CODES OF

RIGHT CONDUCT
Contents:

1. Introduction...........................................................................................................................3

2. Conflict of Interest

3. Dress and Personal Appearance Requirements .................................................................4

4. Religious and Cultural Dress................................................................................................5

5. Implementing the Dress and Personal Appearance Policy..................................................5

1. Conflict of interest

When you are experiencing a conflict of interest, your personal goals are no longer aligned with your

responsibilities towards the company. In other cases, if we become aware of such behaviour, you may be
faced with an ethical and legal issue and lose your position in the company.
 Owning stocks of one of our competitors is a conflict of interest.
 Accepting a bribe may benefit you financially, but it is illegal and against our business

For this reason, conflicts of interest are a serious issue for all of us. We expect you to be vigilant to spot
circumstances that create conflicts of interest, either to yourself or for your direct reports. Follow our policies
and always act in our company’s best interests. Whenever possible, do not let personal or financial interests
get in the way of your job. If you are experiencing an ethical dilemma, talk to your manager or Human
Resource Manager and we will try to help you resolve it.

2. Attendance / Conduct and Behavior relating to Productivity

 Habitual Tardiness. When an employee incurs five or more unexcused tardiness in a
month; or when an employee incurs less than five unexcused tardiness in a month but
aggregates 10 or more tardiness within a period of three months.
 Attending to personal matters at excessive periods during working hours, exceeding break
periods, playing parlor games, collecting debts, soliciting contribution or bets, and the like.
 Peddling of or soliciting orders for any merchandise within the Company’s premises.
  Absence from working place during working hours including loitering or wandering about.
 Using the company telephone and other electronic facilities for prolonged periods of time
for personal reasons before, during and after office hours.

3. Dress and Personal Appearance Introduction

3.1 Royal Blind and Scottish War Blinded, for the purposes of this code of conduct referred to as the Royal Blind
Group, aspires to a corporate personality that is approachable, forward thinking, professional, positive and
empowering.
3.2 It is essential that staff maintain an appropriate standard of dress and personal appearance at work and to
conduct themselves in a professional manner. The purpose of our Dress and Personal Appearance Policy is to
establish basic guidelines on appropriate clothing and appearance at our workplaces, so that we:
 promote a positive image and employees look professional
 respect religious, racial and gender-specific clothing requirements and those of employees with disabilities
where possible
 take account of health and safety requirements, and
 help employees decide what clothing it is appropriate to wear to work.
3.3 It is important that all employees dress in a manner appropriate to their working environment and the type of
work they do. Some services and roles within Royal Blind Group may also have specific requirements that
result clothing demands, for example, because their work raises health and safety risks. Where this is the case
uniforms and appropriate protective clothing will be issued to employees.
3.4 We expect employees to take a sensible approach to their dress and personal appearance in the context of
their own role, the expectations of their manager and the standard of the company. Any queries employees
have regarding the operation of our policy (including whether an article of clothing is suitable to wear to work)
should be directed to in the first instance to their line manager.

3.5 This policy applies equally to all employees and supply staff. Agency staff working with the Royal Blind Group
and other contractors will be required to comply with the principles outlined for the duration of their service
provision, however their own organisation’s policies will apply to issues of concern.
3.6 This policy does not form part of any employee’s contract of employment. It will be reviewed regularly and may
be amended from time to time as required by the Royal Blind Group and employment legislation. An up-to-date
version of the document can be accessed on the Intranet or obtained from the employee’s line manager or
Human Resources Department.

