Sustainability, Compliance, and Business Conduct Policy, 2024
“Focused Agility’s (“FA”) commitment and strategy begins with respect and value -- respect for other businesses, fellow global citizens, and our natural environment, and the belief that EVERYONE brings value.”
Sustainability, compliance conduct policies are misunderstood – both by those who write them, and by those who look for them in a business’s governance documents.
They are not documents laying out how a business will save the planet, nor help enrich people lives, nor save people from their own decisions, nor support one or more political causes popular in the moment, nor follow Nation State’s laws or industry group standards.
Rather, a Sustainability, Compliance, and Business Conduct Policy statement outlines a business’ commitment and strategy towards all areas of sustainability, compliance, and conduct as they are faced, both over time and in-the-moment, and in such a manner that the foundation of a business’ ethics, morals, and integrity are plain on their face and can be measured.
Our commitment and strategy begins with respect and value -- respect for other businesses, fellow global citizens, and our natural environment, and the belief that EVERYONE brings value, period!
This “Policy” espouses our belief that our business can make a positive contribution to our global society and our collective citizenry, and to our natural environment by managing our activities with care and by working with responsible organizations to those ends.
FA, its employees, each of our operating brands, and our partners and suppliers are required to comply with this Policy.
We recognize that many different stakeholders have an interest in what we do, and we welcome discussion of our policies and performance.
Social Investment
FA, its employees, and brands are required to:
Undertake pro bono work for not-for-profit organizations involved in tackling social and environmental issues.
Leverage FA’s tech abilities, platforms, intellectual property, and skillset to advance worthwhile endeavors.
Make appropriate financial and other donations to social and environmental organizations at the discretion of managers and with the input of their working teams.
Managing Relationships & Politics
In all our relationships we will be open, honest, and transparent, will not pay or receive bribes or inducements of any kind, and will not be involved in ANY political activism outside the continental United States, and will only be involved in United States political activism as would apply to Congressional and SCOTUS term limits.
Information about our business shall be communicated clearly and accurately in a nondiscriminatory manner and in accordance with all regulations.
We will treat all information relating to the Group’s business, or to its clients, as confidential. In particular, “insider trading” with respect to our customers -- or theirs -- is expressly prohibited and confidential information must not be used for personal gain.
We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts this.
We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties.
We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business.
No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees.
Employee Workplace, Relations, and Development
FA and its brands:
We believe that a workplace should be safe and civilized and that employment must be freely chosen; we will not tolerate sexual harassment, discrimination, or offensive behavior of any kind, which includes the persistent demeaning of individuals through words or actions, the display or distribution of offensive material, or the use or possession of weapons on FA or client premises;
We will select and promote our people on the basis of qualifications and merit, without discrimination or concern for race, religion, national origin, color, sex, sexual orientation, gender identity or expression, age, nor disability. However, United States military Veteran status may be utilized for hiring, promotions, and specialized training at the sole discretion of FA management, consistent with applicable laws.
We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol;
We will support training and career development for all our people.
We will provide a safe and civilized workplace free from sexual harassment or offensive behavior.
Ethics, Fiduciary Duty, and Compliance
FA and its brands:
Will comply with applicable regulations and self-regulatory codes of practice in the countries in which they operate.
Will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, color, sex, sexual orientation, gender identity, age or disability, or military Veteran’s status.
Will not undertake work designed to mislead in any respect, including social, environmental and human rights issues.
Will not knowingly create work which contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, color, sex, sexual orientation, gender identity or expression, age or disability;
We will consider the potential for clients or work to damage FA and its brand’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights;
We will not for personal or family gain directly or indirectly engage in any activity which competes with companies within FA’s group of brands or with our obligations to any such company;
We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, clients and brokers or their representatives. We will collectively ensure that all staff understand this policy through training, communication and by example;
Environment
FA sets both qualitative guidance and quantitative targets for reducing our key environmental impacts. We aim to minimize the environmental impacts associated with the web products and marketing campaigns we create for clients. Our operating brands, partners, and suppliers are encouraged to help achieve these goals.
FA and its brands will respect the environment by minimizing their impact from:
Energy use;
Transportation and logistics;
Consumption of paper and other resources;
Water use; and,
Managing any significant sustainability risks in our supply chains.
Human Rights
FA and its brands will uphold the principles contained in the United Nations Universal Declaration of Human Rights and the International Labor Organization's fundamental conventions on core labor standards.
We support the right of our people and their families to basic human rights, the right to fair conditions of work, freedom of opinion and expression and freedom from forced labor and child labor.
Questions or Comments
You are encouraged to reach out to us with any comments or questions regarding this Statement by emailing to: Engage@FocusedAgility.com.