Reviewed May 2018
We are proud to operate to the highest professional and ethical standards, setting ourselves above and beyond the requirements of the industry’s code of conduct. You can find more information on our Code of Conduct below.
This code applies to all employees of Decideum Ltd and also applies to agents acting on behalf of Decideum Ltd. as part of a contractual or sub-contractual agreement in which the main contractor (and the invoicing point for the work carried out by the agent) is Decideum Ltd.
- We will only act for reputable, bone fide organisations, whose identity and objectives are transparent.
- We will not act for organisations whose policies or objectives are invidiously discriminatory, or that deliberately carry out illegal activities, or which are considered a threat to national security.
- We will not advise on or participate in any activity that we consider illegal, offensive or defamatory and if we become aware of client activities that breach the Law we will bring this to the attention of the client and, if said activities continue, will cease to act for that client.
- We will not make extravagant, exaggerated or inaccurate claims to clients about the nature and extent of our influence. Similarly, we will not make extravagant, exaggerated or inaccurate claims on behalf of clients when making representations to anyone in the Government and political audiences.
- We will not claim, or attempt, to provide special or privileged access to elected representatives or public officials or to charge a fee in relation to any special, preferential access.
- We will remain morally and politically neutral in dealings with clients regardless of personal beliefs.
- We will not compel any member of staff to work on an account that represents a major conflict with their personal, moral or religious beliefs.
- We will comply with relevant codes of practice or regulations as these apply to clients, which are notified to us by clients and on which we are briefed by clients.
ACCURACY AND RELIABILITY
- We will provide clients with accurate, factual, balanced, timely and relevant information that is verified and referenced wherever possible using its original source. Where information is unverified, this will be clearly identified.
- We will use publicly available sources of information unless confidential information is voluntarily given and permission to use it is granted, in which case we will abide strictly by the terms of any such permission.
- We will preserve the integrity of information we acquire; maintaining its state of confidentiality and respecting at all times the intellectual property and copyright of individuals and organisations.
- The advice we provide to clients shall be fair and balanced, including alternative options and interpretations to assist clients in making informed decisions.
TRANSPARENCY AND OPENNESS
- We shall conform to all legal requirements for lobbying transparency that are applicable in every country in which we are active and ensure that all relevant staff are trained on such requirements.
- We shall not attempt to pass off the company or ourselves as being any other organisation, for the purpose of gaining access to an individual or organisation exerting influence on an individual or organisation or for any other purpose.
- We shall always identify our clients and ourselves at the earliest possible moment when conducting any communication with an elected representative or public official, or any person acting for or on their behalf, verbally or in writing, as appropriate.
- Only where there is a contractual agreement engaging the company (or a member(s) of staff) to work for a client organisation in a specific seconded role will staff state they are working for a client organisation, and they will only do so on matters relating to this role.
- We will not present ourselves in false roles to elicit information, obtain appointments or access individuals.
- We shall disclose immediately upon request a full list of clients to all public officials, officers, elected representatives and journalists, whose identity has been verified by us, as well as to our existing clients and prospective new clients.
- We shall normally refer directly to the relevant client, enquiries about the nature of our work for them. The exception to this shall be where the client gives express, written permission for us to answer such queries, in which case we shall normally secure the client’s approval for our response before communicating it.
- We shall comply with the General Data Protection Regulations (EU) 2016/679 .
INFLUENCE AND PRIVILEGE
- We shall not offer any financial inducements or apply improper influence to an elected representative or any person acting for or on their behalf, including public officials and advisors or any individual or organisation.
- We shall never exploit privileged access to, or relationship with, a public official or Parliamentarian that has been willingly and voluntarily granted by them in connection with a specific issue or client, for the purposes of addressing a separate issue or favouring a different client or to claim advantage for Decideum Ltd. for promotional or commercial purposes.
- We shall never arrange events (including political dinners of any sort) with Parliamentarians or public officials where attendance of these persons at such an event is dependent on payment of an entry fee or charge.
- We shall not employ or pay consultancy fees to any sitting elected national or regional representative, Peer or official or foreign power.
- We shall not procure or hold or use for the purpose of business any privileged pass or permit that allows access to non-public areas of a Parliament or Assembly, except where a specific pass exists for such purposes such as the European Parliament.
- We shall always conduct ourselves in a professional manner, with due regard for relevant recommendations from the Committee on Standards in Public Life and abiding by all statutes and rules of the public and private institutions and buildings which we visit and complying with all reasonable requests of staff employed in those premises.
- We shall ensure that we do not gain undue benefit as a result of activities taken by or on behalf of a client or as a result of privileged information gained as a result of same.
CONFLICTS OF INTEREST
- We shall report to a senior manager in the company all possible conflicts of interest as soon as possible.
- We shall not undertake to work with new clients where this work presents a possible conflict of interest to a current client for the duration of our contract.
- Where a conflict of interest occurs, the member of staff will have no further contact with the client or the account. A declaration will normally be made to the client, with the involvement of the individual staff member concerned.
- Where a conflict of interest occurs between two clients, we will either:
– Seek informed permission in writing from all parties involved, only proceeding if all agree.
– Resign from or cease to pursue one of the clients (depending on the circumstances).