Behaviour Policies and Guidelines


The following page includes:

ANTY-BRIBERY AND CORRUPT POLICY

General Principles

Be Talent Limited (the “Company”) strives to undertake our business fairly with honesty and transparency. This must be reflected in every aspect of our business affairs.

This policy affects all our employees and associates.

Good relations with our partners, customers, governments and other stakeholders are one of the keys to our success. We can all help build healthy relationships by behaving honestly, with integrity and with respect for people. Failure to do so erodes trust and undermines the foundations on which we build our lives and our business.

Please do your part by studying this policy and acting in accordance with its guidelines.

The Company is committed to implementing and enforcing effective systems to counter bribery. It is the Company’s policy to conduct all aspects of its business in an honest and ethical manner at all times.

The Law in the UK and Jersey

Under the UK Bribery Act 2010 (the “Bribery Act”), bribery and corruption is punishable for individuals by up to ten years' imprisonment. If any company is found to have taken part in the corruption or lacks adequate procedures to prevent bribery, it could face an unlimited fine and be excluded from tendering for government contracts.

We expect that compliance with the Bribery Act will help with compliance with our international obligations in this regard. However, it is your responsibility to ensure you comply with all local statutory and regulatory obligations.

Policy Aims

The aim of adopting this policy across the Company is to meet the higher requirements of the Bribery Act, and to maintain the highest possible standards of business practice, and advise individuals of the Company’s 'zero-tolerance' to bribery.

Be Talent does not tolerate bribery, insider dealing, market abuse, fraud or money laundering. Facilitation payments are bribes and must not be paid. Any real or potential conflicts of interest (or the appearance of a conflict) must be avoided and inappropriate gifts or hospitality should never be offered or accepted.

Even unsubstantiated claims of corruption can damage reputations and the business.

The guidelines contained in this policy are the boundaries within which every Be Talent employee must operate every day.

This policy applies to all individuals working for the Company and any subsidiary or entity under the control of Be Talent Ltd. Contractors, partners or consultants who are our agents or working on our behalf or in our name will be required to act consistently with the policy.

Policy Statement for Employees, Contractors and Agents

Bribery occurs when you: offer, pay, seek or accept a payment, gift or favour to influence a business outcome improperly. Bribery and corruption, whether involving government officials or commercial entities can be direct or indirect through third parties such as agents and joint venture partners. It includes facilitation payments, even though in some countries facilitation payments are legal. Even turning a blind eye to your suspicions of bribery and corruption can result in liability to the individual or the Company.

You should not:

  • Make or receive contributions of any kind with the purpose of gaining any improper commercial advantage;
  • Provide or accept gifts or hospitality in return for favourable treatment, to influence a business outcome or to gain a business advantage;
  • Make, or accept, “kickbacks” of any kind.

You should:

  • Ensure people you work with understand bribery and corruption is unacceptable;
  • Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage;
  • See that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken. 

Be Talent is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value, or normal and appropriate hospitality.

Gifts and hospitality should never be allowed to influence your business decisions or cause others to perceive an influence.

Business gifts:

  • Receiving promotional gifts of low value is normal and appropriate;
  • Any gift offered and then refused because of its value, must be reported to the relevant officer noted below;
  • Business gifts are primarily aimed at thanking customers and suppliers for their custom and loyalty, only authorised gifts may be given.

Hospitality:

  • The acceptance of corporate hospitality must be transparent; all invitations must be reported to the relevant officer before an employee accepts any invitation. Business and travel expenses incurred and normal business lunches and meals are exempt.

Government Officials:

  • Any gifts or hospitality offered to a government official must have prior approval from the relevant officer;
  • Gifts and hospitality must never be offered to the spouses, family members or guests of a government official;
  • Non-business travel and hospitality should never be offered to any government official.

You should decline gifts or hospitality if you would feel uncomfortable telling your line manager or supervisor, colleagues, family, friends or the public that you have accepted them.

Donations:

  • Relevant company board approval is required before any charitable donations are made;
  • The Company does not make political donations. Such donations may impact our business or reputation.

Competition Law

Be Talent is committed to free, fair and ethical enterprise. You must follow all applicable trade laws and ensure that Be Talent’s core values are applied in all business dealings.