4. Dress and Personal Appearance requirements

4.1 While working for the Royal Blind Group employees represent the organization (with clients, service users and
the public). Our employees’ appearance contributes to our reputation and image.
4.2 We expect our employees to follow the requirements below in relation to their dress and personal appearance
at work within the Royal Blind Group.
 Where we provide safety clothing and equipment, including protective footwear, it should be worn or used as
appropriate and directed.
 Where we provide uniform, this must be always worn.
 All employees must always appear clean and smart.
 Employees should not wear gym clothing to work except if their role specifically requires this. This includes track
suits, sports t-shirts (including football colours) and jogging bottoms.
 Employees should not wear any item of clothing to work that carries wording or pictures that might be offensive
to others (including slogans).
 Employees should not wear clothing to work that exposes areas of the body which would normally be covered at
work such as cut off shorts, hot pants, crop tops and items made of see through material.
 Employees must not display any item of underwear.
 Employees clothing should not wear clothing to work that is dirty, frayed or torn.
 Employees should not wear clothing or jewellery to work that could present a health and safety risk to them, to
colleagues or to service users/customers.
  Employees must not have exposed tattoos that contain any content which the management considers offensive
to others.
 Employees should ensure that items of make-up, such as false nails, do not inhibit their ability to carry out their
work.
 Employees’ footwear must be safe, clean and take account of health and safety considerations for the role they
are carrying out.
4.3 Employees delivering direct and personal care are expected to follow the additional requirements below:
 Where uniform is worn, it must never be worn outside the work premises
 Employees with long hair must have their hair always tied back.
 Employees are not allowed to wear any jewellery apart from ear studs and wedding band.

5. Implementing the Dress and Personal Appearance Policy.

5.1 Managers are responsible for ensuring that staff observe the standards always set by this dress code.
5.2 Failure to comply with this policy may result in action under the Royal Blind Group Disciplinary Policy.
 6. Cyber security and digital devices

This section deals with all things digital at work. We want to set some guidelines for using computers, phones, our
internet connection and social media to ensure security and protect our assets.

6.1 Internet usage

Our corporate internet connection is primarily for business. But you can occasionally use our connection for personal
purposes if they don’t interfere with your job responsibilities. Also, we expect you to temporarily halt personal activities
that slow down our internet connection (e.g. uploading photos) if you’re asked to.

You must not use our internet connection to:

 Download or upload obscene, offensive or illegal material.
 Send confidential information to unauthorized recipients.

 Invade another person’s privacy and gain access to sensitive information.

 Download or upload pirated movies, music, material or software.
 Visit potentially dangerous websites that can compromise our network and computers’ safety.
 Perform unauthorized or illegal actions, like hacking, fraud or buying/selling illegal goods.

6.2 Cell phone

We allow use of cell phones at work. But we also want to ensure that your devices won’t distract you from your work or
disrupt our workplace. We ask you to follow a few simple rules:
 Use your cell phone in a manner that benefits your work (business calls, productivity apps, calendars.)
 Keep personal calls brief and use an empty meeting room or common area so as not to disturb your
colleagues.
 Avoid playing games on your phone or texting excessively.
 Don’t use your phone for any reason while driving a company vehicle.
 Don’t use your phone to record confidential information.
 Don’t download or upload inappropriate, illegal or obscene material using our corporate internet connection.

Also, you must not use your phone in areas where cell phone use is explicitly prohibited (e.g. laboratories.)

6.3 Corporate email

Email is essential to our work. You should use your company email primarily for work, but we allow some uses of your
company email for personal reasons.
 Work-related use. You can use your corporate email for work-related purposes without limitations. For
example, you can sign up for newsletters and online services that will help you in your job or professional
growth.
  Personal use. You can use your email for personal reasons if you keep it safe and avoid spamming and
disclosing confidential information. For example, you can send emails to friends and family and download
eBooks, guides and other safe content for your personal use.

Our general expectations

No matter how you use your corporate email, we expect you to avoid:
 Signing up for illegal, unreliable, disreputable or suspect websites and services.
 Sending unauthorized marketing content or emails.

 Registering for a competitor’s services, unless authorized.

 Sending insulting or discriminatory messages and content.
 Spamming other people’s emails, including your coworkers.

In general, use strong passwords and be vigilant in catching emails that carry malware or phishing attempts. If you are
not sure that an email you received is safe, ask our [Security Specialists.]

7. Social media

We want to provide practical advice to prevent careless use of social media in our workplace. We address two types of
social media uses: using personal social media at work and representing our company through social media.

