Code of Conduct
The LEA Group is committed to the economic development of the countries in which we operate and to respect their laws, culture, customs and traditions. Our reputation is a key business asset and is essential for our long term success. This Code of Conduct sets out the professional, ethical and social values that are an integral part of our corporate culture and which provide a framework to guide decision-making and action within the organization.
To Whom this Code of Conduct Applies
This Code of Conduct applies to all the operating companies of the LEA Group and of its employees, including those working in a contractual relationship. All the employees and Contractual staff must:
- Read and understand this Code of Conduct and seek clarifications if any aspect is unclear.
- Understand what may constitute a violation of this Code and ensure compliance.
- Report any suspected violations of this Code immediately.
Each operating company will be responsible for preparing and implementing a training program for those employees to whom the specific policies contained in this Code of Conduct apply.
Where appropriate, this Code of Conduct applies to all joint venture partners, associated firms, sub-consultants and suppliers with whom we have contractual relationships. Representatives of these entities will certify their compliance with the LEA Group policies and procedures of this Code of Conduct and all applicable anti-corruption laws of the jurisdictions within which we operate.
Chief Compliance Officer
The LEA Group has assigned responsibility for the implementation of this Code of Conduct to our Chief Compliance Officer, who in consultation with the Board of Directors establishes procedures necessary to implement this Code of Conduct, periodically monitors compliance and confirms that adequate employee training is provided.
Reporting and Discipline
Should any person employed by the LEA Group or associated with us observes potentially illegal or unethical behaviour that could potentially be considered a violation of this Code of Conduct or related procedures, they should inform the Chief Compliance Officer. Information can be communicated anonymously. Reports of potential misconduct will be investigated and the concerned employee’s cooperation will be sought, if needed.
Failure to report violations will be treated as a violation of this Code of Conduct. Reactions of any sort against anyone who reports a potential violation in good faith is prohibited and will not be tolerated.
Violations of this Code of Conduct and related policies and practices will be taken seriously. Violators will be subject to disciplinary action including summary dismissal.
This document presents the principles of our Code of Conduct. More detailed information will be provided to help guide all those to whom the Code of Conduct applies. All supplementary information will be considered part of the Code of Conduct. As stated above, if any aspect of this Code of Conduct is unclear or if you have any questions, please contact the Chief Compliance Officer either directly or through your HR Department or your immediate supervisor.
We will always act honestly and fairly and will not engage in any corrupt activities or fraudulent practices.
- Corrupt and or fraudulent practices will include, but not be limited to:
- Accepting or paying any money to clients or their representatives, suppliers or vendors in order to influence any decision;
- Accepting cash or favours from contractors, suppliers or vendors for a consideration;
- Accepting or giving undue favours directly or indirectly in order to facilitate or where it could be seen to facilitate the circumvention of established company rules and practices, resulting in compromises in quality and or quantities;
- Participate in abnormal or questionable business dealings that are seen to violate the spirit of this code of conduct.
- We will conduct our business in compliance with applicable Canadian and Indian laws and regulations as well as the applicable laws and regulations of all other countries in which we are operating.
- We believe in open and fair competition and only seek competitive advantage through ethical and lawful means and will not seek to gain advantage by acting fraudulently or by making false claims and we will not instruct anyone to do so, on our behalf.
- We will comply with all applicable anti-corruption laws of Canada, India, the United States of America, all other countries in which we operate or are deemed to operate as well as the anti-corruption code of the World Bank, the Asian Development Bank and other international financial institutions with whom we have contractual obligations.
- The LEA Group prohibits any kind of “facilitation payment” or payment for “expediting” or securing performance of routine, non-discretionary action of the client agencies.
- We will not offer or receive bribes or improper payments. Specifically, our personnel are prohibited, on behalf of the organization, from offering, promising, authorizing or paying cash or giving valuables or favours directly or indirectly for the purposes of :
- Influencing any acts or decisions of representatives of client agencies, directly or indirectly;
- Inducing any representatives of clients to undertake or omit to do any acts in violation of the lawful duties of such representatives;
- Securing any improper advantages;
- Influencing representatives of clients to use their official position to change decisions of client agencies.
- We permit modest gifts and hospitality for the purpose of building business relationships or showing appreciation or for seasonal greetings. Please seek guidance from the management of your operating company in order to determine what is considered appropriate before giving any gifts or providing hospitality.
- No employees will make payments or donations to any political parties, politicians or candidates for public office without approval of the Board.
- In case any LEA Group personnel, including employees, consultants, members of joint venture or associate firms, vendors or suppliers indulge in corrupt or fraudulent activities (as defined above), the employee is doing it on his own volition and such activities are not authorized and will not be subsequently approved by LEA Group Management or Board members.
- We will avoid situations in which personal interests or actions conflict with our clients or company’s best interests.