Message from the Board of Directors

Sonardyne Code of Conduct

Sonardyne Code of Conduct

At Sonardyne we are committed to undertaking our business responsibilities with honesty, fairness and transparency and this is reflected in every aspect of our business affairs. We are clear about what we believe in: the ethics and business standards we set ourselves, our representatives and our suppliers. Everything that we do is guided by principles that define our character and culture. Our Codes and Policies outline the principles and behaviours that Sonardyne upholds as a company, to ensure that the highest standards of integrity are maintained.

We operate a zero-tolerance approach to the giving or receiving of bribes or corrupt payments in any form.

The action and conduct of Sonardyne Directors, employees or anyone else acting on Sonardyne’s behalf is essential to maintaining these standards. All Sonardyne personnel, including agents, resellers, consultants and contractors are required to read, become familiar with and act in accordance with our Codes and Policies.

Ralph Rayner

Sonardyne Code of Conduct (Portuguese)

Sonardyne Code of Conduct (Portuguese)

Chairman

Ethics

Our Codes of Conduct set out our business principles that guide every person working for, with and on behalf of Sonardyne to behave with integrity, act with good judgement and within the law.

‘Doing the right thing’ and ‘doing it right’ is at the heart of our Codes of Conduct and it is with these values that we conduct our business, everywhere we operate.

Communications and Training

We train our employees and provide communications to explain how the Codes’ principles apply to their work. New staff receive training as part of their

supplier-code-of-conduct

Sonardyne Supplier Code of Conduct

induction and we regularly provide all employees with refresher training. Sonardyne commercial bulletins remind our employees of our commitment to uphold our values and incorporate them into our business process, and our due diligence procedures and contracting terms, formally set out our requirements for suppliers, agents and resellers to understand and adhere to the Codes, our Policies and Processes.

Speaking Up

Sonardyne provides an environment where employees and others with whom we interact, are encouraged to ask questions about the Codes. Everyone is empowered to raise concerns and report violations when they believe there is anything unethical or unsafe in the way we conduct our business, through our secure and confidential reporting channels:
ethics.helpline@sonardyne.com
+44 (0)1252 743209

Sonardyne has zero-tolerance for retaliation against anyone seeking advice or reporting a concern in this way.

Human Rights

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We are implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Anti-Bribery and Corruption

Our equipment is used in, and many of our employees travel to, countries which rank highly on Transparency International’s Corruption Perception Index.

Our company’s Policy is to comply with all laws, rules and regulations governing bribery and corruption in all the countries where we operate, including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977. Our ethical behaviour seeks to ensure that no bribes or corrupt payments are made, requested, offered or received by anyone acting on our behalf.

We do not pay facilitation payments and we provide our employees with focussed training and guidance to assist them in managing any such requests.

Our Anti-Bribery Policy is incorporated directly into our business processes throughout the organisation. It is applied to our contracts through the inclusion of appropriate clauses. Due diligence is performed on third parties that seek to represent us or who provide products and services to us. We conduct regular reviews and risk assessments of all our Ethics Policies and Processes.

Gifts and hospitality remains the most frequent subject raised by employees about our Code, in particular around the interpretation and appropriateness of such during seasonal festivities. Our policy does not permit the offer or acceptance of gifts, nor hospitality that is not within the context of a business meeting.

Suppliers

We expect that wherever our suppliers are located, producing products or delivering services for us, that these are provided in a manner compatible with the high standards that contribute to the reputation of Sonardyne as well as in full compliance with all applicable laws, regulations and our Supplier Code of Conduct.