6.1 Using personal social media at work

You are permitted to access your personal accounts at work. But, we expect you to act responsibly, according to our
policies and ensure that you stay productive. Specifically, we ask you to:
 Discipline yourself. Avoid getting sidetracked by your social platforms.
 Ensure others know that your personal account or statements don’t represent our company. For
example, use a disclaimer such as “opinions are my own.”
 Avoid sharing intellectual property (e.g. trademarks) or confidential information. Ask your manager first
before you share company news that’s not officially announced.
 Avoid any defamatory, offensive or derogatory content. You may violate our company’s anti-harassment
policy if you direct such content towards colleagues, clients or partners.

6.2 Representing our company through social media

If you handle our social media accounts or speak on our company’s behalf, we expect you to protect our company’s
image and reputation. Specifically, you should:
 Be respectful, polite and patient.
 Avoid speaking on matters outside your field of expertise when possible.

 Follow our confidentiality and data protection policies and observe laws governing copyrights, trademarks,
plagiarism and fair use.
 Coordinate with our [PR/Marketing department] when you’re about to share any major-impact content.
 Avoid deleting or ignoring comments for no reason.
  Correct or remove any misleading or false content as quickly as possible.

8. Employee relationships

We want to ensure that relationships between employees are appropriate and harmonious. We outline our guidelines,
and we ask you to always behave professionally.

7.1 Dating colleagues

If you start dating a colleague, we expect you to maintain professionalism and keep personal discussions outside of
our workplace.
You are also obliged to respect your colleagues who date each other. We won’t tolerate sexual jokes, malicious gossip
and improper comments. If you witness this kind of behavior, please report it to HR.

7.2 Dating managers

To avoid accusations of favoritism, abuse of authority and sexual harassment, supervisors must not date their direct
reports. This restriction extends to every manager above an employee.
Also, if you act as a hiring manager, you aren’t allowed to hire your partner to your team. You can refer them for
employment to other teams or departments where you don’t have any managerial or hiring authority.

7.3 Friendships at work

Employees who work together may naturally form friendships either in or outside of the workplace. We encourage this
relationship between peers, as it can help you communicate and collaborate. But we expect you to focus on your work
and keep personal disputes outside of our workplace.

7.4 Employment of relatives

Everyone in our company should be hired, recognized or promoted because of their skills, character and work ethic.
We would not like to see phenomena of nepotism, favoritism or conflicts of interest, so we will place some restrictions
on hiring employees’ relatives.
To our company, a “relative” is related by blood or marriage within the third degree to an employee. This includes
parents, grandparents, in-laws, spouses or domestic partners, children, grandchildren, siblings, uncles, aunts, nieces,
nephews, stepparents, stepchildren and adopted children.

As an employee, you can refer your relatives to work with our company. Here are our only restrictions:
 [You must not be involved in a supervisory/reporting relationship with a relative.]
 [You cannot be transferred, promoted or hired inside a reporting relationship with a relative.]

 [You cannot be part of a hiring committee, when your relative is interviewed for that position.]

If you become related to a manager or direct report after you both become employed by our company, we may have to
[transfer one of you.]

9. Workplace visitors

If you want to invite a visitor to our offices, please ask for permission from our [HR Manager/ Security Officer/ Office
Manager] first. Also, inform our [reception/ gate/ front-office] of your visitor’s arrival. Visitors should sign in and show
identification. They will receive passes and will be asked to return them to [reception/ gate/ front-office] once their visit
is complete.
When you have office visitors, you also have responsibilities. You should:
  Always tend to your visitors (especially when they are underage.)
 Keep your visitors away from areas where there are dangerous machines, chemicals, confidential records or
sensitive equipment.
 Prevent your visitors from proselytizing your colleagues, gathering donations or requesting participation in
activities while on our premises.

Anyone who delivers orders, mail or packages for employees should remain at our building’s reception or gate. If you
are expecting a delivery, [front office employees/ security guards] will notify you so you may collect it.

