Code of Conduct

Incorporating Values and Standards

Depending on your start date these codes may be contractual.

Updated: April 2024

The HALO Trust is committed to ensuring that staff, volunteers and beneficiaries are protected from any harm (whether moral, emotional, verbal, sexual, physical, or financial); children and vulnerable people are foremost in this commitment. Our Code of Conduct (which incorporates the Charity's Values and Standards) provides anybody who directly, or indirectly works for HALO with explicit guidance on what is expected of them. All staff, partners and contractors must understand and adhere to it to ensure that the highest standards of professionalism are matched by behaviour which is always beyond reproach.

HALO has six values and three standards; using and meeting them is an individual duty and employment condition, but leaders at every level also have a responsibility for ensuring that staff, partners and contractors clearly understand and abide by our Values and Standards.

HALO's values are the principles and characteristics we expect our staff to uphold and display; foremost we should always seek to proactively identify and do the right thing. The application of our values and standards is essential to effective safeguarding and security and is fundamental to the protection of children and vulnerable people.

• Moral courage – to do that which stops, prevents, or denies any opportunity for wrongdoing, whatever the conditions, or pressures.
• Physical courage – putting yourself in harm's way to protect/ support others – is implicit and there are circumstances where it might be required. The moral courage of our staff is the essential component of HALO's ability to prevent, intercept and deal with any form (or allegation) of abuse.
• Discipline – the determined, rigorous and cost efficient use of time and resources to deliver HALO’s outputs, putting HALO's purpose(s) before self‐interest and personal ambitions; getting the job done thoroughly and to the highest of standards, whatever the temptations, or reasons not to.
• Integrity – to uphold the right moral and ethical standards. This includes honesty, reliability, consistency and judgement and speaking up for what we believe in as well as speaking out against poor practice, or behaviour which impacts the safety and security of HALO's staff and beneficiaries, particularly the vulnerable.
• Respect for others – to treat others as we would expect to be treated (whatever their race, gender, or sexual orientation); understanding and considering the needs and expectations of others and respecting their opinions and feelings, even if we don't agree with them.
• Loyalty – loyalty to each other, the whole team and to HALO's purpose and ethos. Loyalty is a component of teamwork and transforms groups of diverse and disparate individuals into a cohesive and effective whole; it is therefore central to our organisational success.
• Selfless commitment – putting the needs, safety and security of others (and of the organisation) before our own.

HALO's standards provide the framework within which our values must be applied. Our behaviour must be:

• Lawful. We must comply with the standards expected of us by our own SOPs, by donors, the Charity Commission, UN2/UK/US/EU law and the laws of host‐countries. Where a host‐country has laws which are different to UN/UK/US/EU, we must ensure that we uphold the laws which correspond to our values, while respecting (and without compromising our relationship with) the host‐country. We must operate within the spirit, as well as the letter of the law – where there is ambiguity we must have the integrity to comply as is intended, rather than choosing to manoeuvre around legislation.
• Appropriate. We must behave as we would wish others to behave towards us – in a decent, respectful, consistent and considerate way. Where circumstances require robust leadership it must be provided (and accepted), but 'appropriate' includes having the professional and personal fortitude to call out behaviour which is not.

• Professional. Professionalism defines HALO's reputation. It is underpinned by our values and standards and involves the highest levels of competence and safety and the relentless pursuit of excellence, whether conceptual technical, or procedural. The agile application of lessons‐learned is an essential component.

The 'Code' includes HALO's Values and Standards.

The Trustees, CEO and Directors have a responsibility for developing, overseeing and auditing compliance with HALO's Code of Conduct. The Code applies to anyone working with, or providing services for HALO (including partners, contractors, suppliers, external consultants and third‐party representatives).

Any member of staff who breaches the Code will face disciplinary action, which could result in dismissal for gross misconduct; compliance is a contractual obligation. Partners, contractors, suppliers, or external consultants who are proven to be wilfully in contravention will have their contract terminated with immediate effect.

From time to time it may be appropriate for the Code to be adjusted and it will be subject to annual Trustee Review (via the HALO Board's Governance and Nominating Committee).

