Ethics

Summary

• Respect for clients, team members and people we interact with. We treat people with dignity, and respect and lead by example. We welcome differences in people, ideas, and experiences and use them as learning opportunities.
• Our services must add value to our customers. We put our customers first, we service their wants and needs and help identify blind spots. We exceed their expectations by playing a partnership role.
• Strive for Excellence in every delivery. We are a high-performance, high-delivery team and expect the best from ourselves. We own our work and results.
• Act with Integrity. We are honest, fair, and objective. We comply with all laws and follow our ethics policies without fail.

Why We Have a Code?

IRL is a market leader in data science technology. We are constantly evolving. We make many decisions every day, and as we grow the right thing to do may not always be clear. Our Code of Ethics can help us make decisions that earn and build trust. It tells us about the behaviours we expect of each other and where to get more information or support.

Our Code reinforces that IRL Consulting is committed to:

• Complying with the laws and regulations in all locations where we operate. Because we are an RSA company operating globally, our clients around the world often are subject to additional legal requirements.
• Maintaining our Code when local laws or policies are not as strict. If you believe our Code conflicts with local/regional law, please raise it with a Director for guidance on what to do.

Who is our Code of Ethics for?

Our Code applies to all employees and directors of IRL Consulting and associated businesses including subsidiaries and contractors. We expect our suppliers, vendors, service providers, and other business partners to act with integrity and honour our values. Specific requirements for these third parties are included in the Standards for Suppliers and/or in our contracts with them.

Staff who violate our Code may be subject to discipline, up to and including termination.

When to Speak Up?

Building trust requires we do the right thing and speak up if we have questions or concerns. If you don’t know the right thing to do, ask for advice from your manager or speak to one of the directors.

Ethics & Compliance can provide you with an opinion on the right action to take. Make your voice heard and get the answers you need. If you see, suspect, or are told about an activity that violates our Code, compliance policies, the Standards for Suppliers/Customers, or the law, you must report it.

Looking the other way or letting someone else take the lead may seem easier, but unethical or unlawful behaviour hurts us all. It erodes trust. Report your concerns and cooperate fully and honestly in all internal investigations.

How to Speak Up?

We are a growing company. Our ethics will stay with us as we grow. Most concerns can be reported to your manager, a director, team leader or anyone in a position to take your concern up the chain of command. If your concern is about one of the following, it must be immediately reported directly to a Director: 

• Bribery (including any suspected violation of our Anti-Corruption Compliance Policy)
• A company officer or direct report to any company CEO potentially violating our Code
• Falsifying financial records or interfering with our internal controls on accurate financial reporting Global or local policies may indicate additional matters that must be reported directly to a Director.

*All reports about Ethics & Compliance are treated as confidentially as possible.

Make Ethical Decisions

We build trust when we make decisions consistent with our values and take responsibility for our actions. Being ethical means doing the right thing even when no one’s watching.

Integrity in Action

• Follow the law. Learn about the laws that apply to your role and our business.
• Know our Code and live our values. Review our Code and understand how it and our policies apply to your job. Staff must acknowledge that they have read and understood it.
• Act in IRL’s best interest. Never allow personal interests to impact the business decisions you make as an IRL employee.
• Be honest. Be transparent and make decisions that reflect our values.
• Lead by example. Talk about our Code and our values with your fellow associates and team members.
• When in doubt—reach out. If you have questions or concerns, let somebody know.

Recognize and Avoid Conflicts of Interest

Fair and objective decisions build trust with our colleagues, customers, and third parties. When making business decisions, we put IRL’s interests before personal interests. A conflict of interest occurs when personal interests interfere with or may appear to interfere with, our work at IRL. While we can’t list every circumstance, it’s important to know and avoid the common situations that could create a conflict or the perception of a conflict.

Outside employment, financial investments, gifts and entertainment, and personal relationships are areas where conflicts can arise. If you realize an activity or situation could influence or appear to influence your ability to make objective business decisions, let your manager, team leader or Director know. They can help you take steps to avoid or resolve a conflict.

1. Outside Employment and Business Interests

   • Do not work for a competitor or customer while you are a staff member at IRL. Contract staff should discuss with their managers to determine if a conflict exists before accepting employment with a competitor or customer.

2. No side business activities are permitted unless passed by the Board of Directors.

   • If approved no side business may interfere with your work at IRL or use IRL resources, including any and all data/customers/contacts/suppliers associated with or previously associated with IRL. It cannot supply products to IRL, supply products to any current or potential IRL supplier with whom you have a business relationship or influence, compete with IRL, or reflect negatively on ILR.

