Last updated: August 2024

 

Anti-Bribery and Corruption Policy

What is Bribery and Corruption?

An offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or a breach of trust, in the conduct of the modernspace’s business.

Policy Statement

Modernspace has no tolerance for:

1. breaching the laws or regulations of the jurisdictions in which it operates
2. acting in a corrupt manner

Modernspace will observe all relevant legislations and regulations at all times and has zero tolerance for dealing with Clients that offer or solicit bribes.

Dealing with such Clients could result in:

1. Criminal or civil proceedings against Modernspace and its officers and staff
2. Immediate financial loss either through fines or suspension of business
3. Reputational damage adversely affecting current and future revenue generation.

 

Bribery and Corruption Principles

To manage Bribery and Corruption Risk Modernspace will observe the following principles:

We will not offer any bribes or other inducements nor deal with third parties who offer or expect bribes or inducements in order to win business under any circumstances and regardless of any local customs.

We will always deal at arms length commercial terms and ensure that any discounts or premiums meet this principle.

We will ensure that any and all gifts or entertainment we give or receive are appropriate and cannot be considered as lavish or inducements.

We will appoint Brokers and Intermediaries only when there are pressing commercial circumstances.

We will deal with Government departments and public officials with scrupulous attention to proprietary and never offer or accept requests for unofficial facilitation payments.

 

Extortion Exception

We will take reasonable steps to remove ourselves from danger if our physical safety is put at risk. In exceptional circumstances, this may include making a payment to a public official or other individual to ensure our safety in the situation. We must report any such incident as soon as it is safe to do so.

August 2024 

 

Anti-Money Laundering Policy

What is Money laundering?

The goal of a large number of criminal acts is to generate funds for the individual or group that carries out the act. Money laundering is the processing of these criminal proceeds to disguise their illegal origin. This process is of critical importance, as it enables the criminal to enjoy these profits without jeopardising their source.

 

Modernspace has defined a zero tolerance for:

3. breaching the laws or regulations of the jurisdictions in which it operates
4. dealing with potential financial criminals

Modernspace will observe all relevant legislation and regulations at all times and has zero tolerance for dealing with Clients that would expose us to unacceptable Financial Crime Risk.

Dealing with such Clients could result in:

4. Criminal or civil proceedings against Modernspace and its officers and staff
5. Immediate financial loss either through fines or suspension of business
6. Reputational damage adversely affecting current and future revenue generation.

 

Client On Boarding Process

To manage Financial Crime Risk and ensure we have identified our Clients we implement a number of controls and processes via our Client On Boarding Process. These include:

1. Conducting Client due diligence procedures in order to determine the background and identity of our Clients at the inception of the relationship and on a periodic basis
2. Implementing controls in respect of payments we make and receive using a risk-based approach to ensure that the payments are consistent with the requirements of this policy.
3. Requiring employees to be alert to any unusual or suspicious arrangements which could expose us to Financial Crime Risk, and to report such arrangements to the Chief Financial Officer.

August 2024

 

Conflict of Interest Policy

What are conflicts of Interest?

A Conflict of Interest occurs when an entity or individual becomes unreliable because of a clash between personal (or self-serving) interests and professional duties or responsibilities.

At Modernspace declarable Conflicts of Interest include:

1. having an ownership, a shareholding, a directorship in or with a third party or any other commercial relationship or activity, whether it directly or indirectly affects the business of Modernspace
2. having a personal or business relationship with a third party outside of normal Modernspace activities
3. working with or considering hiring a relative or close personal relation

 

Policy Statement

Modernspace:

5. has zero tolerance of breaching the laws or regulations of the jurisdictions in which it operates
6. avoids conflicts of interest wherever possible
7. ensures all conflicts of Interest are declared and managed

Modernspace requires that all Staff always act in the best interests of Modernspace. Improper management of Conflicts of Interest could lead to:

7. Criminal or civil proceedings against Modernspace and its officers and staff
8. Immediate financial loss through inappropriate commercial terms, fines or suspension of business
9. Reputational damage adversely affecting current and future revenue generation.

 

Conflicts of Interest Register

To manage Conflicts of Interest Modernspace will maintain a register of declared and approved potential Conflicts of Interest.

August 2024

 

Environmental Policy

The Environment and Sustainability

The United Nations Global Compact Principles regarding the Environment (the Principles) set out expectations for all businesses to minimise adverse environmental impact above and beyond compliance with laws and regulations.

 

Policy Statement

Modernspace has zero tolerance of breaching the laws or regulations of the jurisdictions in which it operates.

Modernspace is committed to minimising its adverse environmental impact. This means we will 

1. support a precautionary approach to environmental challenges;
2. undertake initiatives to promote greater environmental responsibility; and
3. encourage the development and diffusion of environmentally friendly technologies.