All staff have a duty to ensure that we stick to our Values and Standards and abide by all the aspects of this Code. Anyone concerned about any form of malpractice, improper action or wrongdoing must report it immediately. HALO's Whistleblowing Policy refers and should be read in conjunction with the Code.

Below we summarise our:

• Ethics
• Confidentiality
• Intellectual property

And place particular focus on our policies relating to:

• Conflicts of interest
• Gifts and hospitality code for trustees and senior management
• Anti‐fraud and bribery
• Whistleblowing
• Safeguarding
• Equality and diversity
• Information security management
• General data protection
• Data retention and management

• Confidentiality and non‐disclosure

• We are committed to treating colleagues, patrons, donors, beneficiaries, stakeholders, suppliers, and the public respectfully and professionally, taking account of confidential issues where appropriate.
• We will endeavour to deal courteously with those who hold opinions that differ from ours, and respect cultural differences. We will also respect and be compliant with local laws.
• We operate with honesty and integrity in all our work, taking steps to identify and deal with corrupt or unethical practices and professional misconduct. We will be open and transparent in undertaking activities and decision making and never place ourselves under any financial or other obligation that might influence our performance.
• We will act with objectivity and reach conclusions based on best professional practice, considering the customs and any applicable local laws and traditions of other cultures.
• We will disclose any conflicts of interest and actively manage them.
• We value all our employees; we commit to invest in them to promote creative thinking and we encourage employees to find simple solutions to complex problems.
• We respect diversity and will never tolerate discrimination, harassment, or bullying.
• We will endeavour to assess and minimise the adverse impacts of any of our decisions on the environment.
• We may, in some circumstances, positively discriminate in favour of employing staff who are from local marginalised communities or groups.

• It is a condition of your employment that you have a duty of confidentiality in matters involving HALO.
• It is the duty of every employee to protect sensitive information. Sensitive information includes, but is not limited to: HALO's intellectual property; budgetary and financial information; salary information; documents and materials related to business development, particularly those associated with grants and contracts; confidential employee information; any information whose disclosure might jeopardise the security or viability of HALO's work both current and planned; any information whose disclosure might jeopardise the safety of HALO staff; and any information which would give a competitor a business advantage.
• This duty to protect sensitive information includes both a prohibition on the disclosure of such information as well as an obligation to take all reasonable steps to safeguard such information particularly against theft or accidental disclosure.
• The disclosure of confidential or sensitive information is likely to be construed as a breach of confidentiality. It is a condition of your employment that you must not disclose any HALO sensitive or confidential matter with any outside organisation including the media.
• Subject to our Whistleblowing policy, any such breach of confidentiality would be deemed as gross misconduct and could lead to your dismissal.
• You undertake at all times during and after the period of employment with HALO not to use or disclose, without HALO’s consent, any information belonging to or concerning HALO.
• This restriction does not apply to disclosure that has been authorised by HALO, is required by UK or national law, in the proper course of your employment, or which is necessary to deal with a matter that is already in the public domain.

• You may during the work that you do for HALO, make discoveries and inventions and may create tools, procedures, machinery, writings, photographs or recordings which contain intellectual property rights (IP). As they are made by you in the course of your employment, HALO has rights to these items of IP. HALO will always recognise, accredit, and respect your position as the creator of any such IP.
• You shall give us full written details of all such IP. You acknowledge that all intellectual property rights in all such IP shall automatically, on creation, vest in HALO absolutely. To the extent that they do not vest automatically, you hold them on trust for HALO. You agree promptly to execute all documents and do all acts as may, in the opinion of HALO, be necessary to give effect to this clause.
• You hereby, irrevocably, waive all moral rights under the Copyright, Designs and Patents Act 1988 (and all similar rights in other jurisdictions) which you have or will have in any existing or future works.
• You irrevocably appoint HALO to be your attorney to execute documents, use your name and do all things, which are necessary for HALO to obtain for itself or its nominee the full benefit of this clause. A certificate in writing, signed by any director or the secretary of HALO that any instrument or act falls within the authority conferred by this agreement shall be conclusive evidence that such is the case so far as any third party is concerned.

