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13/10/2017 - EMI Ethics Policy


EMI Ethics Policy 

In all East Midlands Instrument Company Ltd’s (EMI) operations it is important to retain a set of core values and approaches to the process of doing business. The Company recognises its obligations to all those with whom it has dealings. The reputation of the Company and the trust and confidence of those with whom it deals are among its most vital resources, and the protection of these is of fundamental importance. The Company expects and maintains high ethical standards in carrying out its business activities.  Corrupt practices will not be tolerated.

The choices and decisions which we make from the Board Room down really do matter, our 'code of conduct' sets out how we do things at EMI and offers guidelines for ethical compliance in important policy areas. It applies to all employees from the Board down and defines the values that underpin our everyday decisions. It provides guidance for dealing with different situations that we may face from time to time. Ethical business behaviour depends on all of us accepting our responsibility for upholding the highest standards of behaviour and decision-making and challenging where we believe these values are compromised. The health, safety and welfare of our employees, environmental performance and protection employment practices to prevent forced labour underpin our values and benefits.

Relations with Customers

Everybody must play their part in providing quality and efficiency to customers. East Midlands Instrument Company Ltd believes that integrity in dealings with customers is a prerequisite for a successful and sustained business relationship. Personal contact, helpful and responsive action are features of the service we provide to develop long term relations with our customers.

This principle governs all aspects of the Company's approach to its customers. In all advertising and other public communications, untruths, concealment and overstatement will be avoided.

No employee may give money or any gift of significant value to a customer.  Nor may any gift or service be given which could be construed as being intended as a bribe.

The Company accords the same degree of confidentiality to confidential customer information as it does its own confidential information.

Relations with Competitors

The Company will compete vigorously, but honestly.

In any contacts with competitors, employees will avoid discussing proprietary or confidential information.

The Company believes service excellence to be the best way of enhancing its reputation. Whilst fair comparison between East Midlands Instrument Company Ltd’s strengths and competitors' weaknesses may be made, the Company will not engage in damaging competitors' reputations either directly or by implication, misrepresentation or innuendo.

Relations with Suppliers

East Midlands Instrument Company Ltd will aim to develop relationships with our suppliers based on mutual trust and all dealings will be conducted in a professional manner at all times. We also undertake to pay our suppliers on time and according to agreed terms. All supplier relationships are assessed against our Quality standards and feedback given to suppliers on a regular basis.

The receipt of gifts or favours by employees can give rise to embarrassing situations and may be seen as an improper inducement to grant some concession in return to the donor.  The following principles should be observed:

a) gifts or favours must not be solicited;

b) gifts of money must never be accepted;

c) reasonable small tokens and hospitality may be accepted provided they do not place the recipient under any obligation, are not capable of being misconstrued and can be reciprocated at the same level, and the employee's immediate line manager is made aware of the same.

Any offer of gifts or favours of unusual size or questionable purpose should be reported immediately to the employee's line manager and the Managing Director.

We expect our suppliers to comply with ethical, moral and fair trading practices which include safety & environmental provisions and employment practices, e.g. Modern Slavery Act 2015, Equality Act 2010 and appropriate employment practices.

Relations with Employees

East Midlands Instrument Company Ltd values its employees as a key resource. An atmosphere of good employee communication, engagement and responsibility both individually and as a team is of central importance. The personal development and optimum use of employee talent is strongly encouraged.

Every employee has an equal opportunity for personal recognition and career development, regardless of personal background or belief.

No form of discrimination or harassment will be tolerated.

An important part of this policy is recruiting, selecting, rewarding and promoting people who demonstrate entrepreneurial behaviour and show individual initiative in combination with a high degree of knowledge and experience of our products, markets and culture.

Relations with Community

East Midlands Instrument Company Ltd seeks to comply with all legislation affecting its operations. We will seek to serve and support the community in which we operate by providing services efficiently and profitably, and by providing good employment opportunities and conditions. We will take into account the concerns of the wider community including both national and local interests. Local suppliers will be used where possible, apprenticeship schemes offered locally as well as employment opportunities.

Issues relating to International Business

East Midlands Instrument Company Ltd will respect the traditions and cultures of each country in which it operates and commits itself to obey the laws of countries and communities where it conducts business.

Where business practices differ in countries in which the Company operates, it will favour consistent procedures among subsidiaries and associates.  It will work for multilateral action aimed at achieving a high common standard.

The Environment

East Midlands Instrument Company Ltd is concerned with the conservation of the environment in its broadest sense, and recognises that certain resources are finite and must be used responsibly.

We will therefore:

• work with others toward a consensus on environmental quality standards which are desirable and attainable, as demonstrated by EMI’s commitment to ISO14001 standard & approval.

• aim to improve all aspects of the business in respect of environmental issues, pollution prevention and reduce our carbon footprint proactively and through offsetting initiatives.

• pay particular attention to environmental issues including the conservation of energy and natural resources, the control of noise levels, recycling of waste material and the utilisation of non-polluting technology and carbon reduction initiatives.

• Purchasing shall be undertaken to provide for minimal waste.  Personnel who are assigned to procurement identification shall ensure that only materials necessary for the fulfilment of the order shall be purchased. Local suppliers shall be used where appropriate to reduce our carbon footprint within the supply chain.

• A supply chain assessed in accordance with the Approved Supplier Process shall be used to procure safe product which is SFARP without risk to the environment or supply chain resource.

Health and Safety

East Midlands Instrument Company Ltd provides healthy and safe working conditions for all its employees and will do all that is reasonable and practicable to:

• Protect the health, safety & welfare of its employees and minimise any adverse effects on their health or environment in accordance with OHAS 18001 approval.

• Implement working practices to prevent personal injury and damage to property

• Making all employees aware of risk assessments and raise awareness of their own responsibilities for the health and safety of themselves and others

• Utilise Occupational Health Assessment and Surveillance to enable the early detection of adverse health effects arising from work related activities

Human Rights

East Midlands Instrument Company Ltd is committed to the prevention of any violation of established Human Rights of any kind, particularly where child labour or undesirable forced acts are involved which include compliance with the Modern Slavery Act 2015.

Modern Slavery Act 2015 (M.S.A)

Whilst EMI do not fall within the scope of criteria of Section 54 of the M.S.A emi are committed to upholding the values of the act. EMI canvas their supply chain and seek to raise awareness in support of improper, illegal and unethical practices.

Social Responsibility

East Midlands Instrument Company Ltd is committed to and encourages collaboration with organisations that support Fair Trade and operate non-exploitative employment practices in their own businesses and supply chains throughout the world.

Conflict of Interest

This policy does not allow bribery or political contributions and requires employees to seek to avoid conflicts of interest and to disclose any that do exist. Employees must ensure that their actions are not affected by conflicts of interests.


East Midlands Instrument Company Ltd regards information for the purpose of its business as a corporate asset which must be protected against loss of availability, infringement and improper disclosure. We seek to ensure as far as reasonably practicable, that this information is protected. This applies also to intellectual property including inventions, trade secrets, technical information, product design, production expertise, customers’ information etc.


Honesty, completeness and accuracy of records are vital. Records of transactions should be maintained in an accurate, complete, transparent and timely manner in accordance with accounting principles. No unrecorded funds or assets should be established or maintained.

East Midlands Instrument Company Ltd believes that implementation of the ethics policy:

• promotes a culture of ethical behaviour throughout the organisation
• sets clear standards for employees
• makes good business sense
• protects the integrity and enhances our reputation
• supports the principles of good corporate governance.


emi is a division of East Midlands Instrument Co. Ltd