At Oxwash, we strongly believe in promoting a culture of openness, trust, and integrity. Our vision, mission, and values are all centred around our commitment to ethical business conduct. To ensure that this commitment is upheld, we have put together a Code of Ethics that serves as a guide for all individuals and entities associated with our organisation. This Code of Ethics is endorsed and reinforced by our CEO and founders and applies to everyone we employ or have business relations with, including employees (including interns, volunteers, and members of our Board) as well as business entities such as vendors or venture capital companies.
Company Foundation and Governance
Policy Brief & Purpose
Our professional code of ethics policy provides clear guidelines on our business ethics and stance on controversial matters for our team members. We trust our employees to use their best judgement, but we also want to provide them with a concrete guide they can depend on if they're unsure about how they should act. This policy is created to provide a framework and guidance on Oxwash’s approach to achieving and maintaining good business behaviour using sound ethical conduct. It ensures that all employees and other entities that Oxwash does business with are aware of their individual and collective responsibilities about Oxwash’s ethics and emphasises our expectations of being treated fairly and with good business practices. All employees are responsible for reading this document in its entirety and ensuring that they comply with all the policy requirements as stated within this document.
The purpose of the Code of Ethics is to maintain a culture of openness, trust, and integrity in Oxwash’s business practices. Effective ethics involve the participation and support of every Oxwash employee. Oxwash is committed to protecting employees, business partners, and suppliers from illegal or damaging actions by individuals, knowingly or unknowingly. The Code of Ethics is designed to guide employees in situations where they might be unsure of how to act. While some professional ethics correspond to laws that must be followed, there are some circumstances where there may be grey areas. This is when the Code of Ethics will provide guidance.
Legal & Regulatory Compliance
At Oxwash, we are committed to adhering to all legal and regulatory requirements in every jurisdiction we operate. Our dedication to compliance is unwavering, ensuring the highest standards of conduct in all business practices.
Transparent Accounting
Transparency is a cornerstone of our business. We are committed to maintaining proper financial management, ensuring honesty and transparency in our financial statements.
Social Responsibility
Diversity, Equality and Inclusion
Oxwash acknowledges that everyone has unique qualities to offer and seeks to respect and understand these differences. We believe in promoting equal opportunities throughout our business, where everyone can participate and has the same opportunity to fulfil their potential.
To comply with our obligations under the Equality Act (2010), we are committed to preventing unfair discrimination, harassment, and victimisation, advancing equality of opportunity, and fostering good relations between people with a protected characteristic and those with none.
We recognise that Diversity values the full range of differences between people, both in the workplace and in wider society. It acknowledges that entry into the workplace and an individual's potential can be influenced by a range of factors beyond the characteristics included within equality legislation.
Inclusion is about an individual's experience within both the workplace and in wider society, and the extent to which they feel valued and included. It's mandatory to respect everyone you interact with, and be kind, polite, and understanding. You must respect others' personal space, opinions, and privacy. Any kind of violence is strictly prohibited, as well as harassing or victimising others.
To learn more about what constitutes harassment, victimisation, and bullying, please read the Oxwash Bullying and Harassment Policy. If anyone that you interact with, whether a colleague, customer, or other stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to your manager. You can also report rudeness and dismissiveness if they become excessive or frequent.
Preventing Sexual Abuse and Exploitation
Oxwash fully upholds principles of freedom of speech and of protection of victims of sexual abuse and exploitation. Any direct or indirect participation in sexual exploitation and abuse as defined in this policy is prohibited for Oxwash employees, partners or contractors, as well as other entities mentioned in this policy. Under no circumstances shall Oxwash staff and the other entities mentioned in this policy, take undue advantage of their professional position for their personal interest or to obtain a favour of a sexual nature.
For this policy, the term “sexual exploitation and abuse” includes:
Sexual harassment,
Abuse of power to obtain sexual favours,
Rape,
Sexual assault,
Sexual relations with a minor,
Paid sexual relations,
Human trafficking sex-related.
“Sexual harassment” is characterised by the repeated imposition of sexual comments or behaviours on a person that:
Are degrading because of their degrading or humiliating nature,
or
Create an intimidating, hostile or offensive situation for the person concerned.
Sexual harassment includes a large number of prohibited behaviours such as:
Physical assaults of a sexual nature, such as rape or sexual assault, attempts to commit such acts or
Physical intent such as touching, pinching, fondling or any other gesture against the body of another individual;
Sexual advances, sexual proposals or comments with sexual connotations such as equivocal gestures,
Noises, remarks, jokes or comments about a person’s sexuality or sexual experiences;
Any employee found to have violated this policy will face disciplinary action, which may include a warning or termination of their employment contract for serious misconduct. In such cases, no notice will be given and no compensation will be paid. Depending on the severity of the offence, Oxwash may also report the matter to the relevant law enforcement authorities for further investigation and legal action.