10. Solicitation and distribution

Solicitation is any form of requesting money, support or participation for products, groups, organizations or causes
which are unrelated to our company Distribution means disseminating literature or material for commercial or political
purposes. We don’t allow solicitation and distribution by non-employees in our workplace. As an employee, you may
solicit from your colleagues only when you want to:
 Ask colleagues to help organize events for another employee (e.g. adoption/birth of a child, promotion,
retiring.)
 Seek support for a cause, charity or fundraising event sponsored, funded, organized or authorized by our
company.
 Invite colleagues to employee activities for an authorized non-business purpose (e.g. recreation, volunteering.)
 Ask colleagues to participate in employment-related activities or groups protected by law (e.g. trade unions.)

In all cases, we ask that you do not disturb or distract colleagues from their work.

11. PENALTIES AND DISCIPLINARY ACTIONS

In penalizing an employee, the Company may impose primary disciplinary action alone or concurrently or successively
with one or more secondary disciplinary action/s, and/or any other disciplinary action.

A. Primary Disciplinary Actions

1. Verbal Warning. Is a verbal reminder and admonition to the erring employee of the infraction or offense of the
employee and a warning that the repetition of the same or commission of similar offense in the future would give rise to
grave penalties or disciplinary action.
2. Written Reprimand. Is a formal written notice which contains a summary of the acts and omissions of the employee
in violation of the Code and other Company policies, procedures, rules and regulations and a warning to the employee
that repetition of the same or commission of a similar offense in the future would give rise to grave penalties or
disciplinary action.
3. Suspension. This disciplinary action refers to the temporary removal of an employee from performing his work or
duties and serves as a warning that a repetition of the same or commission of a similar may warrant dismissal. During
the period of suspension, the employee shall not receive any salary(ies) or benefit(s) but will continue to be liable for
obligations to or paid through the company such as but not limited to payment of SSS Loan, salary loan, car loan,
housing loan, etc.
4. Termination. This refers to the cessation of employee’s service with the Company for just or authorized cause. An
employee whose employment is terminated shall forfeit all his employment benefits and privileges except those to
which he is entitled under the law. A terminated employee shall not be issued a clearance but is entitled to a Certificate
of Employment.
5. Table below summarizes the disciplinary action/s that corresponds to each class of offense committed:

Occurrence Penalty
Serious Offense
1st Offense Suspension or dismissal (depending on the attending circumstances)
2nd Offense Dismissal
Less Serious Offense

Written reprimand to suspension of 3 working days depending on the

1st Offense circumstances

Suspension of 5 working days or dismissal depending on the gravity of

2nd Offense the offense and the attending circumstances
 Suspension of 10 working days or dismissal depending on the gravity
3rd Offense of the offense and the attending circumstances
4th Offense Dismissal
Minor Offense
1st Offense Verbal reprimand
2nd Offense Written reprimand

Written reprimand to suspension of 3 working days depending on the

3rd Offense circumstances

Suspension of 5 working days or dismissal depending on the attending

4th Offense circumstances

Suspension of 10 working days or dismissal depending on the

5th Offense attending circumstances

Suspension of 15 working days or dismissal depending on the

6th Offense attending circumstances
7th Offense Dismissal

B. Secondary Disciplinary Actions

1. Disqualification from Salary Increases or their equivalent.
2. Disqualification from Promotion for a given period.
3. Forfeiture. The Company may, at its sole option and discretion, forfeit all other forms of
compensation, like program-based monetary and non-monetary incentive schemes and awards.
4. Restitution. The employee shall be required to repay or give back the equivalent amount of the loss
or damage sustained by the Company, its employees, clients or other parties doing business with the
Company, because of an act or omission of the employee.

11. Guidelines in the Application of Penalties

1. Only one (1) penalty shall be imposed for each case. “Each Case” means one (1) administrative charge
which may involve one or more charges or counts.
2. The Management shall determine the appropriate penalties to be imposed taking into consideration
mitigating and aggravating circumstances and all other circumstances. Mitigating circumstances are
circumstances which may either decrease the nature of the offense committed and the applicable penalty or
off-set the aggravating circumstances, if any. Examples of mitigating circumstances are:
a. First Offense
b. Good faith
c. Due diligence and no intention to commit so grave a wrong.
d. Sufficient Provocation, threat, coercion, Inducement from the other part
e. Voluntary admission.

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