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This code has been formulated to provide all SIPL employees with guidance on appropriate professional conduct. It serves as a reaffirmation of our enduring values and practices rather than introducing new beliefs or establishing new conduct rules.
SIPL and its employees are also subject to Standards of Business Conduct and other written policies and guidelines issued by SIPL.
The core principle of this code is that SIPL's reputation for quality products and services, business integrity, and the independence and integrity of our publications, services, and products are central to our enterprise's success. In simpler terms, our customers must trust that we provide them with truthful information, which is essential for our business. If we fail in this regard, SIPL's prosperity will be compromised. For example, our customers should be able to assume that:
Every company professes business integrity, but our work's impact on others' work, lives, and fortunes places distinct responsibilities on all SIPL employees.
These principles imply that each one of us is responsible for preserving and advancing a company that upholds this code. All SIPL employees hold positions of trust. When you accept a position within SIPL, regardless of its level or department, you are accepting the individual responsibility to uphold SIPL's policies governing legal and ethical business practices. This also includes adhering to legal requirements and ethical business practices and encouraging proper ethical behavior among colleagues and subordinates.
Additionally, it should be clear to each of us that business integrity is not limited to specific roles, such as news reporters / editors or the legal department. Business integrity demands that we make all business decisions objectively and realistically.
Managers, by virtue of their positions of authority, must serve as ethical role models for all employees. Part of a manager's leadership responsibility is to demonstrate the highest standards of integrity when dealing with employees, customers, and the wider world. Managers must refrain from even implicit or unspoken endorsement of actions that could harm SIPL's reputation and always exhibit sound business judgment in their duties.
Another significant aspect of leadership is fostering employees' commitment to our principles and their ability to make ethical judgments. Managers should communicate the seriousness of SIPL's expectations regarding ethical conduct and express personal support for these guidelines. Ethical leadership also involves creating a work environment where employees feel comfortable voicing concerns or seeking assistance or advice when faced with potentially compromising situations and supporting those who raise such concerns.
This document does not aim to provide an exhaustive list of all applicable laws, regulations, and norms that apply to SIPL. In our ever-evolving business environment, we are frequently challenged by complex situations that demand quick responses under pressure. No written policy can cover every business scenario definitively. As a result, this code emphasizes and clarifies a standard of ethical conduct that should guide all our business dealings and relationships. Moreover, more detailed guidelines for managers are available for some topics covered in this code, with others being issued from time to time. Some departments also issue their specialized guidelines. For further information on additional guidelines, please consult your supervisor.
Any information and material obtained by SIPL employees in the course of their employment is the exclusive property of SIPL. This includes not only our work and that of our colleagues but also information related to future activities, such as yet-unpublished news, information, advertising, and publication schedules. Under no circumstances should such information be shared with anyone outside SIPL, including friends and family, until it has been made public.
These rules also extend to confidential information about SIPL. SIPL employees are prohibited from disclosing any confidential information belonging to the company or using it for personal benefit. Anyone who possesses or has access to confidential information has a crucial responsibility to maintain its confidentiality and prevent it from being disclosed, whether intentionally or unintentionally, to others both inside and outside SIPL. Confidential business information should only be shared within SIPL with other employees who require the information to fulfill their job responsibilities.
SIPL is entitled to our complete business loyalty, professional attention, and undivided focus on our business and customers. Employees should not utilize SIPL's assets, talents, information, technology, name, or influence for their personal gain. All intellectual contributions made by employees while working at SIPL belong to the company.
SIPL recognizes that the company's success is closely linked to the success of our customers. Thus, it is our duty to deliver our products and services as promptly as possible while maintaining the highest levels of quality. Business interactions should be transparent and honest, with transactions serving the best interests of both SIPL and the customer.
To ensure this, SIPL employees should not directly or indirectly offer or provide to customers, prospective customers, or any party that provides or seeks to provide news, information, material, equipment, supplies, or services to SIPL any gift, entertainment, or reimbursement of expenses exceeding nominal value or customary courtesies for the time and place. For example, a reasonably priced meal is considered an acceptable entertainment expense. Employees should also avoid offering or providing, directly or indirectly, any material, equipment, or services to individuals who could influence business or governmental decisions affecting SIPL.
Conversely, SIPL employees should not request or accept, directly or indirectly, any payment, loan, service, equipment, or any other benefit or thing of value exceeding nominal value or customary courtesies for the time and place from suppliers, customers, or any party providing or seeking to provide news, information, material, equipment, supplies, or services to SIPL or any entity with an existing or potential business relationship with SIPL.
