Business Ethics & Compliance

Purpose and scope

PTS is committed to responsible business conduct in its customer, supplier and working relationships. This policy sets expectations for partners and personnel acting for PTS. Relevant requirements must also be communicated to contractors and suppliers as part of their engagement.

Honest representation

We describe our capabilities, experience and business status accurately. We do not invent customer relationships, testimonials, approvals or certifications. Product plans and concepts must be distinguished from available services and implemented capabilities.

Anti-bribery and fair dealing

We do not offer, request or accept bribes, kickbacks or improper advantages to obtain business or influence a decision. Gifts and hospitality must have a legitimate business purpose, be proportionate and comply with applicable rules. Anything that may influence a pending decision must be disclosed to a partner and declined where inappropriate.

Conflicts of interest

People acting for PTS must disclose actual or potential conflicts, including outside employment, personal relationships or financial interests that could affect a decision. The partners must agree and record a suitable response, which may include limiting access, reassigning a decision or declining work.

Confidentiality and intellectual property

Customer and third-party information must be used only for authorised purposes. We do not request or use materials obtained in breach of another employer’s, customer’s or supplier’s rights. Permissions and contractual terms must be respected when using source files, publications, software, images or trademarks.

Records and applicable requirements

Business records must accurately reflect transactions, approvals and delivery activities. Applicable legal, contractual and customer requirements must be identified for each engagement. We will seek clarification where requirements are uncertain and will not represent a general policy as proof that every requirement has been met.

Respectful working relationships

We expect fair and respectful treatment of colleagues and business contacts. Harassment, discrimination, intimidation and deliberate concealment of concerns are inconsistent with this policy.

Raising a concern

Send concerns to [email protected] with the subject “Compliance concern”. Include the relevant facts and information you are authorised to share. The PTS partners are responsible for handling concerns. If the concern involves a partner, you may address written correspondence to the other partner at our business correspondence address. The general email inbox is not an anonymous or independently operated reporting channel; avoid including sensitive details until an appropriate handling route is agreed.

We will assess reports fairly, limit disclosure to those who need to handle the matter and take proportionate action. We prohibit retaliation for good-faith reporting. Confidentiality will be respected as far as possible, but absolute anonymity or secrecy cannot be guaranteed where investigation or legal duties require disclosure.

Ownership and review

The partners are responsible for implementing this policy, recording significant decisions and addressing breaches. Review takes place at least annually and after material changes or significant concerns. Corrective measures may include changes to access, process, training or an engagement, subject to applicable agreements and law.