TA-06: Professional Conduct & Ethics¶

Reference: TA-06 | Issue Date: 14/03/2026 | Review Date: Sep 2026 Applicable Standards: ISO 9001 Cl. 7.3 | ISO 45001 Cl. 7.3 Related Documents: HPOL07, HPOL08, HPOL09, HPOL13, HPOL14, HPOL23, HREG04 (L30, L31)

Who Should Read This

All CRGI Solutions staff. This article covers the ethical standards we expect and the legal obligations that underpin them.

Overview¶

CRGI Solutions operates in a professional services environment where our reputation is built on trust, competence, and integrity. This article covers five areas of professional conduct that are both legal requirements and fundamental to how we work: our code of conduct, anti-bribery, modern slavery, equality and inclusion, and whistleblowing.

Code of Conduct¶

Our Code of Conduct (HPOL07) sets the baseline for professional behaviour at CRGI. The core expectations:

Act with integrity — Be honest in your dealings with colleagues, clients, suppliers, and stakeholders
Maintain professional standards — Deliver work to the quality expected of a certified engineering consultancy
Respect others — Treat everyone with dignity, regardless of role, background, or personal characteristics
Protect confidentiality — Don't share client, company, or personal information inappropriately
Declare conflicts of interest — If you have a personal interest that could influence your professional judgement, disclose it
Comply with the law — Follow all applicable laws and regulations, as well as CRGI policies

Anti-Bribery & Corruption¶

The Bribery Act 2010 is one of the strictest anti-corruption laws in the world. It applies to CRGI and to every individual who works for us.

What Counts as Bribery¶

Bribery is offering, promising, giving, requesting, or accepting a financial or other advantage to induce someone to act improperly, or to reward them for doing so. This includes:

Cash payments — Obviously
Excessive gifts or hospitality — Lavish entertainment, expensive gifts, luxury trips
Facilitation payments — Small payments to speed up routine processes (illegal under UK law even where common locally)
Political or charitable donations — Made to gain business advantage
Favours and reciprocal arrangements — "I'll give you this contract if you give us that one"

What's Acceptable¶

Normal business courtesies are fine — a reasonable working lunch, modest promotional items, standard industry hospitality. The test is whether it could reasonably be seen as intended to influence a business decision.

Your Responsibilities¶

Never offer or accept bribes in any form
Declare any gifts or hospitality that could be perceived as excessive
Report any concerns about potential bribery — internally or through the whistleblowing procedure
If someone pressures you to make or accept an improper payment, refuse and report it immediately

CRGI has an "adequate procedures" defence under the Act, which depends on all of us following this policy consistently. One breach puts the entire organisation at risk.

Modern Slavery¶

The Modern Slavery Act 2015 requires organisations to ensure that slavery, servitude, forced labour, and human trafficking do not exist in their business or supply chains.

Why It's Relevant to CRGI¶

You might think modern slavery doesn't touch a virtual engineering consultancy. It can. Our supply chain includes IT equipment manufacturers, cloud service providers, and subcontracted services — all of which have extended global supply chains where exploitation can occur.

What to Watch For¶

Signs that someone may be a victim of modern slavery or forced labour include:

Appearing malnourished, unkempt, or withdrawn
Seeming under the control of others or unable to speak freely
Living and working in the same place
Having no access to their own identity documents
Working excessive hours with little or no pay
Appearing fearful, anxious, or reluctant to seek help

Your Responsibilities¶

If you encounter any indication of modern slavery in our supply chain or at client sites, report it immediately
We assess all suppliers against modern slavery criteria as part of our supplier approval process (HPROC08, HPOL14)
CRGI publishes an annual Modern Slavery Statement (HPOL13)

If you suspect someone is a victim of modern slavery: contact the Modern Slavery Helpline on 08000 121 700 or report through CRGI's internal channels.

Equality, Diversity & Inclusion¶

The Equality Act 2010 (as amended by the Worker Protection Act 2023) protects people from discrimination based on nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

What We Expect¶

Equal treatment — Everyone at CRGI is treated on merit, regardless of personal characteristics
Inclusive language — Be mindful of the language you use in communications, documentation, and meetings
Reasonable adjustments — If you have a disability or condition that affects your work, we will make reasonable adjustments to support you
Zero tolerance for discrimination — Direct or indirect discrimination, harassment, and victimisation are disciplinary matters

Bullying and Harassment¶

Bullying is behaviour that intimidates, degrades, humiliates, or offends. It doesn't have to be related to a protected characteristic to be unacceptable. In a remote team, it can take forms like: persistent undermining in group calls, exclusion from communications, unreasonable criticism of work, or intimidating messages.

Harassment is unwanted conduct related to a protected characteristic that violates someone's dignity or creates an intimidating, hostile, or offensive environment.

If you experience or witness either, report it. You can speak to Sean Ashton, Dragos Ciordas, or use the whistleblowing procedure.

Whistleblowing¶

CRGI's Whistleblowing & Raising Concerns Policy (HPOL23) provides a safe route for reporting serious concerns without fear of retaliation.

What You Can Report¶

Criminal offences (including bribery and fraud)
Failure to comply with legal obligations
Health and safety dangers
Environmental damage
Deliberate concealment of any of the above

How to Report¶

Internally — Raise with Sean Ashton or Dragos Ciordas
If you can't raise internally — Contact the relevant prescribed body (e.g. HSE, Environment Agency, ICO, or the Serious Fraud Office depending on the concern)
Anonymously — You can raise concerns anonymously, though it's harder for us to investigate without being able to ask follow-up questions

Protection¶

You are legally protected from dismissal or detrimental treatment for making a qualifying disclosure under the Employment Rights Act 1996 (as amended). CRGI will never penalise anyone for raising a genuine concern in good faith, even if it turns out to be unfounded.

Key Takeaways¶

Act with integrity in everything you do
Never offer or accept bribes — when in doubt, declare it
Be alert to modern slavery indicators in our supply chain and at client sites
Treat everyone equally and with respect
If something isn't right, speak up — we protect those who do

CRGI Solutions HSQE Department | HSQEMS v2.0 | Classification: CRGI Information