The Mpac Group policies have been established by the Board of Mpac Group plc and ensure that our values are embedded across the organisation. We are proud to be a responsible and fair employer with a focus on reducing our environmental impact across all our business functions.
Read our full policies below.
Anti-Bribery & Corruption Policy Statement
In accordance with the Group Ethics Policy the Board of Mpac Group plc is committed to the Group operating in an honest way and without the use of corrupt practices or acts of bribery to obtain an unfair advantage.
- has a clear anti-bribery and corruption policy;
- trains its employees so they can recognize and avoid the use of bribery;
- encourages its employees to be vigilant and to report any suspicion of bribery by providing appropriate means of communication and ensuring that sensitive information is treated accordingly;
- investigates instances of alleged bribery thoroughly and will assist the appropriate authorities with their investigations and any subsequent prosecution;
- and takes firm action against anyone found, after investigation, to be involved in bribery and corruption.
The Group prohibits:
the offering, giving, solicitation or acceptance of any bribe whether in the form of cash or other inducement, to or from any person, firm or company, wherever they are based and whether they are a public official or body or a private individual, firm or company, by any individual employee, agent or other person or body acting on the Group’s behalf, in order to:
- gain any commercial, contractual or regulatory advantage for the Group in a way that is unethical, or
- gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual. A full copy of the policy can be read
The Group recognizes that market practices vary across the territories in which the Group carries on business and what is normal and acceptable in one place may not be in another. The policy prohibits giving or receiving any inducement which results in personal gain or advantage to the recipient or any person or body associated with them and which is intended to influence the recipient to take action which may not be solely in the interests of the Group or the person or body employing them or whom they represent.
The policy is not intended to prohibit the following practices providing they are appropriate and proportionate to the particular market and they are properly recorded:
- normal and appropriate hospitality;
- the giving of small or ceremonial gifts to mark a festival or special event;
- the use of a recognized fast-track process which is available to all on the payment of a
- If there is any doubt as to whether a potential act is acceptable or not, the matter should be referred to the Site or Managing Director for the business, the Group Company Secretary or the Chief Executive for guidance before
The prevention, detection and reporting of bribery is the responsibility of all Group employees. Any concerns can be raised confidentially through the whistle-blower service maintained by NAVEX Global. Full details of the hotline are contained in the Group Ethics Policy which is issued to all employees. Further copies are available from local HR departments, the Group Company Secretary or can be found on the Mpac Group plc website at https://mpac-group.com/group-policies/
Employment Policy Statement
The Group is committed to developing its employment policies in line with best practice and providing equal opportunities for all, irrespective of gender, age, marital status, sexual orientation, ethnic origin, religious belief or disability. Full and fair consideration is given to applications for employment from people with disabilities having regard to their aptitudes and abilities. Every reasonable effort is made to support those who become disabled, either in the same job or, if this is not practicable, in suitable alternative work.
Environmental Policy Statement
The Group is committed not only to compliance with environmental legislation but also to the progressive introduction of appropriate measures to limit the adverse effects of its operations upon the environment. In particular, reasonable efforts are made to minimise waste arising from operations, to recycle materials wherever possible and to consider alternative methods of design or operation. The Group aims both to reduce its costs by these means and to promote good practice in use of resources at sustainable levels.
Group Health & Safety Policy Statement
1. The promotion of the health and safety of all employees, contractors and others affected by the Group’s operations and products is a vital, mutual objective for management, employees, and contractors at all levels, worldwide.
2. It is therefore Mpac Group policy, in all of its businesses, to do all that is reasonably practicable to prevent personal injury and damage.
3. In particular the Group aims to:
- provide and maintain safe and healthy working conditions taking account of any applicable legal requirements
- provide training and instruction to enable employees to perform their work safely and efficiently
- make available all necessary safety devices and protective equipment and to supervise their use
- maintain a constant and continuing interest in health and safety matters applicable to the company’s activities, in particular, by consulting and involving employees or their representatives wherever possible
- ensure employees and contractors are aware of their duties and responsibilities.
