Our Code of Conduct

Our Code of Conduct gives us the guidance and support we need to conduct our business ethically and to comply with the law. Itrepresents our commitment to doing the right thing. By being part of Foster & Odan Group you are agreeing to uphold this commitment. If you do not, you could put yourself, your colleagues and the group at risk. Put simply, failure to follow this Code is misconduct, which could result in disciplinary action and even dismissal.

What are managers expected to do?

  • Ensure the Code is understood by those they manage;
  • Provide advice and guidance on interpreting the Code;
  • Uphold and promote the requirements of the Code;
  • Individually sign their acceptance of the Code each year.

How to raise a concern or ask a question?  

Foster & Odan Group aims to conduct business with the highest standards of ethics, honesty and integrity, and recognises that workers have an important role to play in maintaining this aim. Any worker providing services to the group concerned about any form of malpractice, improper action or wrongdoing by the Company, its employees or other stakeholders is strongly encouraged to report the matter.

We believe it is essential to create an environment in which individuals feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against them, that they will be taken seriously and that the matters will be investigated appropriately and as far as practicable be kept confidential.

We believe that any employee with knowledge of wrongdoing should not remain silent. We take all matters of malpractice, improper action or wrongdoing very seriously and you are strongly encouraged to raise incidents or behaviours that are not in accordance with the Code, or the policies to which it refers, by following the procedure set out below:

Line Manager

In the first instance, you should consider raising your concern with your line manager. He/she has a responsibility to listen and respond to any matter that is of concern to you. Concerns can be raised verbally or in writing. They may be able to agree a way of resolving your concern quickly and effectively.

Senior Manager

If you feel that you cannot raise your concern with your line manager, for whatever reason, you should contact the senior manager in your business, who will consider the matter and, if appropriate, manage any investigation.

Bribery and Corruption

We do not give or accept improper payments or gifts in order to conduct business anywhere in the world. We agree the terms of supplier payments at the start of business and pay in accordance with our contractual obligations.

We operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by workers or anyone else acting on the Company’s behalf.

You should not get involved in any business transactions that could result in personal benefit. You should not use your position as a worker to get discounts from contractors/suppliers unless they are corporate agreed discounts notified and made available to all workers, or do personal business, unless expressly authorised by management.

Bribery, Gifts and Entertainment

All workers are required to declare offers and/or receipts of individual gifts, hospitality and entertainment to their line manager.

Bribery is not acceptable in general terms, but if you are in any doubt as to whether any conduct could amount to bribery, the matter should be referred to the Mr. David Adolph, Group Secretary.


Fraud is deemed gross misconduct. Disciplinary procedures will be rigorously applied to any instances of fraud which will result in dismissal.

The group  defines Fraud as the deliberate action by any person, or deliberately allowing an action to be taken, to create, falsify, destroy, deface, or conceal any account, balance, record or document, or impersonate, deceive, or misuse their position with the intention of:

  • Obtaining money, assets, services, information or any other benefit which would otherwise be denied;
  • Distorting personal or business performance;
  • Causing a loss to the Company or another party (eg supplier, third party contractor, customer or worker);
  • Prejudicing the group’s rights, competitive position or business reputation, or those of another party (as above);
  • Attempting or assisting in any of the above.

Workers must follow group procedures when dealing with the group’s property, goods and cash. When dealing with financial transactions you must also follow Company policies, including Invoice Authorisation Controls, Non- Merchandise Contracts Approval Process and Group Expenditure and Commitment Approval Policy.

When travelling and claiming expenses you must follow the Business Travel and Expenses Policy.

Conflicts of Interest

You should not put yourself in a position where you are involved in an activity for personal gain, to you or your family, which conflicts with the group’s interests. Conflicts of interest can take many forms including, but not limited to:

Engaging in any activity that competes with the group;
Taking personal advantage of an opportunity that belongs to the group;
Engaging in a business relationship on behalf of the group where you or a family member has an interest in the other party, unless previously advised to, and agreed by, management.

Working Relationships

This section sets out the group’s key policies and procedures.


The Foster & Odan Group values the loyalty and confidence of our customers above all else. We will not compromise the safety of our customers and will always strive to live up to and offer the highest possible standards of Quality, Value, Service, Innovation and Trust. We will always try to make sure our labelling, advertising and other forms of communication are clear, honest and accurate and we will always work to respect cultural and ethical beliefs.

We welcome customer feedback and try wherever possible to act on it to continually improve the service we offer. We make sure any complaints are handled fairly and professionally within appropriate timescales. Information that we hold about our customers will be handled properly and responsibly. It is our responsibility to protect our customers’ personal data.


All group colleagues work hard with the common aim of serving our customers. We are committed to equal opportunities. We treat everyone equally regardless of age, gender, gender reassignment, colour, ethnic or national origin, disability, hours of work, nationality, religion or belief, marital or civil partner status, disfigurement, political opinions or sexual orientation.

We treat all colleagues with dignity and respect and expect colleagues to treat each other and our customers in the same way. We all have a responsibility not to indirectly support unfair behaviour by ignoring what is happening around us. It is Company policy to promote an environment free from discrimination, harassment, and victimisation where everyone will receive equal treatment. All decisions relating to worker practices will be objective, free from bias, and based solely on work criteria and individual merit. In every set of circumstances we aim to find the ‘best fit’ between personal requirements and business needs.

As a company, the group is committed to provide clear, honest and accurate communication directly to colleagues.

