ALL AOC's Employees,
Honesty, Transparency and Integrity is at the core of the business of the ACE Group,
it is the common thread through all our activities. The purpose of this Manual is
to lay down our rules of behaviour in all our dealings for the ACE Group and to
provide guidance in our day-to-day business.
These rules apply to all employees of the ACE Group. Our joint venture partners,
agents, intermediaries, consultants and subcontractors shall also be required to
comply with them. It is the responsibility of all of us, at all levels of our organization,
to comply with, and live by the rules set out in this manual. No deviation can or
will be tolerated and no employee will suffer any adverse consequence for having
complied or for reporting suspected violations.
This manual reflects the Business Principles for combating Bribery issued by Transparency
International and Social Accountability International and is also an expression
of our values and standards. The following basic principles should be applied:
- Do not do anything which you know or believe to be illegal or unethical.
- Do not use any Company property for your own benefit.
- Do not engage into any transaction which does not have a genuine, legitimate business
purpose.
- Ask yourself whether any contemplated transaction or business practice would withstand
the scrutiny of the public eye if exposed.
- Do not do anything which could require you to be untruthful.
- Seek advice when in doubt.
PROFESSIONALISM
All our services must be provided in a professional, independent and impartial manner,
honestly and in full compliance with Group approved methods, practices and policies.
We do not surrender to any pressure from clients in one area of our business in
order to obtain a favorable treatment in another area.
All findings and results shall be accurately documented and not be improperly changed.
Reports and certificates shall reflect these results and findings and the professional
opinions obtained.
ACCURATE RECORDS
All transactions must be properly and accurately recorded and all book entries supported
by proper documentation issued by bonafide parties.
All records must be retained in accordance with applicable laws and Group policies.
IMPARTIALITY
Situations where the interests of the ACE Group diverge from your own personal interests
or those of your close relatives or of persons with whom you are in close personal
or business contact must be avoided because they can influence your judgment, even
without your noticing it. Even, the mere appearance of conflicts of interest must
be avoided because it creates the impression of lack of impartiality.
The following are examples of conflict of interest situations which must be avoided:
- Rendering services to a client in which the ACE Group has a direct or indirect interest.
- Taking personal advantage of a business opportunity for the ACE Group or using company
property or company resources for personal purposes.
- Accepting, directly or indirectly, any kind of personal advantage granted by reason
of employment with the ACE Group, except for socially acceptable gifts and hospitality.
- Taking any interest in a supplier, client or competitor of the ACE Group except
for publicly traded securities to an extent which does neither grant significant
influence nor create undue dependence and subject to reporting this interest.
- Holding an office or any kind of position with, or performing services for, a competitor
or client other than in the performance of your duties for the ACE Group.
- Accepting an office or any employment outside the ACE Group without having obtained
clearance.
- Conducting any ACE business with a close relative or with an organisation with which
you or one of your close relatives is associated.
- Employing a relative without having obtained clearance.
INAPROPRIATE BEHAVIOUR
Inapropriate behaviour may be neither granted nor accepted, whether directly or
indirectly.
Inapropriate behaviour can be considered to be advantages granted to influence governmental
or corporate decisions or actions in violation of duty. They may take the form of
bribes, gifts, excessive entertainment or kickbacks. They also include political
contributions unless they are disclosed, comply with local law and have obtained
prior clearance.
Inapropriate behaviour is usually evidenced by agents, intermediaries, consultants
or contractors claiming to perform a bona fide service or by joint venture partners
or suppliers. We therefore do not deal with these parties if we know or have reasons
to believe that they engage in granting improper advantages. In addition, in order
to prevent any misuse of funds, all payments for goods or services must be made
to the person who supplied them and cash payments must be avoided and may be made
only in accordance with Group policies. Clearance must be obtained for the remuneration
of agents, intermediaries and consultants.
Gifts, hospitality and entertainment must always be related to a genuine business
purpose. They may not be intended or appear to be intended to influence a decision
or action and must be kept within what is socially acceptable and legally permissible.
