📘 Code of Conduct & Ethics

QA Business Consultancy UK Ltd is committed to maintaining the highest standards of integrity, professionalism, and regulatory compliance. This Code reflects our values and responsibilities, and aligns with international best practices and UK regulatory expectations.

1. 🎯 Purpose & Scope

This Code applies to all employees, directors, contractors, and third parties acting on behalf of QA Business Consultancy UK Ltd. It supports our compliance framework and is designed to meet the principles of:

• ISO 37301: Compliance Management Systems

• ISO 37001: Anti-Bribery Management Systems

• FCA Principles for Businesses, including Principle 1 (Integrity), Principle 2 (Skill, care and diligence), and Principle 3 (Management and control)

2. 🧭 Ethical Principles

We are guided by the following core values:

• Integrity: We act honestly and transparently in all dealings.

• Accountability: We take responsibility for our actions and decisions.

• Fairness: We treat clients, colleagues, and stakeholders with respect and impartiality.

• Compliance: We follow all applicable laws, regulations, and internal policies.

3. ⚖️ Legal & Regulatory Compliance

We comply with:

• UK laws including the Bribery Act 2010, Data Protection Act 2018, and Companies Act 2006

• FCA rules and guidance, including Conduct of Business Sourcebook (COBS) and Senior Managers & Certification Regime (SM&CR)

• ISO-aligned internal controls and risk management procedures

4. 🔐 Confidentiality & Data Protection

We protect personal and business data in accordance with UK GDPR and ISO 27701 (Privacy Information Management).

• Data is accessed only by authorised personnel

• Breaches are reported and managed through formal incident response protocols

5. 💼 Anti-Bribery & Corruption

Aligned with ISO 37001, we:

• Prohibit all forms of bribery, facilitation payments, and improper inducements

• Conduct due diligence on third parties

• Maintain accurate records and financial transparency

• Provide training and enforce disciplinary measures for violations

6. 📣 Whistleblowing & Reporting

We maintain confidential channels for reporting misconduct, aligned with FCA whistleblowing rules and ISO 37301.

• Reports are investigated promptly and fairly

• Whistleblowers are protected from retaliation

• Outcomes are documented and used to improve controls

7. 📚 Training & Awareness

All staff receive:

• Mandatory compliance and ethics training

• Role-specific modules for high-risk functions

• Regular updates on regulatory changes and policy revisions

8. 🔍 Monitoring & Enforcement

We conduct:

• Internal audits and control testing

• Compliance reviews aligned with ISO 37301

• Corrective actions and continuous improvement plans

9. 🤝 Third-Party Conduct

We expect suppliers, contractors, and partners to:

• Comply with our Code and relevant laws

• Sign contractual clauses enforcing ethical standards

• Cooperate with audits and due diligence processes

10. 🧩 Accountability

Breaches of this Code may result in:

• Disciplinary action, including dismissal

• Termination of contracts

• Reporting to regulatory authorities