• We aim to ensure that no job applicant or worker receives unlawful, less favourable, treatment on the grounds of race, disability, religion or belief, age, gender, marital status, or sexual orientation.
• We make the utmost efforts to ensure employees are treated based on their relevant merits and abilities.
• We believe that the working environment should always be supportive of the dignity and respect of individuals.
• HALO has undertaken, under the UN Charter, to take all appropriate measures to prevent sexual exploitation or abuse of anyone by it or by any of its personnel or any other persons who may be engaged by HALO to perform any services. For these purposes, sexual activity with any person less than eighteen years of age, regardless of the age of majority or consent, shall constitute the sexual exploitation and abuse of such person. In addition, HALO has undertaken to refrain from, and shall take all appropriate measures to prohibit its personnel or other persons engaged by it from, exchanging any money, goods, services, offers of employment or other things of value, for sexual favours or activities, or from engaging in any sexual activities that are exploitative or degrading to any person.
• Harassment can be defined as conduct which is unwanted and offensive and affects the dignity of an individual or group of individuals. If a complaint of harassment is brought to the attention of management, it will be investigated promptly, and appropriate action will be taken. See the Disciplinary policies for more information.
• If you feel you are being harassed you are strongly encouraged to seek early advice/support from your Manager, Programme Manager or Head of Region. If you feel your Manager, Programme Manager or Head of Region is harassing you, then you should contact an appropriate member of senior management who will advise your next steps.

• HALO (@halotrust.org) email addresses should be used for work related correspondence only and all correspondence, including HALO internal correspondence, should be professional in tone. To ensure regulatory compliance and for the protection of our donors, we may monitor and read email messages sent to and from our system.
• If you have access to HALO's computers, including email, and access to the internet as part of your job, you must not abuse this by using these facilities for purposes unrelated to HALO business although reasonable personal use of internet facilities is permitted. Accessing pornographic or other unsuitable material is strictly prohibited.
• Only software packages properly authorised and installed by us may be used on our equipment. You must not load any unauthorised software onto our computers.
• Staff should not make statements, or make representations, on behalf of HALO on any social media sites or forums, without formal permission from HALO to do so. Whilst you are encouraged to share stories or photos posted on official HALO web page and social media sites, it is prohibited for you to make comments on any social media site, which may be disparaging or derogatory about HALO, its employees, patrons, donors, suppliers, beneficiaries, any HALO host nation or which could jeopardise HALO's relationship with host states.
• Use of HALO's email system or computer equipment to access or distribute inappropriate content or comment is a serious disciplinary offence and can result in dismissal.

• Smoking (including e‐cigarettes) is strictly prohibited in all of our buildings and vehicles.
• Please only smoke in designated areas and dispose of cigarette ends considerately.
• Consumption or being in possession of alcohol or any intoxicating drugs in the workplace is strictly prohibited both during work time and during any period prior to work where the effects carry over to the workplace. Any such instances will be dealt with under the disciplinary procedure and may lead to dismissal.
• We have a policy of no alcohol consumption when conducting mine clearance operations, weapons disposal or driving HALO work vehicles, be it on or off duty. Any breach or non‐observance of this policy can result in summary dismissal.
• Consumption or being in possession of unlawful drugs is strictly prohibited at all times.

• We reserve the right to require you to submit to an alcohol or drug test and obtain the results if management has grounds to believe or suspect that you are or may be under the influence of alcohol or drugs.

• You should not, directly or indirectly, engage in, or have any interest, financial or otherwise, in any business enterprise which interferes or is likely to interfere with your independent exercise of judgement.

• Should you be in doubt as to whether an activity involves a conflict, you must discuss the situation with the appropriate member of senior management.