4. Employees and contractors worldwide have a duty to co-operate in the operation of this policy by:
- being alert to potential hazards to themselves or others
- complying with Health and Safety rules applicable to them
- reporting any incidents or circumstances that have led or may lead to injury or damage
- assisting in the investigation of accidents, training and spreading good practice, with the objective of introducing measures to improve safety
- availing of the training and the safety devices and equipment provided to them.
5. The Managing Director/General Manager, at each of the locations within the Group, worldwide, is fully responsible for:
- maintaining safe and healthy working conditions having regard to local laws and practices
- developing a health and safety culture in which employees are proactive in the development of health and safety practices
- making the necessary arrangements within the framework of this general policy stated above.
Group Ethics Policy
- Policy statement & guidance
- Standards in conducting business
- Compliance with law
- Avoiding conflicts of interest
- Commercial activities
- Internal controls
- Slavery and human trafficking
- Queries or concerns
1. Policy statement & guidance
The Board of Mpac Group plc (“Mpac”) is committed to the Group operating to the highest standards of ethical behaviour. It has established certain principles which it expects all locations within the Group to adhere to and certain values that should be embodied in the day to day activities of the Group. It expects all employees of the Group, led by the members of the Board and the Group’s senior management, to encourage and support all other employees in acting in accordance with the policy.
In support of this policy and its principles, the Board has adopted guidance to help assist with their application. This guidance is contained in the rest of the Ethics Policy document, under the following headings:
- Standards in conducting business
- Compliance with law
- Avoiding conflicts of interest
- Commercial activities
- Internal controls
- Queries or concerns
In support of the Group’s business objectives, including that of operating to the highest standards of ethical behaviour, we aim for excellence in what we do through the application of the following values:
– honesty & integrity
– empowerment & responsibility
– delivery of commitments
– open communication
3. Standards in conducting business
We are honest and show integrity
3.1 All employees are required to practice the highest standards of honesty and integrity in fulfilling their duties. Mpac, its customers, its suppliers and its other business partners and stakeholders, all place considerable trust in employees, therefore:
- employees must always represent themselves, and the Group’s business, openly to ensure that when communicating with other parties the nature of the employee’s purpose/role is understood;
- products and services should be designed and produced with safety and quality as imperative aims;
- marketing and selling should be robust but fair, with no misrepresentation of the features, terms and benefits of the products and services;
- communication should be clear and courteous, respecting the traditions of the individual or the local setting.
It is the Group’s policy neither to make political contributions nor to engage directly in party politics. This does not prevent the Group from lobbying by usual and lawful means to present its views and thus promote certain policies by public authorities which it believes will be beneficial for the business, its customers, employees and shareholders generally. Such lobbying must be on the basis of reasoned, logical argument and not seeking to impose undue pressure.
Employees, officers or representatives (including agents) of Mpac must not engage in corruption anywhere in the world. Corruption includes, but is not limited to, bribery and/or the giving or receiving of an improper advantage. Employees, officers or representatives should be aware that corrupt behaviour is a criminal offence in all countries in which Mpac does business and that penalties on conviction are severe. Engaging in corruption may also have the effect of making an individual liable to Mpac for damages or other legal remedies, and for an employee or officer would constitute gross misconduct and would, after investigation, probably lead to dismissal without notice. Representatives who engage in corruption will have their agreements with Mpac terminated with immediate effect.
The Group will not make a payment or gift nor grant any special favour or other consideration to a public official or government employee, or an employee or shareholder of a customer or potential customer, or to a third party facilitator (e.g. agent or customer representative, save for bona fide commissions as regulated by contract – see section 7.2), or to any other third party save for bona fide payments made under a properly formulated contract, unless it is a modest gift or entertainment which is:
- consistent with normal business practice in the locality;
- lawful under local laws;
- not likely to be seen as a bribe or pay-off;
- not intended to exert improper influence; and
- transparent and open for audit and inspection by the appropriate persons.
Where any doubt exists as to whether any payment or transaction of any kind would be of a proper nature or not, an employee or officer or representative should seek guidance before committing to or making such payment or transaction, from any one of their line manager, Site or Regional Director, Group Company Secretary, Group Finance Director or Chief Executive.
We treat people with respect at all times
3.2 The Group is committed to dealing with all people and organisations in a respectful way. This means treating others as we would wish and expect to be treated ourselves. We must ensure that the quality of what we deliver, both goods and services, is of a standard that the recipient should reasonably and properly expect. If we have disagreements these should be handled in a professional and courteous way, with a view to finding ways to resolve the issue in question.