Anti-Bribery and Corruption
At Oxwash, we highly value upholding fair business practices. We are committed to promoting and maintaining the highest levels of ethical standards concerning all of our business activities. Our reputation for maintaining lawful business practices is of paramount importance. Therefore, we have a zero-tolerance policy towards bribery and corruption, and we are committed to acting fairly and with integrity in all of our business dealings and relationships. We implement and enforce effective systems to counter bribery.
Our Anti-Bribery Policy sets out Oxwash’s position on any form of bribery and corruption. It provides guidelines aimed at:
1. Ensuring compliance with anti-bribery laws, rules and regulations;
2. Enabling employees and persons associated with Oxwash to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent, and report any wrongdoing, whether by themselves or others;
3. Providing suitable and secure reporting and communications channels and ensuring that any information that is reported is properly and effectively dealt with; and
4. Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.
The Anti-Bribery policy applies to all permanent and temporary employees of Oxwash (including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with Oxwash or who performs functions concerning, or for and on behalf of, Oxwash. This includes but is not limited to directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers, and sponsors ("associated persons").
All employees and associated persons are expected to adhere to the principles set out in this Anti-Bribery and Corruption policy. This policy states that employees and others acting for or on behalf of Oxwash are strictly prohibited from making, soliciting, or receiving any bribes or unauthorised payments, including kickbacks. As part of its anti-bribery measures, Oxwash accepts transparent, proportionate, reasonable, and bona fide hospitality and promotional expenditure, whether given or received. For more information, please read the Oxwash Anti-Bribery Policy.
Environmental Care
We recognise that our operations have a significant environmental footprint. To address these material issues, we have developed an Environmental policy that drives our investment in cutting-edge equipment and technologies that minimise water usage and optimise energy efficiency. We monitor and track our emissions, constantly striving for reduction targets.
All employees at Oxwash play a role in environmental responsibility. Through regular training and awareness initiatives, we encourage sustainable practices and cultivate a culture of environmentally conscious decision-making throughout our company.
External Relations
Political and Charitable donations
Political donations involve providing cash, venues, equipment, personnel time, or other benefits to a political party, an individual running for office, or an entity connected to political figures. Charitable donations entail similar support to charities or individuals associated with charitable causes.
Guidelines for Political and Charitable Donations
Political Contributions
Oxwash strictly prohibits political donations by or on behalf of the organisation to counter corruption risks. Personal political donations by employees are allowed, but they should not be linked to decisions by public sector bodies related to Oxwash's business.
Charitable Contributions
While Oxwash recognizes the importance of charitable giving, it controls the risk associated with donations to charities connected to political entities or involved in contractual activities. Charitable donations are not universally prohibited but are subject to due diligence.
2. Controls
Oxwash implements effective controls for charitable donations to minimise corruption risks.
Consideration of Intention
Always assess whether the intention behind a donation could influence someone to act improperly; if so, refrain from donating.
Perception Tests
Apply the "Newspaper Test" to evaluate potential public perception and the "Prosecutor Test" to assess explanations in case of corruption allegations.
Legal and Regulatory Environment
Ensure compliance with local laws and recipient regulations before making any donation.
Due Diligence on Charities
Conduct reasonable and proportionate due diligence on charities to identify connections with Oxwash's business transactions or potential involvement.
Cautious Donations
Exercise caution when donations could be perceived to influence decisions in favour of the organisation.
Public Disclosure Consideration
Assess whether public disclosure of donations is required by law or if voluntary disclosure can enhance transparency and mitigate corruption perception.
CEO Approval
Obtain advance approval from Senior Leadership, including the CEO, for charitable donations. Document reasons for the donation, ensuring satisfaction that it is appropriate and not corrupt.
f) Recordkeeping
Maintain a comprehensive register or appropriate record of all given and received charitable donations.
By adhering to these guidelines, Oxwash aims to ensure ethical practices in political and charitable contributions, fostering transparency and integrity in all donation-related activities.
Sponsorship
Sponsorship is the act of providing financial support or funding for an activity in exchange for advertising or other benefits. Oxwash is committed to complying with all applicable laws and regulations when it comes to sponsorships. We will not engage in any illegal or unethical activities in connection with our sponsorships.
To ensure transparency, all sponsorship arrangements by Oxwash will be documented in writing. We will deal directly with the entity or event that we are sponsoring, without using intermediaries.
At Oxwash, we prioritise sponsorship projects that have ongoing benefits rather than one-off events. These projects will be implemented at the corporate level.
Internal Conduct
Integrity
At Oxwash, integrity is a core value that we aim to uphold throughout all levels of the business. We have fostered a company culture that promotes trust and respect among employees. We expect all employees to act honourably and follow strong moral and ethical values. Integrity is vital in decision-making, customer service, and interactions with colleagues.
This is how employees are expected to practise integrity in their daily work:
Keep your commitments to show that you are reliable.
Be honest and transparent when communicating with others.
Hold yourself accountable for your actions and own up to your mistakes.
Avoid gossiping about others.
Keep your promises to your colleagues.
Set a positive example for colleagues by being optimistic and encouraging.