Not acting within the Principles and the legal and regulatory framework based upon the Guiding Principles could result in:

10. Criminal or civil proceedings against Modernspace and its officers and staff
11. Immediate financial loss either through fines or suspension of business
12. Reputational damage adversely affecting current and future revenue generation.

 

Client On Boarding Process

To manage the risk of any negative environmental impact we implement a number of controls and processes via our Client On Boarding Process. These include:

4. Conducting Client due diligence procedures in order to determine the commitment of our Clients to environmental issues, at the inception of the relationship and on a periodic basis
5. Requiring employees to be alert to any unusual or suspicious activities which could expose us directly or indirectly to facilitating avoidable adverse impact to the environment, and to report such activities to the Human Resources.

August 2024

 

Equal Opportunities Policy

modernspace is committed to the expectation of a respectful, fair and safe working environment.

Our continued success relies on being an attractive employer of choice for the highest calibre of employee.

In order to maintain our high performance workforce we are committed to offering a work environment that treats people fairly and with respect.

We recognize the many values of a diverse mixture of people within our workforce.

We foster an environment where we look after our own and each other’s health and well being.

We work together to the include the diversity of thought and behaviour of all of our colleagues, to optimise solutions delivered to our Customers and other stakeholders.

We are an Equal Opportunities employer and will always hire, promote, reward and offer development opportunities based on capabilities, qualifications, experience, performance, and ethical behaviour.

We promote inclusion, fairness and equality and never discriminate based on race, nationality, religion, gender, age, sexual orientation, disability, ancestry, social origin, trade union membership, political belief, or any other potential bias.

We have zero tolerance for any bullying and harassment, physical threats or violent behaviour of any kind.

We have high expectations of our supervisors to build a diverse and inclusive workforce based on these commitments.

 

Policy Statement

Modernspace will respect and uphold the Commitments made in this policy.

Not acting within the Commitments and the legal and regulatory framework requiring Equal Opportunities and Non Discrimination could result in:

1. Loss of morale within our workforce and inability to retain our high calibre workforce or attract new talent
2. Criminal or civil proceedings against Modernspace and its officers and staff

Reputational damage adversely affecting

August 2024

 

Human Rights Policy

Human Rights

The United Nations Guiding Principles on Business and Human Rights (Guiding Principles) set out expectations for all businesses to respect human rights above and beyond compliance with laws and regulations.

 

Policy Statement

Modernspace has zero tolerance of breaching the laws or regulations of the jurisdictions in which it operates

Modernspace respects all Human Rights. This means we will 

4. avoid causing or contributing to adverse Human Rights impacts through our own activities, and address such impacts when they occur;
5. seek to prevent or mitigate adverse Human Rights impacts that are directly linked to our operations, products or services by our business relationships, even if we have not directly contributed to those impacts.

In particular for our business activities, including our relations with third parties, we uphold:

1. the freedom of association and the effective recognition of the right to collective bargaining.
2. the elimination of all forms of forced and compulsory labour.
3. the effective abolition of child labour

Not acting within the Guiding Principles and the legal and regulatory framework based upon the Guiding Principles could result in:

13. Criminal or civil proceedings against Modernspace and its officers and staff
14. Immediate financial loss either through fines or suspension of business
15. Reputational damage adversely affecting current and future revenue generation.

 

Client On Boarding Process

To manage the risk of any abuses of Human rights we implement a number of controls and processes via our Client On Boarding Process. These include:

6. Conducting Client due diligence procedures in order to determine the commitment of our Clients upholding Human Rights, at the inception of the relationship and on a periodic basis
7. Requiring employees to be alert to any unusual or suspicious activities which could expose us directly or indirectly to facilitating Human Rights abuses, and to report such activities to the Human Resources.

August 2024

 

Speaking Up Policy

Doing the Right Thing

Modernspace is committed to conducting its business ethically, honestly, and in compliance with all applicable laws and regulations. In short we are committed to doing the right thing.

 

Speaking Up

Modernspace is equally committed to ensuring that the company fosters a culture where staff and external stakeholders are encouraged to report concerns in good faith without fear of being disadvantaged or retaliated against.

Where you suspect or believe any actual, planned or potential wrongdoing that breaches any law, regulation, Group policy or Group controls has occurred, is occurring or may occur and you are not comfortable reporting such wrongdoing within your line management then you should Speak Up.

You can Speak Up by emailing to speakingup@modernspace.com detailing your concern.

All Speaking Up reports will be recorded reviewed and, where appropriate, independently investigated. An acknowledgement and where possible, feedback will be provided to the person raising the concern.

Every effort will be made to maintain the confidentiality of the person making a report (although where, for example, the report leads to legal proceedings, this cannot be guaranteed).

Where a report has been made in good faith nobody will be disadvantaged or retaliated against for Speaking Up, even if there is no conclusive evidence to support the concern raised.

August 2024