ASSL through its Code of Conduct requires employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees must practice honesty, integrity and loyalty in fulfilling their responsibilities and to comply with all applicable laws and regulations. ASSL encourages whistleblowing as a measure to protect the welfare and well-being of employees, the company and all stakeholders, providing that persons act in good faith, to report any suspected act of misconduct by employees, or risk/threat to ASSL and its stakeholders. This policy ensures the protection of individuals who report activities believed to be illegal, dishonest, unethical, or otherwise improper.
Potential breaches of ASSL's Code of Ethics and Conduct include:
- Employee relations and human resources issues, such as harassment, discrimination, or misconduct.;
- Ethics and compliance issues, such as financial reporting, insider trading, bribers or conflicts of interest;
- Loss prevention and asset protection issues, such as criminal activity (for example fraud, threats and violence, alcohol/drug abuse or internal theft), the security and protection of assets and facilities or actions involving harm to the environment; and
- Health and Safety, such as taking unnecessary risks, not following mandatory guidelines or false reporting.
Seeing Something and Saying Something
The most effective way to raise a concern is to do so openly. Openness makes it easier to assess the concern, investigate where appropriate and to obtain more information if required. However, we understand that in certain circumstances, those reporting issues of concern would like to do so anonymously and in those circumstances all concerns reported will be treated in confidence. The person’s name or details will not be revealed to any party without their consent.
Whilst ASSL encourages whistleblowers to identify themselves, anonymous calls will be taken equally seriously and investigated as fully as possible. However, the effectiveness of any investigation may be limited where an individual chooses not to be identified. It is the whistleblowers decision if they choose to remain anonymous and there is never any tracking or covert attempt to discover a whistleblowers identity.
ASSL encourages anyone reporting a violation to identify himself or herself when making a report to facilitate the investigation of the violation. However, reports may be submitted anonymously by filling out the online Whistleblower Reporting Form or calling the Telecare Hotline Trinidad:1-868-330-1133/1-868-681-7711. Barbados: (246) 836-4164.
Seeing Something and Saying Something - ASSL's Response
ASSL will promptly investigate, all concerns raised and:
- use reasonable endeavours to keep the identity of the individual raising a concern and the information received confidential, while recognising that ASSL may, in certain circumstances, be required to disclose information and identities of individuals, for example in legal proceedings or government investigations;
- when appropriate, provide feedback to the individual who raised the concern;
- track the progress of each case, implement recommendations and ensure that appropriate actions are taken, including disciplinary action when required; and
- where appropriate, report actual or suspected breaches of law to the relevant law enforcement agencies.
The first step in submitting a report is to choose the primary issue that you are reporting. Please select one of the following choices that best fits your issue:
| Major Classification | Sub-Classification | Description |
| Diversity, Equal Opportunity and Respect in the Workplace | Discrimination | Statements or actions based on age, race, color, national origin, sexual orientation, gender, disability or religion that are the basis for employment, promotion or compensation decisions. |
| Harassment - Sexual | Statements or actions expressing unwelcome sexual advances, requests for sexual favors, unsolicited physical contact or propositions, unwelcome flirtations, or offensive verbal or visual expressions or physical conduct of a sexual nature. | |
| Harassment - Workplace | Persistent statements, conduct or actions that are uninvited, degrading, offensive, humiliating or intimidating and create an unpleasant or hostile environment. | |
| Retaliation or Retribution | Statements or actions discharging, demoting, suspending, threatening, harassing or discriminating against an employee because of any lawful act taken by such employee in connection with reporting a violation of law or policy, filing a complaint, or assisting with an investigation or proceeding. | |
| Employee Relations | Conflict of Interest | Any personal interest, any business or professional activity or relationship, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity. |
| Inappropriate Behavior | Statements or actions that are not harassing in nature, but are believed to be unsuitable for the workplace. | |
| Unfair Employment Practices | Employment decisions, practices or disciplinary actions that are believed to be unfair regardless of whether they are the result of job performance, changes in business needs or other business related decisions. | |
| Environmental, Health and Safety | Environment, Health and Safety | Conduct, actions, policies or practices that either violate local environmental, health or safety laws or regulations or may cause or result in potentially hazardous conditions that impact the environment or the health or safety of employees, customers or others. |
| Substance Abuse | The lawful use, possession, sale, conveyance, distribution, concealment, transportation or manufacture or illegal drugs, intoxicants, controlled substances or drug paraphernalia in the workplace or while conducting business. | |
| Threats and Physical Violence | Statements or actions that threaten acts of violence or the presence of weapons, firearms, ammunition, explosives or incendiary devices in the workplace, on work premises or in work vehicles. | |
| Financial Concerns | Accounting and Auditing Practices | Statements or actions that violate or conflict with either internal policies, procedures, or practices or government regulations related to the detailed reporting of the financial state or transactions of an organization or the examination, verification, or correction of its financial accounts. |
| Conflict of Interest - Financial | Any financial interest, any business or professional activity, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity. | |
| Gifts, bribers and Kickbacks | Payments, payments in kind, gifts, bribers, extensions or credit or benefits extended to or received by customers, employees, suppliers, vendors, competitors, directors, officers, auditors, government employees, government officials or agencies, or other parties that are unlawful, improper, or designed to influence business decisions or political processes. | |
| Trading on Inside Information | The purchase or sale of stock or other securities based on non-public and material information obtained during the course of employment or providing such information to another person who purchases or sells stock or other securities based upon that information. | |
| Misuse or Misappropriation of Assets | Customer Relations | Statements or actions that are negatively impacting or interfering with customers, customer relationships or customer agreements. |
| Disclosure of Confidential Information | The unauthorized or illegal disclosure, copying, duplication, misuse or release or confidential or personal data including but not limited to employment, financial medical and health, customer lists, contracts, business plans, personnel records or other property marked or generally regarded as confidential or trade secrets. | |
| Misuse of Resources | The improper, unauthorized or unlicensed use of property or resources for non-business related reasons or purposes including improper use of systems and timekeeping. | |
| Theft | The unauthorized removal or taking or supplies, equipment, furniture, fixtures, products, cash, merchandise or other tangible property. | |
| Other | Guidance Request | Statements actions or policies that concern the caller but are not currently resulting in harm, injury or corporate liability and cannot be included in any other category. |
| Policy and Process Integrity | Antitrust or Fair Trading | Discussions or agreements with competitors about prices or credit terms, submission of bids or offers, allocation of markets or customers, restrictions on production, distribution or boycotts or suppliers or customers that would result in monopolization or anti-competitive markets. |
| Espionage or Sabotage | Actions that result in the gathering, receipt or acceptance or non-public confidential information or trade secrets about competitors to gain a competitive advantage or the deliberate destruction, disruption or damage to a competitor's equipment or property for competitive advantage or gain. | |
| Falsification or Destruction of Information | Statements or actions that encourage or result in unlawful, untimely, false or intentional misrepresentation, concealment or destruction of information in order to deceive or mislead. | |
| Quality Control | Complaints about product or service quality or effectiveness; allegations of product tampering; violation of policies and practices for manufacturing controls; allegations of non-compliance with product standards or service delivery. |