Competition laws protect free enterprise and prohibit behaviour that limits trade or that restricts fair competition such as: price-fixing, market-sharing or bid-rigging. The laws apply to every level of business.

You must not:

  • Agree with others not to compete in particular markets or for particular customers or accounts;
  • Rig bids or tenders;
  • Agree on minimum resale prices with resellers or partners.

Import & Export Controls

Import and export sanction laws give countries legal control over the sale, purchase, shipment, electronic transfer or disclosure of information, software, goods and services across borders.

Controls, sanctions and embargoes can be imposed on countries, entities, individuals or goods.

While in the context of the Be Talent activities it is viewed as unlikely that we would fall foul of these regulations, we endeavour to not knowingly trade in countries or with entities that are subject to controls and sanctions.

Non Compliance

In the event of a breach of the policy by other organisations, or individuals, the Company will take appropriate action which may include terminating any business relationships.

Monitoring

If you have any concerns or require any advice you should talk to:

  • Your line manager or supervisor;
  • Your account manager if you are not an employee;
  • The relevant officer noted below or any other Director or senior manager with whom you feel comfortable having a conversation.

The policy will be monitored on an ongoing basis to ensure that it addresses issues effectively.

The following will be monitored:

  • That all individuals working for the Company are advised of the policy;
  • Assessment of any reported incident or related occurrence.

Monitoring of the policy is essential to assess how effective the Company has been to establish control of its obligations.

This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience.

Compliance Structure

The Board of Be Talent Limited is committed to and has overall responsibility for the policy.

The relevant officers who are responsible for logging matters relating to this policy and giving approvals where appropriate are the following Director:

Managers must ensure compliance by their teams.

All employees should play an active role in ensuring compliance with the policy.

Policy Statement for Partners

The Company only wishes to do business with partners who operate with ethical standards that match international best practice. Be Talent expects its partners to have a ‘zero-tolerance’ approach to bribery and corruption and to abide by sanction orders and trading laws applicable to their business. By accepting Be Talent’s standard terms and conditions each partner confirms that they have appropriate measures in place to prevent such practices. Be Talent reserves the right to request documentation and further assurance in this regard.

Translations of the Be Talent Anti-Bribery and Corrupt Practices Policy into languages other than English are provided for information and convenience. For the definitive and binding version, please refer to the English language version which shall prevail in the case of any discrepancies between it and the translated versions.

© 2017 Be Talent. All rights reserved.


GUIDELINES FOR THE ETHICAL USE OF PSYCHOMETRIC ASSESSMENT INSTRUMENTS

All users of our tools and/or their outputs are expected to follow our guidelines for ethical practice, detailed below.

Communicating with Participants

  • All participants should receive a briefing on the following before completing an assessment or development activity:
  • The nature of the assessment and development questionnaire;

    Why and how the questionnaire is being used;

    It is generally best practice to provide feedback to participants. In the event that participants are to be given feedback this should be provided in compliance with any applicable statutory or regulatory requirements and the participant should be informed when and how the feedback will be delivered;

    How long the participant’s results will be retained for;

    Who will have access to the participant’s results (which will include the test publisher: when the administration is delivered online, participant data is entered on the test publisher’s platform for scoring or the participant data is otherwise submitted to the test publisher for any purpose).

  • Participants should be given ample opportunity to ask questions regarding the process, and receive an honest and professional response;
  • Participants should be invited to reveal any factor which might make the questionnaire less suitable for them (e.g. a disability or poor language skills). If there is a potential difficulty, appropriate adjustments to the process should be made. If the user is uncertain of the steps that should be taken to ensure a fair administration with respect to any participant they should contact Be Talent to seek guidance;
  • Participants should never be forced to undertake a questionnaire– but the consequences of non-participation should be clearly explained (e.g. elimination from the recruitment process or development scheme).

