Code of Ethical Conduct


It is the policy of Meridian to conduct its business at all times throughout the world with honesty and integrity. It is part of our mission statement that we have pledged that, “we will continue to be an ethical and responsible company.” Meridian recognizes it has a responsibility for all the actions of its employees in connection with the activities of the organization. In view of this, Meridian believes that the ethics demonstrated by our employees and indeed any persons providing services on our behalf should give all customers, shareholders, suppliers, colleagues, business partners and regulators confidence that the company operates in a way that avoids any suggestion of improper or personal motives or actions.

Therefore, all employees and any persons providing services on our behalf are expected to conduct themselves in accordance with this Code at all times. Meridian believes in the companies approach to ethical commercial business practices alongside our other polices concerning ethical conduct. In a wider delivery of our services by all employees and other 3rd parties on its behalf, we require our high standards to be maintained at all times. Meridian believes that all its stakeholders wish to be associated with an ethical organization which publicizes and upholds high standards in all that it does, in particular:

  • We will comply with the law in each country in which we conduct business including laws relating to unfair competition/anti-trust.
  • We will not offer to pay, solicit or accept bribes in any form whether directly or indirectly. This includes payment or receipt of “facilitation payments” which are small payments or gifts made as common practice in some countries to obtain approvals, permits, etc more speedily – they are still bribes. Meridian promotes measures to eliminate these types of payment. All personnel (including 3rd party providers delivering services for us or on our behalf) should ensure they comply with all local laws and regulations. If you are requested to make a payment which you believe may be a facilitation payment you should consult your team leader or Designated Operations Manager (as appropriate). All payments made by deployed personnel should be recorded and a receipt requested if possible.
  • We will only give or receive gifts and entertainment that are not material or customary. Local management in each country will establish guidelines reflecting local custom as to the maximum permitted value and the circumstances in which such gifts and entertainment are acceptable.
  • We will record in our published accounts all material assets and liabilities and not maintain secret accounts.
  • We will not make political donations anywhere in the world.
  • We will not engage in commercial espionage or covert surveillance of our competitors.
  • We will not seek or continue to work where there is a potential or actual conflict of interest unless this is fully disclosed to the effected party(s) and their written consent first obtained.

Agents and contracted third parties in countries where Meridian is not directly represented are expected to comply with this Code in all matters in which they are acting on Meridian’s behalf. Local management and all deployed personnel are expected to monitor compliance and to report any significant breach to the Operations Manager. In case of uncertainty in interpretation, employees and our contractors including deployed personnel should seek clarification from their line managers and operations managers respectively.

Meridian expects its employees to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on ship or in any environment while representing Meridian. Meridian expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the company. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to the Operations Manager.

Accurate and reliable records of many kinds are necessary to meet the Meridian’s legal and financial obligations and to manage the affairs of the company. Meridian’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and record-keeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements. In all matters relevant to customers, suppliers, government authorities, the public and others in the organization, all employees must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints.

Employees uncertain about the application or interpretation of this document or any legal requirements should refer the matter to their supervisor.

Whistleblower Protection Policy


Anyone who, in good faith, reports a suspected or actual violation of law, regulation, company policy or procedure, or ethical or professional standards, will be protected from retaliation as a result of such reporting regardless of whether or not, after investigation, a violation is found to have occurred.

No member of Meridian Global Consulting shall discharge, demote, suspend, threaten, harass or discriminate against the whistleblower for reporting what the whistleblower sincerely believes to be a serious actual or suspected violation or unethical act.

This whistleblower protection extends to individuals who provide information in relation to an investigation of a report by a whistleblower.

Any act of retaliation shall be treated by Meridian Global Consulting as a serious violation of policy, which will result in disciplinary action.

If a whistleblower believes he/she is being retaliated against after reporting a violation, he/she should contact the President of Meridian Global Consulting at (251) 345-6776.

Employee Grievance Procedure


Procedures

It is important that employees are treated fairly and receive prompt responses to problems and concerns. For this reason, Meridian Global Consulting provides a grievance procedure to promote prompt and responsible resolution of issues raised by staff. This procedure may be used freely without fear of retaliation, and the Manager of Human Resources is available to assist throughout the procedure. The process outlined below should be used if an individual disagrees with a supervisor’s action including any disciplinary action. If the problem involves Discriminatory Harassment, Sexual Harassment and/or Discrimination, reference to those policies should be made to initiate a complaint. When unsure which policy applies, contact should be made with a Human Resources HR Consultant.

Step One:

Discuss Complaint with Immediate Supervisor.

Meridian Global Consulting encourages informal resolution of complaints. Employees should first discuss the complaint with their immediate supervisor within three (3) business days of the situation whenever possible. If the complaint is not resolved as a result of this discussion, or such a discussion is not appropriate under the circumstances, proceed to Step Two. If the action in dispute involves suspension or termination of employment, Steps One and Two should be bypassed.

Note: If the immediate supervisor is an officer of the company, Step Two, should be bypassed and the complaint submitted directly to the President who will then schedule a meeting for employee.

Step Two:

Prepare and Submit Complaint Procedure Form to a HR Consultant for Review by the company Operations Manager.

If the employee feels the complaint was not resolved in discussions with his/her immediate supervisor, they may prepare and submit a formal written complaint for review by the person to whom the employee’s immediate supervisor reports (“second-level supervisor”). To do so, the employee should prepare a Complaint Procedure Form and submit it to a Human Resources HR Consultant within seven (7) business days of the Step One discussion with the immediate supervisor (or within seven (7) days of the event being grieved if Step One is bypassed). The Consultant will then review the complaint, send a copy to the second-level supervisor and the immediate supervisor (if appropriate), and schedule a meeting for the employee, the second-level supervisor, and the Consultant to discuss the complaint. The meeting will ordinarily be held within five (5) business days of the Consultant’s receipt of the Complaint Procedure Form. The second-level supervisor will issue a written decision, generally within five (5) business days of the meeting. If the complaint is not resolved to the employee’s satisfaction, they may proceed to Step Three.

Step Three:

Submit Complaint Procedure Form to HR Consultant for Review by the company President.

If the employee is not satisfied with the Step Two decision, they may proceed with the complaint within five (5) business days of receipt of the Step Two decision by submitting it to the HR Consultant for review by the company President. A meeting between the employee, the Operations Manager and the President will generally be held within five (5) business days. The company President will issue a written decision, generally within five (5) business days of the meeting.

General Information

The time limits above are subject to modification on a case-by-case basis due to operational requirements, travel away from home office, in-depth investigations, etc. The company President shall have final authority to resolve any disputes regarding the implementation of this Complaint Procedure, including determination of the appropriate decision makers.