Purpose

Wholegrain is committed to the practice of responsible behaviour with our clients, suppliers, employees, contractors, workers, and any other agent working for us, or supplying services to us.  Through our business practices, we seek to protect and promote the human rights and basic freedoms of these groups.   

We are committed to protecting the rights of all of those whose work contributes to the success of Wholegrain, including those employees and agents of our suppliers.

We are committed to eliminating bribery and corruption in business. It is therefore essential that all our employees and persons associated with Wholegrain adhere to this policy and abstain from giving or receiving bribes of any form.   

We will always act with integrity and professionalism in our work and strive to exceed our clients’ expectations and deliver high-quality work on time and within budget.

This policy is non-exhaustive, and all aspects of Wholegrain’s business and subsequent activities should be considered in the spirit of this policy.

Any, and all, personal data used in conjunction with this policy shall be collected, held, and processed in accordance with our ‘Data Protection Policy.’ 

This policy does not form part of your contract of employment and may be amended from time to time.

Human Rights

Wholegrain is vehemently opposed to the use of slavery in all forms; cruel, inhuman, or degrading punishments; and any attempt to control or reduce freedom of thought, conscience, and religion. 

We will ensure that all of our officers, employees, contractors and workers are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.

We will treat our colleagues and team members with respect and fairness.

We will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.

Employees’ Rights

Wholegrain is committed to complying with all relevant employment legislation and regulations. We regard such regulations and legislation as the minimum rather than the recommended standard.

No employee should be discriminated against on the basis of their age, gender, disability, race, sexual orientation, religion or beliefs, gender reassignment, marital status, or pregnancy. All employees should be treated equally. Employees with the same experience and qualifications should receive equal pay for equal work.

No employee should be prevented from joining or forming a joint consultative committee or trade union. Nor should any employee suffer any detriment as a result of joining, or failing to join, any such organisation.

Environmental Issues

We are committed to keeping the environmental impact of our activities to a minimum and have established a ‘Sustainability Policy’ in order to help achieve this aim. 

As an absolute minimum, we will ensure that we meet all applicable environmental laws in whichever jurisdiction we may be operating within.

Conflicts of Interest

We will provide honest and accurate advice to our clients, even if it may not align with our own interests. 

We will avoid conflicts of interest and disclose any potential conflicts to our clients and team members.  Wholegrain holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers, employees, contractors, and workers. Conflicts of interest potentially undermine the relationship of the company with such partners.

In order to help preserve and strengthen these relationships, we have developed a ‘Gifts and Entertainment Policy’ which provides the rules and guidelines concerning the conduct of Wholegrain’s officers, employees, contractors, and workers aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. 

All officers, employees, contractors, and workers of Wholegrain  are expected to act honestly and within the law.

Information and Confidentiality

Information received by officers, employees, contractors, or workers of the company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given. We will respect the confidentiality of our clients’ information and ideas.

We will never plagiarise or use other people’s work without proper attribution.

We will always be open to feedback and willing to improve our skills and processes.

We will process any personal data collected in accordance with our ‘Data Protection Policy’.

Shareholders and Investors

Wholegrain’s officers, employees, contractors, and workers are committed to ensuring that no act or omission which is within their power and which would have the effect of deliberately, negligently, or recklessly misleading the shareholders, creditors or other investors in the company occurs.

Suppliers and Partners

We expect our contractors, suppliers, and partners to work towards and uphold similar ethical and moral standards to our own.

We will investigate the ethical record of potential new contractors, suppliers, and partners before entering into any agreement with them. Furthermore, we may request information from them regarding the production and sources of goods supplied to us by them.

Wholegrain Digital will withdraw from any agreement or other arrangement with any contractor, supplier or partner who is found to have acted in contravention of the spirit or principles of this policy.

Bribery and Corruption

We will always strive to uphold the reputation of our agency and the web design industry as a whole.

We are fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010.  Officers and employees, as well as any other persons associated with Wholegrain such as contractors, workers, agents, and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment. 

All employees are encouraged to report any suspicion of corruption or bribery within Wholegrain in accordance with the ‘Whistleblower Policy aka Confidential Reporting Policy’. 

Should any officer, employee, contractor or associated person be in any doubt when receiving or issuing gifts and hospitality, they must refer to the ‘Gifts and Entertainment Policy’. 

If an officer, employee, contractor or associated person is found guilty of giving or receiving a bribe, they will be personally criminally liable and will be subject to disciplinary action.  Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.