Last updated: September 2020

Background and overview

This Code of Conduct has been created to help the reader understand our core values, principles and the behaviours expected to support them. It provides guidance and support for every GSG employee and anyone who works with GSG in any capacity.

GSG Mission and Objectives

The GSG is an independent global steering group promoting sustainable development and advancing education in impact investment. The GSG was established in 2015 as the successor to, and incorporating the work of, the Social Impact Investment Taskforce established under the UK’s presidency of the G8.

The GSG currently has over 30 member countries, each with National Advisory Boards (NABs), and strategic partnerships with leading global organisations. It is an organisation of over 500 senior people. The GSG brings together leaders from the worlds of finance, business, government, and philanthropy.

The GSG, a British charity, aims to bring solutions to social and environmental challenges through education by spreading the use of impact approaches in making philanthropic, business and investment decisions.

Under the leadership of its Chair and a growing professional team, directly and through its NABs, in coordination with strategic partners, GSG drives the implementation of impact policy and catalyzes important initiatives directly country by country, and also by working with multilateral bodies.

The GSG was registered as a charity with the Charity Commission for England and Wales (no. 1175658) in November 2017.  As a philanthropically-funded organisation, we have a duty to ensure that wherever possible we aim to seek the best value for all our expenditure.   In addition charities, and those who work for them and with them, should uphold the highest level of institutional integrity and personal conduct at all times.

The GSG is a member of the UN Global Compact which means that as an organisation  we commit ourselves to making the UN Global Compact’s mission and its ten principles part of the strategy, culture and day-to-day operations of our company.  These ten principles are listed at the end of this Code and cover human rights, labour, the environment and anti-corruption.   This Code has been prepared being mindful of these principles.

Our responsibilities

Everyone in  or working with our  business has particular responsibilities, including:

• Leading by example
• Promoting and role-modelling good ethical behaviour and business conduct including complying with all laws and regulations
• Promoting an environment where all stakeholders feel confident and able to raise ethical concerns and that they are taken seriously and followed
• Zero tolerance approach to any form of unacceptable or inappropriate behaviour

While this Code gives you guidance for certain situations there are specific areas where we have a zero tolerance policy:

• Unsafe, illegal or unethical working practices
• Violence and aggression
• Discrimination, bullying and harassment
• Bribery and corruption
• Retaliation against anyone who speaks up and does the right thing

Every GSG employee or anyone who works with GSG in any capacity must comply with our Code. You must make time to read and understand this document. If you have any questions, or need advice please speak to the CEO or CFO.

Principles

Principle 1: Honesty, Integrity and Fair Play

The Company and its staff are fully committed to the principle of honesty, integrity and fair play in the delivery of all that the organisation does. All staff should ensure that the business operations including procurement and staff recruitment, are dealt with in an open, fair and impartial manner.    This also applies to temporary and part-time staff employed by the Company.

Principle 2: Equal Opportunity for All Employees

The company is an equal employment opportunity employer. Employment opportunities are available regardless of race, colour, sex, religion, national origin, age, disability or other legally protected status. This Principle applies to all aspects of the employment relationship, including recruiting, hiring, training, work assignment, promotion, termination, and wage and salary administration.

Principle 3: Safety, and Health Practices

The company is committed to an injury-free and illness-free workplace that is operated in an environmentally sound manner in compliance with all relevant laws and regulations that protect worker safety and the environment. Employees should perform work in a safe manner.

For further information please see the Health and Safety Policy.

Policies

The following are the specific policies that the GSG has in place to apply the above principles.

Anti Bribery & Corruption

We are fully committed to instilling a strong anti-corruption culture and compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“the Act”).   Accordingly we have procedures in place to monitor that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

Please see our Anti Bribery & Corruption policy for further details.

Whistleblowing

GSG has a strong commitment to integrity and ethical behaviour and encourages staff or stakeholders who have concerns about suspected serious malpractice or misconduct or any breach or suspected breach of law or regulation that may adversely impact the company, to voice those concerns without fear of harassment or victimisation.

GSG also provides information on a specialist mailbox that employees can report or raise any suspicions or allegations, in regards to whistleblowing and / or fraud surrounding the DFID grant.  GSG will provide training so that staff fully understand all varieties of what constitutes fraud.

Please see our Whistleblowing policy for further details.

Diversity, equality and inclusion

We promote a diverse, inclusive and equal workplace both internally and externally. Every employee is expected to treat everyone with whom they have contact with dignity, courtesy and respect.

We hire, promote and reward our employees based on their capabilities and skills. Gender, race, colour, ethnic or national origins, marital status, family circumstances, age, disability, sexual orientation, political or religious belief are not relevant to personal and team performance at work.

Our employees have the right to work in a safe environment free from discrimination, bullying or harassment.

We support and uphold human rights principles and international standards. We will not tolerate, engage in or support the use of, forced or child labour. This expectation extends to all our business partners and suppliers.

Please see our modern slarvery and human trafficking policy for further details.

