Code of Conduct

PREAMBLE

ECI stakeholders and professionals, to act responsibly, they should reflect upon the wider impact of their work, consistently supporting the public cause. The ECI Code of Conduct expresses the conscience of the professionals.

The code of conduct is designed to inspire and guide the ethical conduct of all ECI stakeholders and professionals including top management, employees, members, workers, associates, influencers and anyone who is directly indirectly involved with the ECI in an impactful way. Additionally this code of conduct serves as a basis of for the remediation when violations occur.

Purpose of code of ethics and conduct

ECI Code of Conduct describes, in very practical and clear terms, the minimum standards of behaviour required of all ECI stakeholders, team, employees, professionals, associates and anyone who is attached with ECI. These standards of behaviour shall be demonstrated by all Customs employees and are to serve as a guide when making decisions and taking actions.

To ensure public confidence in the integrity of ECI, all ECI stakeholders, team, employees, professionals, associates shall respect and adhere to their particular Code of Conduct, which generally comprises the following key elements.

Key Elements

I. Work Environment

We all deserve to work in an environment where we are treated with dignity and respect. ECI is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our organisational success. We cannot afford to let anyone’s talents go to waste.

ECI is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types and from abusive, offensive or harassing behaviour. Any employee who feels harassed or discriminated against should report the incident to the management. All Council’s staff and members are also expected to support an inclusive workplace by adhering to the following conduct standards:

Treat others with dignity and respect at all times.
Address and report inappropriate behaviour and comments that are discriminatory, harassing, abusive, offensive or unwelcome.
Foster teamwork, staff and members participation, encouraging the representation of different staff or members perspectives.
Seek out insights from staff or members with different experiences, perspectives and backgrounds.
Avoid slang or idioms that might not translate across cultures.

Support flexible work arrangements for co-workers with different needs, abilities and/or obligations.
Confront the decisions or behaviours of others that are based on conscious or unconscious biases.
Be open-minded and listen when given constructive feedback regarding others’ perception of your conduct. Council will not tolerate discrimination, harassment or any behaviour or language that is abusive, offensive or unwelcome.

II. Build Trust And Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.

When considering any action, it is wise to ask: Will this build trust and credibility for ECI? Will it help create a working environment in which ECI can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “YES” to those questions and by working every day to build our trust and credibility.

III. Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Council and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Council, we must contact the Management.

ECI takes seriously the standards set forth in the Council, and violations are cause for disciplinary action up to and including termination of employment.

IV. Compliance With The Law

ECI’s commitment to integrity begins with complying with laws, rules and regulations where we do businesses or services. Further, each of us must have an understanding of the organisation policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or ECI policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.

V. Avoid Conflicts Of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the actions we take on behalf of ECI may conflict with our own personal or family interests. We owe a duty to ECI to advance its legitimate interests when the opportunity to do so arises. We must never use ECI property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with ECI.

Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from the management.

VI. Gifts, Gratuities And Business Courtesies

ECI is committed to competing solely on the merit of our organisation agenda and services. We should avoid any actions that create a perception that favorable treatment of outside entities by ECI was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies or organisation with whom ECI does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of ECI or stakeholders involved, or would cause embarrassment or reflect negatively on ECI reputation.

VII. Confidentiality And Use Of Official Information

Information is a key asset of an organisation. Confidential information is information that has not been publicly disclosed. Any disclosure, either intentionally or in error, of the Council’s confidential information, whether or not such information is in writing or labelled as confidential or proprietary, could result in considerable damage to the Council’s reputation, strategies, objectives, activities or staff.

Confidential information can include technical information, financial information, administrative information, marketing information, research, papers, softwares, correspondences, results, designs, patents, etc., disclosed by Council Members and/or Councils Stakeholders. As between the Council and any Council’s staff or members, any confidential information is the exclusive property of the Council. You must not disclose, publish or otherwise make available to any third party, other than Council’s member or staff, any confidential information, except as expressly authorized by the Council. Confidential information can be accessed, downloaded and/or used only in the performance of your duties for the Council and in accordance with Council policies.

All reasonable precautions to protect the integrity and confidentiality of confidential information in your possession must be exercised. It is forbidden to copy and/or transfer confidential information to any personal device (i.e. personal USB key, laptop, external hard drive, online storage, mobile device, email account). On termination of your employment or your duties with the Council, or at any time at the Council’s request, any equipment or materials in your possession and containing confidential information must be returned immediately to the Forum.

VIII. Use Of Official Identification

Badges, credentials and identification cards are to be used by ECI members, employees, and stakeholders for official purposes only. Identity badges and security items are issued to assist and identify ECI members in the performance of their duties and in exercising responsibilities entrusted to them.

They are not to be used for any other purpose. Security badges, keys, passwords and the like are to be safeguarded by the ECI members to whom they have been issued, and must be surrendered to ECI upon completion of tenure.

IX. Intellectual Proprietary Rights

It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of an anyone’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software, hardware, technology, products, services, etc., or other intellectual property

X. Organisation Recordkeeping

We create, retain and dispose of our company records as part of our normal course of business in compliance with all ECI policies and guidelines, as well as all regulatory and legal requirements. All organisational records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with ECI and other applicable accounting principles. We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of ECI books, records, processes or internal controls.

XI. Media Inquiries

ECI is a leading high-profile organisation, and from time to time, employees / stakeholders may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the organisation, we should direct all media inquiries to the authorised representative / spokesperson of the Council. No one may issue a press release without first consulting or approval with the Management.

XII. Effective Communications

In all matters relevant to client’s, associates, vendors, government authorities, institutions, corporates, the public and others in the Organization, all stakeholders & employees must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints.

XIII. Health and safety

ECI is dedicated to maintaining a healthy environment. All stakeholders & employees should enjoy an expectation of a healthy and safe working environment as it relates to their assigned duties, as this has a direct impact on the overall perceived professionalism of the Council. Concurrently, all stakeholders & employees must take their own responsibilities seriously, contribute to workplace safety and promptly report any health or safety concerns or related breaches of rules or regulations to the management.

XIV. Waivers

Waiver of all part of the Code, such as for potential conflicts of interests, shall be granted only in exceptional circumstances and then only by the Board in writing. Waivers granted to directors or executive officers may only be granted by the Board and shall be publicly disclosed as required by law.

XV. Review of code

The Board shall review and evaluate this Code from time to time as it may determine whether this Code is effective in ensuring that the Company’s business and affairs are conducted with honesty, integrity and in accordance with high ethical and legal standards and make recommendations to the Board.

XVI. No Rights Created

This Code is a statement of the fundamental principles and key policies and procedures that govern the conduct of the ECI’ agenda. It is not intended to and does not, in any way, constitute an employment contract or an assurance of continued employment or create any rights in any Employee, client, supplier, competitor, stakeholder or any other person or entity.

XVII. Selective Disclosure

We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material non-public information with respect to ECI, its securities, operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material non-public information.