3. Global Conflicts of Interest Policy

   • While working for IRL, you may identify a business or investment opportunity that IRL may have an interest in pursuing. Do not take opportunities for yourself that you discover through your position or the use of IRL property or information.

4. Financial Investments

   • Do not invest in an IRL supplier if you can influence IRL’s relationship with that supplier.

   • Do not have a substantial interest (for example, stock ownership) in a competitor.

5. Gifts and Entertainment

   • Decline gifts and entertainment from a supplier if you work with or could work with that supplier in your IRL role. Accepting any benefit from suppliers that we work with can cause a conflict and drive up the cost of doing business.

   • Explain our policy on gifts and entertainment to new suppliers.

   • Our policy on gifts and entertainment applies everywhere we do business.

   • Decline gifts and entertainment from any government official.

6. Family

   • Do not supervise or be directly involved in the hiring of a family member.

   • Do not influence the conditions of employment (for example, pay, work hours, or job responsibilities) or the performance rating of any family member. In certain rare circumstances, the company allows family members to work in the same team if there is enough separation.

   • If you learn that a family member is being considered for employment or is hired into your area of responsibility, you should disclose this to your manager, team leader or Director.

     • A family member is any relative (spouse, child, parent, sibling, grandparent, or grandchild) by birth, adoption, marriage, domestic partnership, or civil union as well as any member of your immediate household, regardless of whether you are related.

7. Romantic

   • Do not have a romantic relationship with another staff member if the employee is in your area of responsibility or you have influence over their conditions of employment or performance rating. If an employee with whom you already have a romantic relationship comes under your supervision due to a change in organizational structure, you should immediately disclose the relationship to your manager, team leader or Director.

   • A romantic partner is someone you are dating or with whom you have a sexual relationship.

8. Supplier Relationships

   • If a close personal friend, family member, or romantic partner works for a supplier /customer over which you have influence, disclose it to your manager, team leader or Director to get advice on managing the potential conflict.

   • Before participating in the selection of a supplier which employs your family member, close personal friend, or romantic partner, disclose the relationship to a manager, team leader or Director to get advice on how to manage the potential conflict.

Create a Safe Place to Work

• Don’t work under the influence. Alcohol and improper use of drugs can affect your work and the safety of people around you.
• Zero tolerance for violence and threats. Immediately report concerning behaviour to a manager, team leader or Director.
• Follow health and safety laws and our policies.

Respect Each Other

Living our value of Respect for the Individual starts with valuing diversity and inclusion. We believe having staff with different backgrounds, styles, experiences, identities, and opinions makes us a better company. Inclusion is an intentional act—it is investing time and energy to understand, support, and champion the uniqueness of individuals. Diversity and inclusion promote individual expression, creativity, innovation, and achievement—and help us better understand and serve our customers.

We are committed to a workplace that is free of harassment and discrimination. We do not tolerate any behaviour that diminishes the dignity of a person, inappropriately or unreasonably interferes with work performance, or creates an intimidating, hostile, or otherwise offensive work environment based on an individual’s identity status. We also do not tolerate retaliation against anyone who raises a concern about harassment or discrimination.

• Treat others how they want to be treated. Be fair and respectful to colleagues, customers, members, suppliers, and third parties who work with IRL. Value others’ differences and listen to different points of view.
• We hire and promote the right way. IRL hires, retains, and promotes employees based on qualifications, demonstrated skills, achievements, and other merits.
• Prevent harassment. Set the right tone and expectation for appropriate behaviour with your team members and peers. Verbal, visual, or physical conduct of a sexual nature is not acceptable.
• Lead by example. Be inclusive with your actions and words. Understand how your actions and comments may be perceived or misunderstood by others. Set clear expectations with your team.
  • Follow harassment and discrimination laws and our policies. Know what behaviours are considered harassment or discrimination and create a respectful and inclusive workplace.
• Speak up. Never tolerate harassment or discrimination. Report harassment or discrimination to your manager, team leader or Director.

Compete Fairly

At IRL we believe success comes from offering quality products and services through free and fair competition. Anti-competitive practices harm our customers. Fair competition leads to stronger innovation and better quality.

Compete independently from our competitors.

