Free policy template · Word

Ethics Policy

An ethics policy states the principles of integrity that guide business decisions — honesty with customers, investors and regulators, accurate books and records, fair competition, responsible use of inside information and respect for human rights. It provides an ethics committee and a simple test employees can use when a decision feels uncertain.

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[Company Logo][Company Name]

ETHICS POLICY

Policy No.:: [Reference Number]
Version:: [Version Number]
Effective Date:: [Date]
Policy Owner:: Ethics Committee

1. Purpose

[Company Name] aims to grow by doing business the right way. This policy sets the ethical principles that guide decisions at every level and the support available when choices are difficult.

2. Scope

It applies to directors, employees and anyone acting on the company's behalf, including agents, distributors and consultants.

3. Definitions

Stakeholders: customers, employees, investors, suppliers, regulators and communities.
Inside information: non-public information that could affect the price of securities of the company or another listed entity.
Ethics Committee: [Members], constituted to advise on and oversee this policy.

4. Policy

Honesty: we communicate truthfully with customers, regulators, auditors and investors and never mislead them.
Accurate records: all transactions are recorded correctly and promptly; no false entries, off-book accounts or backdated documents.
Fair dealing: we compete on merit, do not share pricing with competitors, and do not obtain competitor information illegally.
Inside information: employees must not trade in securities or tip others while in possession of inside information.
Bribery and gifts: we follow the Anti-Bribery Policy without exception.
Conflicts: personal interests must not influence business decisions, as set out in the Conflict of Interest Policy.
Human rights: we do not use child labour or forced labour and expect the same of our suppliers.
Community and environment: we comply with environmental laws and act responsibly where we operate.

5. Procedure

Before making a decision that feels uncertain, apply the ethical decision test: Is it legal? Is it within our policies? Would I be comfortable if it became public? Does it treat others fairly? If unsure, seek advice from your manager, HR, Legal or the Ethics Committee at [Ethics Email]. Concerns about breaches may be raised through the Whistleblower Policy.

The Ethics Committee meets every [Number] months and reviews reported concerns and trends.
All employees complete ethics training on joining and annually.
Senior employees confirm compliance with this policy in writing each year.

6. Responsibilities

Board and leadership: set the tone and provide resources.
Ethics Committee: guidance, oversight and reporting.
Managers: model behaviour and never pressure teams to breach ethics.
Employees: act with integrity and speak up.

7. Non-compliance

Breaches are investigated and may lead to disciplinary action, termination of contracts with third parties, and reporting to authorities where the law requires. Achieving targets is never a justification for an ethical breach.

8. Review & Approval

The Ethics Committee will review this policy annually and report to [Board / Leadership].

Approved by
[Authorised Signatory]
[Designation]
Date: [Date]

Acknowledged by
[Employee Name]
Date: [Date]

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What this template includes

Statement of ethical principles — integrity, fairness, accountability
Fair dealing with customers, suppliers and competitors
Accurate books, records and disclosures
Inside information and trading restrictions
Human rights and responsible sourcing — no child or forced labour
Ethics committee and the 'ethical decision test'

When to use it

Investors, lenders or large clients require a code of ethics
Preparing for listing or stronger corporate governance
Sales targets create pressure to cut corners
Employees need guidance on grey-area business decisions

How to customise this template

1Adapt the principles to your sector
2Name the ethics committee members
3Add insider trading rules if your company or group is listed
4Link to anti-bribery, conflict of interest and whistleblower policies
5Add supplier code expectations if you source from vendors

HR tips

Use real dilemmas from your business in ethics training
Reward ethical behaviour in appraisals, not just results
Make it easy to ask for advice before acting
Publish anonymised outcomes so people see the policy is enforced

Listed companies and regulated sectors have additional obligations, such as insider trading regulations. Review this template against laws applicable to your company and with legal advice.

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Frequently asked questions

What is an ethics policy?+

It is a statement of the ethical principles a company follows in business and the way employees should apply them, supported by advice and reporting channels.

What is the ethical decision test?+

A short set of questions: Is it legal? Is it consistent with our policies? Would I be comfortable if it appeared in the newspaper? Would I treat a customer or colleague this way? If any answer is no, stop and seek advice.

Who should be on an ethics committee?+

Typically a senior leader, the HR head, a legal or compliance head and an independent member where possible, so concerns can be reviewed impartially.

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Document No.:
[Reference Number]
Version:
[Version Number]
Effective Date:
[Date]
Policy Owner:
[HR Name], Human Resources
Approved By:
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1.3 Precedence: Where this manual conflicts with any law, certified standing order or individual appointment letter, the law and then the more favourable term for the employee will apply.
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