Remain respectful during conflicts and disagreements.
Take responsibility for your actions and admit when you make mistakes.
Treat Oxwash's and your colleagues' property with care and respect. Never use company property for personal use or steal from others.
Conflict of interest
A conflict of interest occurs when an employee's or board member's private interest interferes with Oxwash's interests. Oxwash has a responsibility to maintain trust with all its stakeholders by being transparent about situations that may give rise to such conflicts. Conflict of interest may take many forms, including but not limited to, employees using their position at Oxwash for personal gain, engaging in activities that could bring direct or indirect profits to competitors, owning shares of a competitor's stock, using connections obtained through Oxwash for private purposes, using Oxwash's equipment or means to support an external business, or acting in ways that could compromise Oxwash's legality, such as taking bribes or bribing legal authorities.
Employees should bring to management's attention any conflicts of interest they understand or suspect so that corrective actions can be taken. Managers must also monitor potential conflicts of interest of their subordinates. The responsibility for resolving conflicts of interest begins with the immediate line manager and may go up to senior management. All conflicts of interest will be resolved as fairly as possible. Senior management has the responsibility for making the final decision when a solution cannot be found. In general, employees are advised to avoid letting personal and/or financial interests and external activities conflict with the company's fundamental interests.
Employee Conduct
Legal commitments
All employees of Oxwash are required to comply with all relevant legislation that applies to our company. If you are involved in creating contracts, clauses, disclaimers, or online content that may be governed by law (such as consent forms), always seek verification from your manager before finalising anything. Our confidentiality and data protection policy covers all Oxwash employees. You must not jeopardise the information of customers, team members, stakeholders, or our business. You must adhere to all laws related to fraud, bribery, corruption, and any kind of assault. You are also required to follow laws on child labour and avoid doing business with unlawful organisations as outlined in the Oxwash Modern Slavery Statement. If you are unsure about the law in a particular situation, please consult your line manager. Or Oxwash’s legal consultants
Fairness
Oxwash expects all employees to be fair and follow these principles:
Zero tolerance to exploitation of others, their work or their mistakes.
Be objective when making decisions that could affect other people. Always justify any decision with written records or examples. Use the most objective methods possible. For example, when interviewing candidates, ask the same questions to all candidates. Avoid judging non-job-related criteria, such as dress or appearance.
When exercising authority, always strive to be as fair as possible.
Do not show favouritism towards specific team members. Be transparent when you decide to praise or reward a team member.
If you need to raise a formal disciplinary action with a team member, prepare a case with the People team that you can present to the leadership.
Be fair to customers or vendors. If you think our company was in the wrong, be honest about it and discuss with your manager to find solutions that benefit both parties.
Teamwork and cooperation
We expect everyone to do their part and avoid any actions that disrupt or harm others in their group. It is important to promote teamwork by acknowledging the team leader, respecting their judgement and authority, and following their requests or directives without questioning them in a hostile or demeaning way. Mutual respect is the underlying factor that drives teamwork. If you know of anyone who intends to harm the company or their team, please inform your manager. We expect you to work diligently, complete your share of work within set timelines, and constantly strive for improvement. We encourage ambition, a willingness to learn and curiosity, and participation in employee training and development.
Well-being and Safety
Health & Safety
Our employees are expected to prioritise health and safety in all aspects of their work. This commitment involves adhering to established safety protocols, reporting hazards promptly, and actively participating in safety training programs. Each employee must contribute to maintaining a safe and healthy workplace by following guidelines, using personal protective equipment when required, and immediately reporting any incidents or unsafe conditions to their supervisor.
By fostering a culture of responsibility and vigilance, we collectively ensure the well-being of every individual in our workplace.
Innovation and Customer Focus
Responsible Innovation
We encourage our employees to embrace responsible innovation, fostering creativity while maintaining ethical standards. This commitment involves considering the potential impact of new ideas on our products, customers, and the environment. Employees are expected to adhere to regulatory requirements, prioritise product safety and quality, and seek sustainable solutions. By promoting responsible innovation, we aim to contribute positively to society while upholding the values that define our organisation.
Treatment of Customers
Our employees play a crucial role in shaping positive interactions with our customers. We expect each team member to prioritise honesty, transparency, and exceptional service. This commitment involves providing accurate information about our products and services, promptly addressing customer inquiries or concerns, and ensuring fair and respectful treatment for every customer. Employees are encouraged to build long-term relationships based on trust, reliability, and a dedication to exceeding customer expectations. By embodying these principles, our team contributes to a positive and enduring customer experience.
Treatment of Suppliers
The way we treat our suppliers reflects our commitment to integrity and ethical business practices. Employees are expected to engage with suppliers honestly, transparently, and with respect. This commitment includes fair negotiations, timely payments, and collaboration to uphold ethical and environmental standards throughout our supply chain. We strive to build strong and mutually beneficial relationships with our suppliers, recognizing their importance in our overall success. By conducting ourselves with integrity in supplier relationships, we contribute to a sustainable and responsible business ecosystem.