• Don’t share sensitive information with competitors such as pricing, costs, bid submissions, or strategic plans.
• Don’t make agreements with competitors or others that limit competition. For example, don’t agree on price, terms of sale, assortment, margins, promotions, or allocation of products, customers, or markets.
• Interact with suppliers and other third parties the right way. We must be careful to not seek out or pass along confidential information about our competitors via our suppliers. We also must not share confidential information about our suppliers with other suppliers. If confidential information or an improper agreement comes up, stop the conversation. Make it clear you don’t want to participate and report the incident.
• Conduct market research properly. Never encourage anyone to improperly give you confidential information.
• Be honest and accurate. Always be truthful in pricing, marketing, and advertising.
• Sell products the right way. Honest and accuracy is key. Never attack a competitor’s product.
• Seek guidance. If you are ever unsure whether a conversation or agreement is okay, ask for advice.
• Follow competition and consumer protection laws and our policies. Know the antitrust and consumer protection policies and procedures that apply to your role and follow them.
• Report suspected violations to a manager, team leader or Director.

Never Engage in Bribery

IRL competes fairly and honestly everywhere we do business around the world. We never attempt to gain a business advantage through bribery, and we do not tolerate bribery or corruption in any form.

• Do not offer or accept bribes. Laws in some countries make a distinction between bribing a government official and bribing a non-government official. We don’t rely on those distinctions. For us, it is simple, bribery—of anyone, at any organization, at any level—is wrong.
• Third parties must not pay bribes. Any person or company working on IRL’s behalf may not offer, give, or receive a bribe. If the only way to make a deal or complete a service for IRL is through payment of a bribe, we expect third-party service providers to refuse and to report it. Bribes are not how we do business.
• Engage Anti-Corruption Compliance. Get approval from a Director for assurance on Anti-Corruption Compliance before entering into any agreement with a government or engaging a third-party intermediary.
• Follow anti-corruption laws and our policy. IRL is committed to following all applicable laws regarding the prevention of bribery and corruption. Know and follow your local Anti-Corruption Compliance Procedures and controls.
• Immediately report allegations of bribery or attempted bribery directly to a manager, team leader or Director.

Keep Accurate Records

Keeping honest and accurate financial records builds trust in our brand, informs our strategy, and helps operations run efficiently. We all share this responsibility.

• Never falsify a record or account. IRL has certain legal obligations to keep our records clear, accurate, timely, and complete. Never hide, alter, or disguise any business transaction.
• Follow all internal processes and controls when creating and maintaining records. Even if you are not directly responsible for the preparation of disclosures or financial reports, you are responsible for reporting accurate information in the business records you prepare. Properly record information— including approvals, costs, sales, expense reports, and time records.
• This extends to filing systems, both online and offline and file naming conventions.

Use Data and Technology Respectfully and Ethically

When our customers, associates, and business partners share data and information with us, we understand the importance of keeping it safe and using it—and technology—ethically in ways they expect. We will maintain and grow the trust people have in us by respectfully using technology, respecting individuals’ privacy, and protecting their data.

• Respect the trust that people and the business place in us. When dealing with technology and personal or business information, do so in a way that shows you understand and respect its importance to the person and our business.]
• Be clear about what information is being collected and why. When we collect information from individuals, make it clear that information is being collected, and tell the person why you need it.
• Tell people how you are using technology and what you are going to do with the information you collect. Be honest, transparent, and upfront about how someone’s information will be used. Only use it in those ways, so we don’t surprise people with unexpected, unexplained, or unwanted uses.
• Be thoughtful about how much data you collect and how long you keep it. We collect information to support our business functions. We must store and protect everything we collect, so make sure you need it before you collect it. Follow POPIA guidelines for retention and disposal of collected information.
• Protect the information. Safeguard personal and business information from unauthorized access or disclosure. Report any known or suspected unauthorized access or disclosure immediately to a manager, team leader or Director.
• Follow data protection and privacy laws and our policies. Know our data policies, procedures, and controls that apply to your role and follow them when handling data.
• Seek guidance. If you have questions about how to handle data or which laws and policies apply to your project, contact a manager, team leader or Director.
•  

Don’t Misuse Inside Information

You may know important information about our business that hasn’t been made public. Inside information may affect IRL’s reputation or one of our business partner’s reputation or even stock price. By only trading on publicly and lawfully available information, we uphold IRL’s reputation for honesty and fairness.

• Do not trade on inside information. If you have certain important or sensitive information about IRL or our business partners that is not known to the public, it is illegal to buy or sell shares in those other companies. Examples of inside information include financial results, pricing or marketing strategy changes, significant lawsuits or contracts, key management changes, and projections of future sales and earnings. If you are unsure whether something qualifies as inside information, contact a manager, team leader or Director.
• Keep it to yourself. Only share inside information with employees who need it to perform their jobs.
• Do not share insider tips. Do not share inside information outside of IRL, even with family members or friends. When discussing inside information be aware of your surroundings to avoid someone overhearing.

For any questions or queries please contact the Directors of IRL Consulting directly.