Employees should avoid conflicts of interest in procurement. They should not initiate, approve, or engage in purchasing goods or services on behalf of SIPL from any supplier in which the employee, a member of their extended family, or household has a significant financial interest, unless there is a compelling business reason for doing so and it has been pre-approved by SIPL's CEO.
Unauthorized duplication of computer software is strictly prohibited, whether obtained from external suppliers or developed internally, regardless of whether the duplication is for business or personal use. Moreover, all SIPL employees must adhere to the company's standards and policies concerning the use of technology and computer equipment.
Every SIPL employee must adhere to all relevant laws and regulations. The applicable laws are generally those of the location where the employee is based and also the laws of any locations where the employee conducts business. Employees should also respect the local culture and values of these places.
SIPL will not reimburse employees for any illegal or improper payments, including those made to or for the benefit of any public official to influence laws, regulations, or other official acts in SIPL's favor. Additionally, any SIPL employee planning to make a gift to a public official in the course of their employment should obtain prior clearance from SIPL's CEO.
SIPL does not directly or indirectly contribute to political campaigns, political parties, or groups raising money for political campaigns or parties. SIPL does not and will not reimburse any employee for any political contribution made by an employee.
All News Reporters / Editors and senior management members with responsibilities related to news should abstain from partisan political activities. These activities include distributing political materials, making partisan comments on social networking sites, blogging, soliciting campaign contributions, hosting fundraisers for partisan candidates, and making financial contributions to a candidate's campaign. While these restrictions don't apply to an employee's spouse, significant other, or family members, news personnel and senior management with responsibilities related to news should avoid creating any appearance of bias.
However, it is not the intention of SIPL or this code to discourage employees from actively participating in or making financial contributions to non-partisan causes, charitable organizations, civic groups, religious organizations, or other similar organizations. These activities are encouraged as long as they do not interfere with job performance, create the appearance that SIPL is subsidizing these activities, violate this code, or conflict with SIPL's interests. If a conflict arises or may arise between an external organization affiliated with an employee and SIPL's interests, the employee should refrain from participating in the conflicting activity. Employees should not overlap their involvement with these organizations and their coverage responsibilities.
SIPL employees should not allow their SIPL affiliation to be associated with outside organizations' materials or activities without the approval of SIPL's CEO or general counsel, except when the employee is a SIPL representative or when the affiliation is part of a broader description of the employee's identity.
Maintaining the integrity of SIPL's books and records is essential for our business's success. This responsibility is not exclusive to accounting or financial personnel; it's a shared responsibility for all of us.
Therefore:
SIPL is committed to treating all employees with dignity and respect. Our goals include providing benefits and services that enhance employee well-being, effective communication with employees, equal employment opportunities, maintaining a safe work environment, observing collective bargaining agreements where applicable, helping employees realize their potential and maximize productivity, and fairly evaluating and recognizing performance.
SIPL values the contributions of its employees and promotes diversity, recognizing that a mix of individuals enriches the company and stimulates creativity and business growth. We provide equal employment opportunities and advancement based on job-related qualifications and the ability to perform the job, without discrimination based on any legally protected status, such as gender or race. We also maintain a working environment that is free from intimidation and harassment.
Detailed policies related to personnel matters and employment with SIPL are available through the human resources department. These policies are designed to comply with legal and regulatory requirements in the various jurisdictions in which SIPL operates, and employees are required to adhere to these policies.
SIPL is committed to maintaining a safe work environment by eliminating recognized significant hazards in the workplace. We conduct business in an environmentally sound manner based on scientific understanding, customer needs, and local requirements. Employees are expected to comply with all relevant health, safety, and environmental laws and regulations, along with related corporate policies.
SIPL takes this code of conduct very seriously, and all employees are responsible for complying with all aspects of the code. New employees are required to read this code at the beginning of their employment and attest in writing that they have done so. Additionally, all SIPL employees are required to provide a written attestation each year, confirming that they have read and followed this code during the previous calendar year.
The matters addressed in this code are of utmost importance, and any lapse in judgment within the areas it covers may be considered serious enough to warrant disciplinary action, up to and including dismissal.
Any employee with questions about this code or concerns about perceived deviations should promptly contact their supervisor or the SIPL legal department. Retaliation against an employee who makes a good faith report of a possible code violation will not be tolerated. The most important guidance regarding these matters is to check with your respective head of departments.