Administration and Use of Data

  • Process should only be used if they are appropriate for the purpose and will provide relevant data. The choice of methods should always be based on the results of an appropriate evaluation;
  • Questionnaires must be administered, scored and interpreted by trained personnel according to the instructions provided by Be Talent in the relevant manuals and related administration materials;
  • Careful consideration should be given before using the instruments with current employees in making promotion and placement decisions where more direct evidence of performance is available (e.g. appraisal reports and other personnel records);
  • Profile reports should only be used by trained users (for interpretation purposes and to provide more detailed feedback to the candidate);
  • Feedback reports are provided by Be Talent in order to deliver feedback to the participant. These reports are self-contained and may be given direct to the candidate. The participant should be given the opportunity of seeking clarification or further explanation with respect to the feedback report should they wish to. It should be noted that any feedback offered to participants should be delivered in compliance with any applicable statutory or regulatory requirements;
  • Data may only be used for purposes previously agreed to by the participant and in accordance with the privacy policy and other terms, contained on the Be Talent Website, manuals and other relevant literature published by Be Talent;
  • Data should always be corroborated and integrated with data from other relevant sources (e.g. structured interviews, work sample exercises, performance ratings, etc.) when used in decision making;
  • Users should check the ongoing validity of instruments. When used with small numbers this should include checks of continued relevance. Where substantial numbers of people are tested, criterion related validation studies should be undertaken which compare the results with data about the individual’s performance in the work place or in other questionnaires;
  • Regular reviews of results and their impact on decisions taken with respect to participants from different groups (e.g. race, gender, age, etc.) should be undertaken.

Security of Materials

  • All materials (including booklets, answer forms and profile reports) must be stored securely and only be accessible to qualified users;
  • Where the qualified user moves from their current employer or department they should, where possible, ensure that any restricted materials are transferred to another qualified user. If there are no qualified users to whom these products can be entrusted you should contact Be Talent to discuss the possible return of unopened resaleable packs of current materials;
  • All data stored (on file or electronically) must be held according to the requirements of any applicable legislation with respect to the storage, use and confidentiality of personal data;
  • It is an infringement of ethical guidelines and of international copyright law to copy, modify, translate or in any way replicate, in whole or in part, the products supplied by Be Talent. The user confirms that all steps reasonably necessary shall be taken to ensure that no Be Talent products under their control will be used in a way that would infringe our copyright or trademarks and will report to us any such infringements that they become aware of.

Responsibility for Competence

  • Users are responsible for maintaining their own level of competence in the use of the Be Talent tools;
  • Users should not offer services which lie outside their competence;
  • Users are responsible for maintaining their knowledge of current legal and best practice requirements regarding the use of the Be Talent tools.

© 2017 Be Talent. All rights reserved.


DIVERSITY STATEMENT

We aim to be:

A diverse company: We want to attract the very best candidates, at all levels, regardless of race, gender, age, physical ability, religion or sexual orientation. We do not set specific, numerical targets for recruitment or promotion of particular groups, but we place great emphasis on ensuring that the pool of applicants for our jobs is diverse.

A fair company: Where pay, retention, promotions and redundancies are determined without discrimination.

A company, which uses diversity to help achieve our commercial goals and targets new opportunities in growing markets.

Our goals are to have diversity at the heart of everything we do and to be at least the best in our industry for diversity. When we say 'diversity', we mean we have a workforce and client base where differences are valued and respected as an essential part of a successful future at Be Talent. To be the best we can be, we need the widest range of minds and imaginations from the widest range of backgrounds right across the company: in every business; in every country; in every job. That's why diversity within the company is a high priority. And the more global we become the more essential it is that we value, and understand, what makes us different.

  • Our assessment tools undergo extensive international review to ensure wide applicability and fairness to all groups. We are transparent with candidates offering clarity of instruction and detailed feedback. For candidates who have little or no experience of assessment we provide knowledge to enable them to compete effectively and fairly.
  • We integrate multiple perspectives into our research, idea generation, consultation and decision making processes, thus increasing the probability of greater fairness, creativity and innovation in all our outcomes.
  • In assessing and developing people for our clients, diversity simply makes good business sense. In order to look beyond boundaries, we acknowledge the unique contribution that all potential candidates and existing employees can bring in terms of their culture, ethnicity, race, gender, nationality, age, religion, disability, sexual orientation, education, experiences, opinions and beliefs.

© 2017 Be Talent. All rights reserved.


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   020 8645 0222