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.
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.