We care about your wellbeing and will not compromise the health and safety of our employees. We will offer ongoing training and development to enhance your career opportunities within the Company or elsewhere.

The group recognises the importance of respecting your privacy and the need for appropriate safeguards in relation to the collection, storage and processing of personal data. We expect that all information held about employees will be dealt with properly and responsibly. It is everyone’s responsibility to handle information properly.

You must never knowingly provide false information to the Company or about the Company to anyone else. You must never use the Company’s name or resources for personal gain. The work and ideas that are created whilst working for the Company are owned by Foster & Odan Group.

Business Continuity

The Group aims to ensure that we are fully prepared and equipped to continue business in the event of a crisis or disaster at any location at any time. Each Business will set out the processes to be followed locally to recover and restart business after a crisis or disaster affecting locations, systems and business processes. You have responsibilities and your line manager will advise you of these following a major incident.
Fire, Health and Safety
Together we have a responsibility to maintain a healthy and secure workplace. The Company has a responsibility under legislation to protect the health, safety and welfare of all colleagues, customers and contractors on our premises. You have a responsibility to comply with safety rules and procedures and take reasonable care of your own health and safety and the health and safety of others who may be affected by your actions or omissions eg customers, colleagues, visitors and suppliers. Each of us has a responsibility for safety in the workplace.

Managers have a responsibility to make sure employees are aware of Health & Safety regulations and the need to report all accidents and dangerous occurrences to the appropriate person or department. You should never turn up for work under the influence of drink or drugs.

Social Networking Sites

The group recognises that its employees may use blogs or social networking sites in their personal time, both in and outside of work. These sites can be a useful and a fun way to keep in touch with friends and colleagues. You should be aware that information posted on these sites is public and may be viewed by colleagues, customers or the press. You have general obligations to act in the best interests of the group, and not breach confidentiality or the relationship of trust and confidence that exists between you and the Company. This would include posting inappropriate comments on blogs and social networking sites, for example about customers and colleagues.


All group buildings are smoke free. This means that smoking is not allowed anywhere on group premises, including our vehicles. To protect the image and reputation of the group, smoking is not

Fair Partnership

Foster & Odan Group sources products from around the world, respecting third party rights and design integrity to provide our customers with the best quality products. We are committed to being a fair partner that improves the lives and communities of those who work for and with us.

We work in partnership with all our suppliers to ensure that they comply at all times with high standards, in addition to requiring all suppliers to work towards achieving the adoption of recognised international standards.


We are committed to:

  • Reducing the carbon footprint of our operations, supply chain and products;
  • Protecting natural resources such as forests, water resources, the marine environment; and
  • Preventing waste and when this is not possible reusing and recycling all that we can.

We include environmental considerations in our decisions and specifications.

Health, wellbeing and the community

We are committed to promoting healthy lifestyles and wellbeing for our customers and employees via product innovation, the provision of information and encouraging active lifestyles.

We also work with and support a range of external partners to actively make a difference in local communities. We are committed to helping fight illness, tackle poverty and protect the environment in the communities where our customers and employees live as well as on an international scale where appropriate.

Information Governance

Information Governance is our system for handling and controlling information, including personal data, confidential materials, and other important information. We are committed to good Information Governance which involves compliance with all applicable legal and regulatory obligations, keeping data secure and ensuring that we are able to access and use information for legitimate business purposes.

Personal Data

We are committed to handling personal information in line with data protection laws. Wherever you work in the business, you have an important part to play in enabling us to meet this commitment.

Our Data Protection Policy sets out the rules which all employees must follow when handling personal information. It will help you ‘Do the Right Thing’ to protect yourself and our business, by protecting any personal information you handle.

The Data Protection Act 1998 gives individuals certain rights over the information
held on them by companies.  As an worker it is your responsibility to ensure
that all personal information is handled in compliance with data protection laws. This applies to all information, held on computer or in hard copy files, from which a person could be identifiable. Beware of people trying to obtain information to which they are not entitled. Do not access personal data about people without appropriate authorisation, only use it for legitimate legal or business purposes and only hold the information as long as is necessary to carry out the business or legal task.

Confidential Business Information

Information about future marketing or promotional activity, eg brand launches, promotions, sales should never be disclosed in advance of being announced. If information gets into the wrong hands it could affect our competitive advantage, cause financial loss, damage our reputation, or breach legal/regulatory requirements.

Use of Information Technology (“IT”)
The use of the group IT facilities are subject to the group’s IT policies and procedures which are aimed at protecting IT equipment, systems, networks and information including smart phones and other hand held devices. Using IT equipment inappropriately can result in the security of these systems being vulnerable.  Failure to follow and adhere basic security procedures including the guidance for users of small mobile computing devices (smart phones and PDAs) may result in disciplinary action up to and including dismissal. Deliberate or serious breaches may lead to criminal prosecution.
Innovation and Intellectual Property  

The group owns any inventions, discoveries, improvements, brands and designs you make during the course of your employment and all related intellectual property rights. The group will be entitled to the exclusive use of these rights, as far as the law permits and you will have no right to use them for your own purposes unless otherwise agreed in writing. Copyright and similar rights in work created during your employment will also be owned by the group and you agree to waive any moral rights you may have. It is also a term of your employment that you do everything necessary, during or after your employment, to enable the group - at its request and expense - to obtain patents, design, copyright, trade mark and similar protection in any part of the world.

For all matters relating to Code of Conduct please contact:
Mr. David Adolph,
Director, CIO International Limited
Email:  david.adolph@ciointernational.com
Tel:  +1 (647) 287-8001