Phoenix Commercial Ventures Ltd is committed to being a responsible corporate citizen and to the pursuit of a sustainable future, both economic and social.

Phoenix Commercial Ventures Ltd adheres to three fundamental ethical principles:

- Integrity

- Competence

- Courtesy
 
To this end Phoenix Commercial Ventures Ltd (herein after referred to as "Phoenix") has developed a Code of Conduct, which sets out to ensure that these principles are followed in its operations. The Code of Conduct governs Phoenix's business decisions and actions. The Code applies equally to corporate actions, and to the behaviour of individual employees when conducting business on behalf of Phoenix.

The Code of Conduct is not all-encompassing. However, it sets out minimum requirements of behaviour. The Code of Conduct has been adopted by the Board of Phoenix Commercial Ventures Ltd, and is reviewed on a regular basis and revised if necessary.

1 General commitment

Phoenix wishes to be a responsible partner in society; acting with integrity towards its employees, business partners, society and those who are affected by its activities.

Phoenix observes the applicable rules of the law of the countries in which it operates.
 
Phoenix, wherever possible, strives to adapt to local situations in order to take the most appropriate approach to possible problems within the bounds of applicable law and responsible conduct. Phoenix supports the principle of dialogue and cooperation with all parties involved.

1.1 Human rights

Phoenix supports and respects human rights, and strives to ensure that its activities do not make it an accessory to infringements of human rights.

1.2 Child, bonded and forced labour

Phoenix makes no use of child, forced or bonded labour. Phoenix also undertakes never to invest in organisations that use child, forced or bonded labour.

1.3 Free market competition

Phoenix supports the principle of free market competition as a basis for conducting its business and observes applicable competition laws and regulations. 

2 Commitment towards employees

Phoenix values its employees as a key resource. An atmosphere of good employee communication, involvement and responsibility is of central importance.

2.1 Right to organise

Phoenix recognises and respects the freedom of employees to choose whether or not to establish, or to associate with, any organisation. Phoenix respects - within the framework of (local) law, regulations and prevailing labour relations and employment practices - the right of its employees to be represented by labour unions and other employee organisations. 

2.2 Equal and fair treatment

All employees have equal opportunities and will be treated equally in employment and occupation regardless of personal background, race, gender, nationality, age, sexual preference or religious belief. No form of harassment or discrimination will be tolerated.

2.3 Wages and payments

Remuneration and working hours shall comply with local labor laws.
 
3 Commitment towards suppliers and business partners

Phoenix pursues mutually beneficial relationships with its suppliers and business partners. 

4 Assets and information

Each employee is responsible for the proper use, protection and conservation of confidential information disclosed to Phoenix by its business partners. 

4.1 Confidentiality

Phoenix is committed not to make use of information disclosed to it by a third party if it is suspected that the discloser thereby violates an obligation of confidentiality. Unless the information is generally available to the public other than as a result of disclosure by Phoenix, or becomes available to Phoenix either on a non-confidential basis from a third party who is not bound by any confidentiality obligations or by operation of law.
 
4.2 Integrity of records

Records of transactions are maintained in an accurate, complete and timely manner. There are no unrecorded funds or assets.
 
5 Business integrity

5.1 Bribes
 
No members of Phoenix will accept or offer bribes.

5.2 Political payments

Phoenix will not make payments or donations, in money or in kind, to political organisations or individual politicians.

6 Money laundering

Phoenix will not participate in 'money laundering' by entering any arrangement which is known or there is reason to suspect that it will be used to facilitate any acquisition, retention, use or control of any property or money intended to disguise the proceeds of crime.

7 Professional competence

It is the duty of all members of Phoenix to ensure that their professional competences and skills are maintained at a level that is consistent with the responsibility of their job; with due regard to the requirements from their professional bodies regarding ongoing education.

8 Military contracts

On principle, Phoenix will not enter into military contracts.