Code of Ethics
Definitions
Associated parties: these are persons and entities to which the policy applies as defined in the section on applicability above, namely:
+ TSG contractors
+ TSG consultants
+ TSG partners
+ TSG owned entities
+ TSG suppliers and vendors
+ TSG Agents
+ TSG Advisors
+ All other entities or individuals acting for or on behalf of TSG in any way
Statement of Intent
TSG is a provider of Research and Ethics advisory services. It is essential for both TSG’s reputation and the reputation of our clients that we operate at all times to the highest ethical and legal standards.
The code of ethics and business conduct (The Code) must be read in conjunction with our anti-bribery and anti-corruption policy, Whistle blowing policy, and other related policies.
It is not anticipated that there would ever be a conflict between the Code and any law in any place where TSG operates, but should that situation arise TSGs Board will take expert advice where needed and give guidance as to the proper course of action in the particular circumstances.
Applicability
The Code gives guidance in all matters related to the conduct of TSG’s business, whether by TSG’s employees, consultants, subcontractors or other associated parties.
The Code applies to every TSG director, shareholder, employee or associated party at all times and in all situations. Exceptions to its principles will only be allowed in exceptional circumstances by the Board of TSG (“Board”).
Governance
This Code has been reviewed and approved by the TSG Board of directors (“Board”).
The Code will be reviewed and re-approved by the Board no less than annually.
The Code’s owner is TSG’s COO. The COO will ensure that it is up to date at all times, and properly reflects changes to applicable laws, regulations, risks, and industry standards.
Knowing Our Code
TSG, employees are required to read and understand the code. They are trained to understand that the Code is not intended to, and cannot, address every situation they might encounter. Accordingly, they are taught to apply the principles (the spirit) underpinning the Code as well as the written text of the Code.
TSG requires all other parties subject to the Code to apply the same adherence to its principles, and not just to the written text.
Applying The Code
All TSG employees and associated parties are required to comply with all relevant laws and regulations in whatever country or situation TSG’s business necessitates.
TSG recognises, however, that not all decisions are simple black and white decisions. What may be legally compliant may be unacceptable from a business ethics standpoint. TSG employees and associated parties are expected to recognise where legal considerations on their own are not enough, and where integrity is reached via a combination of both legal and ethical standards.
TSG takes any breach of the Code seriously. Employees who fail to abide by our code may face disciplinary action, up to and including dismissal.
Speaking Up- Escalating & Investigating Potential Breaches of The Code
TSG has in place whistle blowing procedures that allow and party subject to the Code, as well as any external party not subject to the Code, to escalate potential breaches of the Code to relevant TSG management for investigation.
In addition to formal whistleblowing channels, any individual on their own behalf, or as a representative of an organisation, is encouraged to bring knowledge of a potential breach of the Code to TSG management attention. This may be done by email directly to the TSG CEO.
TSG strictly prohibits acts of retaliation against any employee or other party who provides information honestly and in good faith, or assists in any investigation, in connection with a possible breach of the Code.
All escalations in response to the Policy will be investigated thoroughly and expeditiously. All employees are required to co-operate fully with investigations.
At the conclusion of any investigation a written report will be delivered to the CEO who will, based upon the findings and recommendations of the report, direct the next course of action. This may include external reporting to a government authority, informing external parties (such as clients) of the report findings, or taking disciplinary action against TSG parties.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Lorem ipsum dolor sit amet, consectetur adipiscing elit. In volutpat augue turpis, eu congue tellus ornare et. Nulla ornare a turpis vel blandit. Proin sit amet urna non enim mollis semper sed sit amet felis. Nulla elementum bibendum hendrerit. Sed justo urna, egestas a magna quis, molestie dignissim mi. Orci varius natoque penatibus et magnis dis parturient montes, nascetur ridiculus mus. Cras id eros quis purus dictum bibendum quis sit amet lacus. Vestibulum hendrerit est id ultrices tincidunt. In viverra, metus quis mollis convallis, tellus enim hendrerit ante, sit amet mollis felis quam eget eros.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.