Conflict of Interest

All employees are expected to:

• notify the CEO of any conflicts of interest during the referencing process and update on any that occur throughout their employment at GSG:
• devote all their available working hours, skill, attention and labour to the performance of their duties;
• not use or disclose any trade secrets or other information of a confidential nature relating to the Company, its business, donors or officers during your employment. (Information of a confidential nature includes but is not limited to, business plans, communication and marketing plans, proprietary research, contact lists)

This obligation will continue after the termination of employment unless and until any such information comes into the public domain other than through any breach of this clause.

Examples of conflict interest are set out below (but are not limited to):

• Employees’ ability to use their position with the company to their personal advantage
• Employees using connections obtained through the company for their own private purposes
• Employees using company equipment or means to support an external business
• Employees acting in ways that may compromise the company’s legality (e.g. taking bribes or bribing representatives of legal authorities)
• Taking advantage of confidential information learned on the job for your own benefit

All Trustees are given the opportunity to raise conflict of interests at regularly held Board meetings.

All contracts with third party suppliers will also require notification of conflicts of interest when agreed

Harassment Policies

The GSG has a firm commitment to equality of opportunity and as such will not tolerate the harassment or bullying of any member of staff, including contractors and temporary staff by other staff members or external suppliers.

We have a full  policy available which details how we handle all discipline and grievances within the business. We also have Bullying and Harassment policies (including Sexual Harassment)

Hospitality and Gifts

GSG has a duty of care to protect the reputation of the company and employees from accusation of impropriety in terms of hospitality and gifts. We also work to ensure that all clients and suppliers are dealt with on an equal basis, and avoid any potential conflicts between employees’ private interests and professional duties.

We as a business want to instill a strong anti-corruption culture in the Company and put in place a gift and hospitality monitoring process to further compliance with the Bribery Act 2010.

Please see our Hospitality & Gifts policy for further details.

Employee Data Protection

We follow the GDPR regulations in terms of how we maintain and store employees personal data and information.

For further information please see the Employee Data Protection Policy.

Sustainability

We believe that developing a sustainable business is not only the best way to help look after our environment, but also contributes to delivering a successful and ethical company.

Our environmental impact is relatively small, but we all still have a responsibility to look after it.

For our staff and partners, this can be an important issue as an increasing number seek to do business only with companies who have a clear understanding of their impact, and have policies in place to try and reduce their impact.

Corporate Social Responsibility

Corporate social responsibility (“CSR”) refers to the way in which businesses regulate themselves in order to ensure that all of their activities positively affect society as a whole. CSR policies aim to guarantee that companies work ethically, considering human rights as well as the social, economical and environmental impacts of what they do as a business.

GSG are committed to ensuring any business undertakings are conducted as ethically as possible by following our CSR policy.

For further information see the full CSR policy.

Environmental Policy

GSG is committed to providing a safe and healthy workplace for our employees and minimises 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.

Our Policy therefore, is to:

• integrate the consideration of environmental concerns and impacts into our decision making and activities,
• minimise our waste and then reuse or recycle as much of it as is possible;
• minimise energy and water use in order to conserve supplies and minimise the consumption of natural resources;
• as far as is possible, purchase products and services that do the least damage to the environment;
• train, educate and inform our employees about environmental issues that may affect their work; and
• promote environmental awareness among our employees and partners and encourage them to work in an environmentally responsible manner

Recruitment

The GSG is an equal opportunities employer, which means that we are committed to providing equality of opportunity in employment to all persons.

When recruiting new employees or when affording our current employees with opportunities for promotion, it means that we will:

• follow the good practice recommendations of the codes of practice and other guidance issued by the Equality Commission;
• not discriminate unlawfully against any person;
• select the best person for the job in terms of qualifications and abilities

Please see our recruitment policy for further details including the selection and interview process.

United Nations Global Compact

The GSG is a member of the UN Global Compact which means that as an organisation we commit ourselves to making the UN Global Compact’s mission and its ten principles part of the strategy, culture and day-to-day operations of our company.  These ten principles are set out below:

Human Rights

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2: Make sure that they are not complicit in human rights abuses.

Labour

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labour;

Principle 5: the effective abolition of child labour; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

Principle 7: Businesses should support a precautionary approach to environmental challenges;

Principle 8: undertake initiatives to promote greater environmental responsibility; and

Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

We recognize that a key requirement for participation in the UN Global Compact is the annual submission of a Communication on Progress (COP) that describes our company’s efforts to implement the above Ten Principles.

We support public accountability and transparency, and therefore commit to report on progress within one year of joining the UN Global Compact, and annually thereafter according to the UN Global Compact COP policy. This includes:

• A statement signed by the chief executive expressing continued support for the UN Global Compact and renewing our ongoing commitment to the initiative and its principles. This is separate from our initial letter of commitment to join the UN Global Compact.
• A description of practical actions (i.e., disclosure of any relevant policies, procedures, activities) that the company has taken (or plans to undertake) to implement the UN Global Compact principles in each of the four issue areas (human rights, labour, environment, anti-corruption).
• A measurement of outcomes (i.e., the degree to which targets/performance indicators were met, or other qualitative or quantitative measurements of results).

All of our company policies are available on our company drive. If you do not have access please speak to the CFO or CEO.