• Your working relationships may bring you into contact with outside organisations where it is normal business practice or social convention to offer hospitality, and sometimes gifts. Offers of this kind to you or your family can place you in a difficult position. Therefore, no employee or any member of his or her immediate family should accept from a supplier of equipment, goods or services, or other person doing business with us, payments of money under any circumstances, or special considerations, such as hospitality, discounts or gifts of materials, equipment, services, facilities or anything else of value unless:

• they are, in each instance, of a very minor nature usually associated with acceptable business practice

• they do not improperly interfere with your independence of judgement or action in the performance of your employment

• they are available to all employees of HALO as a negotiated preferential rate or discount and communicated to all employees as such

• In every circumstance where a gift is offered, the advice of senior management must be sought and your manager must be informed of every gift received for inclusion in the Gift Register, if appropriate.

• As a general rule, gifts of a value of more than £100 should not be accepted and if rejection would create difficulties for HALO, then that gift should be surrendered to the most senior manager onsite for equitable distribution amongst all colleagues.

• Programme Managers, Heads of Region and all senior managers are bound by the Gifts and Hospitality Code for Trustees/Directors and Senior Management.

• To demonstrate that we comply with the standards of transparency required by The Charity Commission, and which are an integral part of our culture, specifically with regard to interaction with third parties who are current or potential suppliers of equipment, goods and services.
• This code sets a framework for our Trustees/Directors ("Trustees") and Senior Management. It encompasses gifts and hospitality from suppliers of equipment, goods of any description and services.
• Common sense plays an important part in deciding whether it is appropriate to accept gifts or hospitality and whether such gifts or hospitality are proportionate in the relevant circumstances. There should be no suspicion of a conflict of interest. Relationships should be open and transparent.
• Our policy note [see "Bribery and Other Corrupt Behaviour"] on The Bribery Act 2010 should be read and understood.
• This code applies to Trustees only to the extent of gifts or hospitality involving third parties who have any current or potential association with us through the business or connections of the respective third parties.
• For the purposes of this code, the term "Senior Management" encompasses all those employees involved in authorising the procurement of equipment, goods and services, specifically Programme Managers, Head of Regions and other UK-based employees.
• This code covers the acceptance by Trustees and Senior Management of gifts and hospitality from third parties, namely individuals who are not Trustees, our employees or members of the HALO Medical Group, but who are current or potential suppliers of equipment, goods and services.
• Hospitality includes the provision of lunches, dinners, holidays and tickets to sporting, social or leisure events. These examples are not exhaustive.

• The general principles for the acceptance of gifts or hospitality are as follows:

  • The value of the gift or hospitality must not be such that there could be any reason for it to be regarded as being outside normally acceptable practice or out of line with the standard of behaviour expected by HALO.

  • The gift or hospitality must be given for an appropriate reason.

  • The gift or hospitality must be given at an appropriate time (e.g. not in advance of an award or contract); and

  • The gift or hospitality must be of a one off or irregular nature, such that it could not be viewed as a regular source of income by HM Revenue & Customs.

• If in doubt whether to receive gifts or hospitality, refer to the Chief Executive or the Company Secretary.

• All gifts or hospitality from suppliers of equipment, goods and services received by employees working overseas, of a value in excess of £100 or local equivalent, should be reported by email to the Head of Region in charge of the respective programme, with the report copied to the Company Secretary for entry in the Register of Gifts and Hospitality.

• We have a strict anti bribery and corruption policy in line with the UK Bribery Act (2010). A bribe is defined as: giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.
• If you bribe (or attempt to bribe) another person, intending either to obtain or retain business for HALO, or to obtain or retain an advantage in the conduct of HALO’s business this will be considered gross misconduct. Similarly, accepting or allowing another person to accept a bribe will be considered gross misconduct. In these circumstances you will be subject to formal investigation under HALO's disciplinary procedures, and disciplinary action up to and including dismissal may be applied.
• All employees must ensure they have read and understood these anti bribery and corruption policies and procedures – please don’t hesitate to ask questions of a member of senior management if you have any concerns.

• The Bribery Act 2010 covers all instances of corruption, in the UK and abroad, by individuals as well as corporates, and between and within businesses as well as in the public sector. The Bribery Act's definition of bribery: "Anything that includes or is intended to induce improper performance".

Four offences

• Offering, promising, or giving a bribe.
• Requesting, agreeing to receive a bribe.
• Bribing a foreign public official

• A corporate offence of failing to prevent a bribe a firm’s employees, agents, intermediaries, and introducers are covered by the act.