For charitable contributions or sponsoring of events, prior clearance must be obtained.
Facilitation payments are modest payments customary in certain countries to expedite
the performance of routine actions which the proposed recipient has a clear and
non-discretionary obligation to perform. Facilitation payments must be minimised
and avoided wherever possible. They may only be made if there is a clear entitlement
to the action to be performed and must be appropriately accounted for.
WORK RELATIONS AND ENVIRONMENT
The ACE Group is committed to providing a safe, healthy and respectful work place
and fair working conditions to all its employees. No discrimination or harassment
based on race, gender, national origin, disability, sexual orientation or age will
be tolerated.
All employees are expected to respect their fellow employees. Sexual harassment
and bullying are unacceptable practices which have no place in a work environment.
Employees must also be open, transparent and truthful in dealing with their fellow
employees, subordinates and superiors.
FAIR COMPETITION
We recognise the benefits of a free market economy and of competition as the optimal
way to allocate resources, but we accept that we have to compete fairly within the
framework of the applicable competition laws.
We never engage in discussions or enter into agreements with competitors on prices
and market allocations. We do not exchange competitive information.
We conduct our marketing, including any references to our competitors or their services
or to third parties, in a manner which is truthful, and neither deceptive, nor misleading
or likely to mislead. We present ourselves in a fair manner and ensure that presentational
information, including descriptions of our network and affiliations, resources employed
and services provided is accurate and unambiguous.
CONFORMITY WITH RULES AND REGULATIONS
We are committed to fully comply with the laws of the countries where we do business.
Each employee is responsible to ensure this compliance and to secure the legal assistance
which may be needed.
INSIDER TRADING
All employees shall abstain from trading in securities issued by ACE SA while in
possession of confidential information which has not been publicly disclosed but
which would, if disclosed, have a substantial impact on the price of the ACE shares
or derivatives. They shall also abstain from passing any such confidential information
to any third party.
CONFIDENTIALITY
Openness and transparency are essential values in the ACE Group. In certain cases,
these values must be balanced against a duty of discretion. Indeed, some information
must be protected to safeguard the rights of our clients, partners or staff or our
own business interests. This includes any information which is not available to
the general public and which there is an interest to keep confidential, such as:
- Information relating to the business of the ACEGroup, including details of clients,
market or financial data, methods and processes.
- Information imparted by third parties under obligations of confidentiality.
- Information relating to personal data of employees.
This confidential information must not be disclosed to others and may not be used
for personal benefit. When confidential information relating to the business of
the ACE Group must be disclosed in the course of business, all measures must be
taken to protect its confidentiality. Confidential information relating to others
may only be disclosed with the approval of the person or entity involved.
OPERATION
The ACE Manual has been issued by the Board of Directors of the Group, who shall
issue rules as required. Select appointees oversee the implementation of the rules
and the Head Human Resource Manager co-ordinates it and provides guidance to management
and employees.
Each employee is responsible to comply with the manual in his/her area of activity.
All employees shall be informed about these rules as contained in the manual and
shall receive training on integrity issues.
Any report or request for clearance or advice under the Manual should be addressed to
the Human resource Manager in the respective country of operation. You should
also report any suspected violation of the rules as well as any solicitation from
a third party or offer by a third party to you of an improper advantage, to the
Human Resource Manager or to any other member of management. Unless you have violated
the rules or are acting maliciously or in bad faith, and to the extent that we are
able to, we will protect you against any form of reprisal and will keep your identity
confidential at your request.
You may make suggestions on the implementation of the rules at any time by submitting
comments to the Human Resource Manager or to any other member of management.
You may contact the Head of Human Resource for the Group at your choice by post,
telephone, fax, e-mail or by using our hotline :
Head Human Resource
ACE GLOBAL LTD
Geneva Branch
1, Rue Richard Wagner
1202 Geneva
Switzerland
Tel: +41 22 919 9111
Fax: +41 22 919 9119
E-mail: aceglobal.geneva@ace-group.net