Think FM Ethical Code of Practice 2025

Date Issued: Wednesday, 03 January 2024

Contents

1. Ethical Conduct Policy
2. Modern Slavery Statement
3. Child Labour
4. Anti-Bribery Policy
5. Anti-Tax Evasion Policy
6. Whistle-Blowing Procedure

1. Ethical Conduct Policy

At Think FM Solutions, we are committed to doing the right thing in all aspects of our business. This requires an unwavering dedication to the highest ethical standards. Every employee shares responsibility for our conduct and success. Our culture is built on four key values:

Integrity

We demand high standards of integrity, safeguard assets, and promote transparency.

Excellence

We continuously improve our products, services, and processes to serve customers better.

Teamwork

We encourage collaboration and foster an inclusive environment that values safety and health.

Accountability

We honour commitments and take responsibility for all actions and results.

2. Modern Slavery Statement

A. Organisation

This statement applies to Think FM Solutions for the financial year 2024-2025.

B. Organisational Structure

Think FM Solutions is a Facilities Management company offering daily office cleaning, specialist cleaning, and mechanical services.

C. Commitment

The organisation is committed to complying with the Modern Slavery Act 2015.

D. Supply Chains

Our main supply chains involve providing FM services to clients in the UK.

E. Potential Exposure

We consider our main risk exposure to be in our supply chain and take steps to mitigate such risks.

F. Steps Taken

• Reviewing supplier contracts for anti-slavery clauses
• Conducting due diligence on suppliers
• Maintaining a zero-tolerance policy toward modern slavery

3. Child Labour

We adhere to all legislation regarding young workers, ensuring proper checks and permits are in place. Restrictions are applied based on age categories:

• 14 years old: Maximum 25 hours per week during school holidays
• 15-16 years old: Maximum 35 hours per week during school holidays
• Over school-leaving age: Maximum 40 hours per week with mandatory rest periods

4. Anti-Bribery Policy

A. Introduction

The organisation prohibits any form of bribery, which is a criminal offence.

B. Offences

It is a criminal offence to:

• Offer or accept a bribe
• Bribe a foreign official

C. Scope

This policy applies to all employees and third parties acting on our behalf.

D. Policy

Employees must not offer, give, or accept any bribe. Any suspected bribery should be reported to the Managing Director.

5. Anti-Tax Evasion Policy

A. Introduction

Tax evasion is illegal, and the organisation takes a zero-tolerance approach to its facilitation.

B. Policy

Employees are prohibited from engaging in or facilitating tax evasion. Any concerns should be reported immediately.

6. Whistle-Blowing Procedure

A. Introduction

Employees are protected by law when making qualifying disclosures in the public interest.

B. Procedure

Employees should report concerns to the Managing Director. If not satisfied, they may contact a regulatory body.

C. Treatment by Others

Any bullying or harassment of whistle-blowers is unacceptable and will result in disciplinary action.