Unlimited fines and sentences up to 10 years in prison for senior corporate staff if an offence is committed with their knowledge.

Sustainable business model

• Wins secured by bribery spell long term trouble, even years after the event.

• Honesty bring long term rewards in terms of a sustainable reputation and brand management.

• Bribery and corruption are profound risks to the organisation.
• Proportionality and materiality are common sense issues.
• Ask rather than hold back.

• HALO works in parts of the world where more due diligence is required. Particular care is required when setting up new programmes in new countries. "Custom" and "Practice" are not excuses.

Policy

• There is no room for deviation of any kind from the highest ethical standards set by personal example of the senior executives and expected to be followed at all levels within all areas of HALO's activities.
• Anyone who crosses the line is wholly out of step with our culture.
• Always say "no" when bribes are requested. Make a formal record of the request and report it up the chain of command.
• Any transgression is to be communicated immediately to a member of senior management, the Chief Executive or member of the Board (see Whistleblowing Policy).
• All Staff, trainees and associates are to be made aware of HALO's uncompromising standards and to be imbued with the values of the organisation. It is their duty to understand and comply with policies.

• Say "yes" to open and transparent relationship building but do not ever offer hospitality to anyone who helps to decide a particular piece of business.

Procedures

• Any questions regarding these procedures should be referred to the Chief Finance Officer, as should any matters that require reporting.
• In-country control must be with in-country management. Essential internal audit checks must take account of potential for corruption.

• The following situations are examples of what HALO employees could encounter:

  • Invitation to bribe someone deciding on the award of a funding contract, this is totally unacceptable, you, must make clear that this will not happen and report it at once.

  • Invitation to offer an inducement to facilitate operations, for example expediting customs clearance or circumventing bureaucracy is totally unacceptable, you must make clear that this will not happen and report it immediately.

  • The offer of payments or gifts for the award of a supplier contract for equipment, fuel, or other consumables, is totally unacceptable, you must make clear this will not happen and report it immediately. The control of choice of suppliers should be controlled locally in accordance with written purchasing procedure.

  • Fraudulent accounting or unjustified funding is totally unacceptable and must be reported immediately.

  • Small Payment, for example, to police for alleged traffic violations. Pay only if evidenced by a supporting document, It is the driver's responsibility to pay fines for a genuine traffic violation or failures in having the requisite vehicle documentation. All such payments should be reported immediately, with the documented payment, to local management.

  • Problems arising from the unethical behaviour of agents, partners, or subcontractors. This underlines the importance of knowing agents acting on behalf of HALO and making relevant agents and others aware of HALO's policy on the Bribery Act. Agents and others should be screened, and their good reputation be a key consideration in the selection. Anti bribery and corruption monitoring the activities of agents and others is the responsibility of local management.

NOTE: Although this policy is written in the context of the Bribery Act 2010 in the UK, and thus by definition applies to HALO UK, the policy and procedures apply equally to The HALO Trust (USA) Inc. (HALO USA), bearing in mind that executive management and administration are carried out from the UK. Reference to "HALO" in this context covers both HALO UK and HALO USA. 

• Any one of our employees who believes there has been a failure to comply with an applicable law, regulation, or clearly established HALO policy, should bring this to the attention of HALO so that HALO will have a reasonable opportunity to investigate and correct the matter as appropriate.
• If you reasonably believe that a policy, practice, or activity of ours is in violation of an applicable law or regulation, a written complaint must be delivered/sent by you, to the Chairman. If the Chairman is the object of the complaint, it must be delivered to any other Trustee.
• We will not seek to discipline an employee who, in good faith and in the public interest, makes a protest or raises a complaint against a practice of HALO, or an individual or entity with whom HALO has a business relationship, on the basis of a reasonable belief that the practice is in violation of an applicable law or regulation or is in contravention of clearly established HALO policy. Breaches of our Principles and/or our Code of Conduct will always be dealt with using our Disciplinary policy, may be considered as Misconduct or Gross Misconduct and could result in dismissal.