duties/role as normal unless deemed inappropriate.
4.10 Confidentiality and anonymity
Coalesce always encourages potential Disclosers to speak up about potential serious wrongdoing in a way that they feel comfortable. The best way to raise a concern is to do so openly, as this makes it easier for Coalesce to investigate and provide feedback.
Coalesce will respect any request for confidentiality as far as possible, restricting it to a ‘need to know’ basis. However, if the situation arises where it is not possible to resolve the concern without revealing the Discloser (for example in matters of criminal law), Coalesce will advise them before proceeding. The same considerations of confidentiality should be afforded to the recipient(s) at the centre of the concern, as far as appropriate.
Disclosers may choose to raise concerns anonymously, i.e. without providing their name at all. If this is the case, the investigation itself may serve to reveal the source of information. Disclosers are therefore encouraged, where possible to put their names to concerns raised. When anonymous concerns are raised, they will be treated as credible and investigated so far as possible.
If a concern is raised in the reasonable belief that it is in the public interest and procedures have been followed correctly, the Discloser raising the concern will be protected by the terms of this policy and, where applicable, by whistleblowing legislation (see gov.uk for more information on who is covered by whistleblowing legislation). Where a Discloser has been victimised for raising a concern, Coalesce concerned will take appropriate action against those responsible, in line with Coalesce’s disciplinary policy and procedures.
4.12 Untrue allegations
If a Discloser makes an allegation but it is not confirmed by the investigation, no action will be taken against them. However, if a malicious or vexatious allegation is made without good reason to: cause trouble; for personal gain; or to discredit Coalesce an investigation may take place. Where the Discloser is an employee or an Coalesce Board Member or a contractor this may result in disciplinary or other action if they have broken the terms of their employment, acted against Coalesce Code of Conduct or broken a clause in a contract.
In addition, if the Discloser is either unable to raise the matter with Coalesce or is dissatisfied with the action taken they may consider raising it with:
• A relevant regulatory body or professional body
• A relevant Trade Union
• Their solicitor
• The Citizens Advice Bureau
• The Police
Further information and signposting for potential Disclosers is available on www.gov.uk.
If a Discloser does take the matter outside Coalesce to an external body, they should ensure they do not disclose information that is confidential, for example, if you are an employee your contract of employment may set out expectations of your regarding what is confidential.
This policy will be communicated to all employees across the Group, as well as to our suppliers, contractors and business partners and wider stakeholders. Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage through the procedures set out in this “Whistle Blowing Policy”.
5.0 Corporate Responsibility Policy Overview
5.1 Ethics & Beliefs
Coalesce was founded on the belief that, whether on a corporate or a personal level, it is important to recognise that all actions have an impact. It is therefore necessary to ensure that the impact is a positive one by making careful decisions and selecting appropriate behaviours.
That belief is instilled into our culture through our Cultural Framework – this sets clear expectations for all employees, at all levels, to guide them in their everyday decision making. At a corporate level it guides all of our business interactions, strategies and decisions and forms the basis of our CSR policy. This policy sets out our commitments and then translates those into small achievable objectives, which are reviewed on an annual basis.
5.2 Commitments to ethical standards
Compliance with all laws: We expect Coalesce personnel and our clients/suppliers to comply with all national, European Union and International laws and regulations in relation to ethical employment and trading.
Exploitative child labour is eliminated: We believe giving young people opportunities in the working environment is crucial for their development, and would not wish to limit this; however, we believe it must be done subject to national laws on the employment of minors and in any event in a responsible way.
We expect that Coalesce, our clients and suppliers:
• employ no person below the minimum legal age for employment;
• do not employ any young persons (under 18 years) at night or for any hazardous work;
• will make the best interests of the young person a primary consideration where a young person of less than 18 years is employed, and will ensure the employment does not adversely harm the young person’s education, health or physical, mental, spiritual, moral or social development; and
• support and develop policies and programmes that assist any child found to be performing child labour to enable the child to remain in education until no longer a child.
Employment is freely chosen: We expect that Coalesce, our clients and suppliers:
• do not use forced, bonded or compulsory labour and workers are able to leave their employment after reasonable notice has been served; and
• do not require workers to lodge deposits of money to secure their position.
No discrimination is practised: Coalesce, our clients and suppliers must ensure that all workers are treated fairly and with dignity and respect; and that no worker receives less favourable treatment in respect of their employment on the grounds of race, gender, religion or belief, any disability, marital status, national origin, sexual orientation, age or the fact that they are a part time or fixed term worker, or is disadvantaged by conditions or requirements which cannot be shown to be justifiable.
These commitments apply to recruitment of persons from outside the workplace and the treatment of contract workers.
Freedom of association
• All workers must be free to join, or not to join trade unions or similar external representative organisations.
• All workers must be informed and consulted in accordance with national laws.
Working conditions are healthy and safe: We expect Coalesce, our clients and suppliers to:
• provide a healthy and safe working environment for all workers in accordance with international standards and national laws;
• provide access to clean toilet facilities, drinkable water and, if applicable, sanitary facilities for food storage;
• provide a work environment for all workers that is free from health and safety risks as far as is reasonably practical;
• identify hazards at the earliest opportunity and implement the most effective, preventative actions immediately; and
• provide the appropriate level of health and safety information, instruction, training and supervision to all workers as and when required to minimise all risks.
Living wages are paid: We expect Coalesce, our clients and suppliers to:
• ensure all workers receive written understandable information on their contract for services prior to entering assignment and the particulars of their fees for the pay period concerned each time that they are paid;
• ensure that fees paid for a standard working week meet or exceed national legal standards; and
• prohibit deductions from fees as a disciplinary measure.
Working hours must not be excessive
Standard working hours shall comply with national laws and not be excessive.
Regular employment entitlements
Barring legitimate contract engagements, we expect Coalesce, our clients and suppliers to ensure that any work undertaken is performed on the basis of a recognised engagement established through national law and practice.
We expect to meet obligations to consultants under labour or social security laws if applicable, and regulations arising from the regular engagement relationship should not be avoided.
Respect for the individual
We expect consultants to be treated with respect and dignity. Physical or verbal abuse or harassment on the grounds of race, gender, religion or belief, disability, marital status, national origin or age and any threats or other are expressly prohibited.
Coalesce will not support or deal with any business knowingly involved in slavery or human trafficking. Our Directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chains.
5.3 Coalesce Actions
Coalesce has designed and implemented, firstly, a blanket policy which covers every area of our business and secondly, is further tailor-made to the specific business units / employees and temporary contractors that represent or are acting on behalf of Coalesce. Coalesce’s Modern Slavery and Human Trafficking Policy will be issued outlining our parameters in respect of Modern Slavery and Human Trafficking and will be reviewed and re-issued annually.
Employees, temporary contractors/consultants and any companies that we operate with on a subcontract / third party basis are strictly prohibited from engaging in any form of Modern Slavery and Human Trafficking. A breach of these Policies by employees will be treated as grounds for disciplinary action which may result in a finding of gross misconduct. A breach of these Policies by temporary contractors or consultants will be treated as grounds for the termination of the contract held between Coalesce and that temporary contractor or consultant.
The success of Coalesce’s Modern Slavery and Human Trafficking Policy encourages employees and temporary contractors/consultants to report to our Legal Department anything suspicious in accordance with the procedures set out in Coalesce’s Policies. In respect of subcontractors and third parties, employees and temporary contractors/consultants are also encouraged to report any suspicious activity to our Legal Department, and Coalesce’s Board of Directors will support any individuals who make such report in good faith.