Purpose
This Code of Ethics & Conduct sets out the values and standards of behaviour that Sunwell Solutions LTD expects from everyone who works for us or on our behalf. It is not a list of rules designed to catch people out — it is a statement of who we are and how we want to operate as a business.
We are a small team, and our reputation depends on every one of us acting with integrity, honesty, and professionalism at all times. This code applies to all employees, contractors, and anyone acting on behalf of Sunwell Solutions LTD, regardless of their role or seniority.
Our Values
- Integrity — we do what we say we will do, and we are honest even when it is difficult
- Respect — we treat colleagues, customers, suppliers, and the public with dignity and fairness
- Accountability — we take responsibility for our actions and their consequences
- Professionalism — we represent Sunwell Solutions LTD with pride and conduct ourselves to the highest standard
Conflicts of Interest
A conflict of interest arises when a personal interest — financial, professional, or personal — could influence, or appear to influence, a decision made on behalf of Sunwell Solutions LTD.
We expect all staff to:
- Avoid situations where personal interests conflict with the interests of the company or its customers
- Declare any potential conflict of interest to the General Manager as soon as it becomes apparent
- Recuse themselves from any decision or process where a conflict exists or could reasonably be perceived to exist
Declarations of conflicts of interest are recorded by the General Manager in a conflicts of interest register. If you are unsure whether a situation constitutes a conflict, err on the side of disclosure.
Anti-Bribery & Corruption
Sunwell Solutions LTD has a zero-tolerance approach to bribery and corruption in all forms. No employee or contractor may:
- Offer, promise, give, or authorise a bribe to any person or organisation
- Request, agree to receive, or accept a bribe
- Make facilitation payments of any kind
If you are ever asked to pay or receive a bribe, you must refuse, report it immediately to the General Manager, and not attempt to handle it alone.
Gifts & Hospitality
Receiving Gifts & Hospitality
Staff may accept modest gifts or hospitality provided:
- The value does not exceed €50 per occasion
- It is not cash or a cash equivalent
- It is not offered at a time when a procurement or contract decision is being made
Any gift or hospitality above €50 must be declared to the General Manager and recorded in the gifts and hospitality register.
Giving Gifts & Hospitality
Gifts of cash or cash equivalents must never be given under any circumstances.
Gifts & Hospitality Register
The General Manager maintains a gifts and hospitality register recording all declared gifts and hospitality above €50. Our employee handbook also prohibits accepting any gift in exchange for performing, or failing to perform, one's duties.
Use of Company Assets
Company assets are for business use only. Staff must:
- Use company equipment solely for work-related purposes
- Take reasonable care of equipment in their possession
- Not install unauthorised software on company devices
- Return all company equipment promptly upon leaving the company
Personal use of company laptops or devices is not permitted. Any loss, theft, or damage must be reported to the General Manager immediately. Detailed rules on the acceptable use of company systems and information are set out in our internal acceptable use policy.
Social Media & Public Conduct
Staff must not:
- Post content that is discriminatory, offensive, defamatory, or harassing
- Share confidential information about the company, its customers, or its operations
- Make statements that could be interpreted as the official position of Sunwell Solutions LTD unless explicitly authorised
Confidentiality
Staff must not share confidential information with anyone who does not have a legitimate need to know it, use it for personal gain, or retain it after leaving the company. Confidentiality obligations continue after employment ends.
Reporting Concerns
Concerns can be reported to the General Manager directly. Where the concern involves the General Manager, or where staff do not feel comfortable raising it directly, they can report it through our internal whistleblowing channel, which also accepts anonymous reports. Reports are handled confidentially and no one will suffer retaliation for raising a concern in good faith.
Consequences of Breaches
Breaches will be taken seriously and may result in a formal verbal or written warning, suspension pending investigation, termination of employment or contract, or referral to relevant authorities. The response will be fair, consistent, and proportionate.