Compliance Principles

The following serve as the core Maloney Compliance Principles:

Integrity

Maloney Commodity Services (Maloney) shall operate in a professional, independent and impartial manner in all its activities.

Maloney shall carry out its work honestly and shall not tolerate any deviation from its approved methods and procedures. Where approved test methods make provision for tolerances in results, Maloney Commodity Services shall ensure that such tolerances are not abused to alter the actual test findings.

Maloney shall report data, test results and other material facts in good faith and shall not improperly change them, and shall only issue reports and certificates that correctly present the actual findings, professional opinions or results obtained.

 

Conflicts of interest

Maloney shall avoid conflicts of interest with any related entity in which it has a financial or commercial interest and to which it is required to provide services.

Maloney shall avoid conflicts of interest between Maloney Commodity Services companies and/or divisions engaged in different activities but which may be providing services to either the same client or each other.

Maloney shall ensure that its employees avoid conflicts of interest with its activities.

 

Confidentiality

Maloney shall treat all information received in the course of the provision of its services as business confidential to the extent that such information is not already published, generally available to third parties or otherwise in the public domain.

 

Anti-bribery

 Maloney shall prohibit the offer or acceptance of a bribe in any form, including kickbacks on any portion of a contract payment.

Maloney shall prohibit the use of any routes or channels for provision of improper benefits to, or receipt of improper benefits from, customers, agents, contractors, suppliers, or employees of any such party, or government officials.

 

Fair marketing

Maloney shall only present itself and conduct marketing, including any comparisons with or references to competitors or their services, in a manner that is truthful and not deceptive or misleading or likely to mislead.

 

Management Assurance to Employees

Maloney management is committed to operating in a manner consistent with its Compliance Principles and as such offers assurance to its Employees that they will not suffer demotion, penalty or any other adverse consequences arising from strict implementation of these Principles even if it may result in a loss of business.