Ethical Policy

1. Policy Statement

It is Bristow & Sutor’s goal to maintain the highest standards of ethics, professionalism and business conduct, as well as ensure that we act in strict compliance with the law and our client’s guidelines at all times. We will not tolerate any behaviour or practice that compromises the Company’s integrity or honesty. All decisions will be fair and based on transparent processes.

2. Our Core Values

Professionalism
Transparency
Accountability
Trust
Compliance
Respect

In support of our core values, we:

identify customers that are vulnerable and deal with these cases sensitively
recover monies from customers who are able to pay the monies owed
promote easy free independent debt advice for customers
readily engage with advice sector representatives
minimize fees and collect the debt at the earliest opportunity
respond quickly to queries or complaints
protect both our Agents and our customers
are open, honest and transparent at all times with debtors and clients
treat customers respectfully and fairly

3. Compliance

Since the Company aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with our principles and values will not be tolerated. Strict adherence to these principles and supporting policies is a condition of employment.

The board has overall responsibility for ensuring compliance with the objectives of this Policy.

4. Independence and Objectivity

Bristow & Sutor is committed to being fair, transparent and impartial in all of its dealings and our members of staff are expected to adhere to specific standards of behaviour, namely:

All staff are required to act in a way that is unbiased, and they must not be subject to any influence which may lead them to act in a way which favours a person or organisation
Other than the salary paid by the company, employees may not directly or indirectly accept any form of payment or material benefit from third parties for services they perform on behalf of the company
All staff are required to declare in writing any financial or personal interest, direct or indirect, in another company which is either a supplier to or a competitor to Bristow & Sutor

5. Professional Competence and Duty of Care

The company will ensure that it and all its staff achieve and maintain professional knowledge and skill at a level required to ensure that a client receives competent professional service based on current developments in practice, legislation and techniques, and act diligently and in accordance with the law and applicable professional standards.

6. Unethical Behaviour and ‘Whistle-Blowing’

The Company promotes a working environment which encourages all members of our team to express their concerns about behaviour or decisions that they perceive to be unethical without fear of reprisal or victimisation. Any member of staff who needs guidance or advice on business ethic issues should speak to his or her manager or the Chief Executive Officer (CEO).

The CEO is responsible for initiating and supervising the investigation of any reports of a breach of these principles and policies and ensuring that appropriate disciplinary action is taken when required.

7. Employment Policies

Bristow & Sutor is committed to attaining the highest standards of employment practice and wishes to be recognised as a good employer. It is committed to communicating its strategy and objectives to employees and to keeping employees informed on the company’s progress against the strategy and objectives.

The company complies with the National Living Wage for all employees.

We support and promote the ethos and principles of equal opportunities, diversity and inclusion in our workforce, striving to create a culture where every member of our team is treated fairly and without fear of harassment or victimisation for any reason.

We seek to promote good practice in the workplace and with third parties and our policies are consistent with the Ethical Trading Initiative Base Code, namely:

Employment is freely chosen
Freedom of association and the right to collective bargaining are respected
Working conditions are safe and hygienic
Child labour shall not be used
Working hours are not excessive
No discrimination is practised
Regular employment is provided
No harsh or inhumane treatment is allowed

8. Balancing Transparency with Confidentiality

The company will be transparent in all of its operations except where it is constrained by issues of confidentiality.

We respect the confidentiality of information acquired in our business operations and relationships and, therefore, would not disclose any such information to third parties without proper and specific authority, unless there is a legal or professional right or duty to disclose it.

The Company will strive to communicate clearly and succinctly to minimise complexity in our business dealings and will comply with the provisions of the General Data Protection Regulations.

9. Protecting Business Assets

All members of staff are required to avoid waste and extravagance and are encouraged to identify improvements to systems and procedures to achieve optimal effectiveness, efficiency and responsiveness.

All employees are expected to follow agreed procurement procedures when commissioning third party services.

10. Suppliers, Advisors and Agents

Bristow & Sutor seeks to work with and to develop relationships with suppliers, advisors and agents who share our values. We communicate and promote our policies and working practices with third parties, and include them in our contractual arrangements, where appropriate.

The Company will pay its suppliers, advisers and agents on time and according to agreed terms. We are committed to working with them and with our clients professionally and on the basis of collaboration and mutual trust and development.

11. Competitors

Bristow & Sutor will:

Compete in a lawful manner
Not seek to damage the reputation of competitors, either directly or by implication or innuendo
Avoid discussing proprietary or confidential information in any contacts with competitors
Not attempt to acquire information regarding a competitor’s business by unlawful means, including industrial espionage, hiring competitors’ employees to obtain confidential information, urging competitors’ employees, clients or occupiers to disclose confidential information, or any other approach that is not above board

12. Governance and Financial Matters