Code of Conduct

Employees of Empresaria Group will observe the highest principles of ethics, equity, integrity, professional conduct and fair practice in dealing with others and will conduct their business in a manner designed to enhance the operation, image and reputation of the recruitment industry and Empresaria Group.

Ethical behaviour is not simply compliance with legal requirements but extends to honesty, respect for and equitable treatment of others, integrity and social responsibility. It is conduct that holds up to disclosure and to public scrutiny. Empresaria employees will act towards other recruitment professionals, candidates, customers, suppliers and others at all times in good faith.

This Code provides a basis for all employees to maintain a working environment that is productive, positive, enjoyable, safe and free from harassment and discrimination. It relies on individuals being responsible for their own professional behaviour within the provisions of this code, Empresaria policies, legislation and relevant clauses that apply to individual contracts of employment.

Employee responsibilities

Employees are responsible and accountable for their own actions and conduct. It is the duty of each employee to act ethically, fairly and responsibly with everybody with whom they have dealings, whether internal or external to the Group, to ensure that a positive and reputable image is portrayed. Abusive behaviour is not allowed. It is the employee's responsibility to create a working environment that is not offensive.

Employees must comply with all relevant legislation, statutory and non-statutory requirements and official guidance and any future amendments to such requirements during the course of providing their services to others. All forms of corruption are prohibited by the Group.

Good and bad news must be reviewed openly and professional without threat or ridicule to those concerned. Improved performance and added value are a constant goal from which recognition and reward is to be shared.

Any employee that is subject to blackmail or extortion should immediately inform the Regional Director or Group Finance Director for guidance on how to deal with the situation and to ensure the Group is fully aware of the situation.

Personal behaviour

Employees are required to undertake their duties in a professional, responsible, conscientious and ethical manner and to act in the best interests of the Empresaria Group. They are expected to act honestly in all of their duties when dealing with clients, suppliers, contractors and fellow employees.

Employees may not pursue any political activity or make political contributions in the name of the Company that has not been approved by the Group CEO.

Employees may not pursue any charitable activity or make charitable contributions in the name of the Company that has not been approved by the Group CEO.

If an employee is required to investigate complaints against other employees or issues affecting employees, they must act consistently, fairly and in a timely manner.

Employees must at all times act honestly in all dealings with clients, candidates, suppliers, colleagues and others to ensure that they are not misled. Employees shall not knowingly make a false or inaccurate statement, fail to disclose a material fact, or make a representation as to future matters without having reasonable grounds for making it.

Employees are expected to be punctual and regular in their attendance. Employees must ensure that their appearance is neat, clean and appropriate for their particular area of work. A high standard of personal hygiene is expected at all times.

Use of facilities and equipment

Employees should take all possible care when using Empresaria property, goods, intellectual property and services and ensure they are used efficiently, carefully and honestly. Unless permission has been granted by the employee's manager, Empresaria resources are not to be used for private purposes.

Privacy and use of personal and official information

Employees have an obligation to ensure that Company information is secured against loss, misuse or unauthorised access, modification or disclosure. Employees have a duty to maintain the confidentiality, integrity and security of official information for which they are responsible. Information about our business, its employees and its customers is strictly confidential. It must never be disclosed to a third party. This includes details of prospective customer's requirements, sales leads and new products or services.

Employees must observe the highest principles of integrity, professionalism, equity and fair practice to maintain the confidentiality and privacy of candidate and client information and should respect the confidentiality of records in accordance with the law and good business practice. Employees must ensure that permission has been obtained and documented before disclosing, displaying, submitting or seeking confidential or personal information.

There is a legal requirement to adhere to proper records management practices and procedures. All employees must therefore ensure that Empresaria documents are not placed in unofficial or private filing systems but place such documents in official files.


It is the responsibility of all employees, through their personal dealings with customers, to strive to affect the quality of relationship and service that they would wish to receive for themselves.

Employees must only seek to obtain business in such a way that both their personal reputation and integrity and that of Empresaria are enhanced. Market prices must be used for all transactions of the Company.

Bribery and corruption

The Group is committed to preventing bribery and corruption and all staff must refrain from engaging in or facilitating any form of corruption.

Staff should carefully consider whether gifts and hospitality is appropriate. Any gifts, whether given or received, or hospitality provided that is intended to influence a business decision is deemed to be bribery and is not allowed. If anyone is unsure as to whether this applies they should seek guidance from the Regional Director or the Group Finance Director.

Facilitation payments are not allowed to be made in any circumstances.


Any breach of this Code of Conduct Policy will be subject to the company's Disciplinary Procedure. Employees should be aware that certain breaches of this code might render them liable to summery dismissal. The following are examples of such misconduct, which Empresaria finds unacceptable:-

  • Accepting or offering bribes.
  • Falsification or misrepresentation of records such as customer records and legal records.
  • Conduct bringing either the employee or Empresaria into disrepute.
  • Any act of race, sex, disability or other unlawful discrimination.
  • Bullying or harassment.
  • Behaving unethically.
  • Abuse of the Company's business systems for the unlawful/unacceptable transmission/receipt of information.
  • Any major breach or continual minor breaches of our general code of conduct.
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