Employees are empowered to perform their duties and take on responsibility
3.3 The Group is committed to ensuring that employees are given clear guidance as to what is expected of them and provided with the right support to perform their duties and are then empowered to perform those duties. In turn, each employee is expected to accept the responsibility they have been given and perform their duties effectively, seeking help, support and guidance when necessary.
We deliver what we commit to
3.4 It is important to maintain and develop our reputation for delivering what we commit to. Employees should not make statements, either to colleagues, customers, suppliers or any other person, knowing those statements are not true or make promises that cannot be fulfilled. Commitments once made must be assiduously followed up and fulfilled. If circumstances arise where a commitment cannot be met, the affected party must be informed promptly with an appropriate alternative course of action agreed and documented.
We communicate openly, and we respect confidences
3.5 It is one of the roles of management to communicate with employees in an open way, keeping them informed of matters that are of relevance and interest to them. It is important to be aware that certain information might be of a confidential, personal or commercial nature, and in such circumstances such information must be treated sensitively and confidences respected. Employees should be encouraged to communicate with their managers and encouraged to bring forward ideas for improving any aspect of the business, as well as to bring forward matters that are affecting them in their work.
Equally, the Group is committed to appropriate, open communication with all its stakeholders, including customers, suppliers, shareholders and business partners, having regard to confidential matters, reflecting the principles of this Ethics Policy.
4. Compliance with law
We comply with the law
4.1 It is Mpac’s policy to comply with the laws applicable to its business in each country in which its business is carried out. No employee has authority to deviate or to direct that any other may deviate from this policy. Any doubt as to what the law is or how it should be interpreted in any situation should be referred to the relevant line manager or the Group Company Secretary.
Health and safety is paramount
4.2 The Group and its businesses have more detailed health and safety policies but, in brief, the Group has a responsibility to take all reasonably practicable steps to ensure protection for all persons affected by its operations. Each employee has a responsibility to consider carefully how to protect the health and safety of themselves and any others who might be affected by their activities, and to take all reasonably practicable steps to do so. Where appropriate, formal risk assessments should be developed, documented and periodically reviewed, and appropriate risk control measures identified and implemented before the relevant activity is undertaken.
Use of drugs and alcohol at work is prohibited
4.3 Mpac is committed to the prevention of illegal activities and to the protection of its employees, its property and the public from any danger which might result from the use of drugs or alcohol. It is Group policy to provide a safe drug-free and alcohol-free work environment. Use or possession of illegal drugs or alcohol during working hours or on Mpac premises is strictly forbidden (except in the case of alcohol if approval has been given by the Site or Regional Director in special circumstances), and is cause for discipline up to and including dismissal. It is the Group’s policy to provide reasonable assistance to employees who seek the Group’s help in overcoming an addiction to or dependence upon drugs or alcohol, although volunteering to participate in such an assistance programme will not necessarily prevent disciplinary action being instigated for violations of the policy which have already occurred.
As a UK listed company, we recognise and abide by the requirements of our regulators
4.4 The Company’s shares are traded on the London Stock Exchange and as such the Company is subject to regulation by the UK’s Financial Conduct Authority (“FCA”). This regulation takes two forms: the Rules of the Alternative Investment Market (AIM) and the Market Abuse Regulations (MAR). The Company endeavours to ensure that every employee is aware of their responsibilities. Any doubt as to the requirements of the FCA or how they should be interpreted in any situation should be referred to the Group Company Secretary.
We communicate promptly and appropriately with the stock market
4.5 The Company will make formal announcements as required and within the timescales set by the Rules of AIM. Only those individuals who are authorised to do so may issue announcements or speak about the financial performance of the Group (see section 5). The Company must not disclose price sensitive information selectively and whenever necessary the Board will ensure the prompt and public distribution of material information regarding the Company.
Information which may affect Mpac’s share price must be kept confidential
4.6 Any employee may from time-to-time have unpublished confidential information about the Group, which if made public may materially affect the Mpac share price. In these circumstances employees must ensure they keep such information confidential and inform Group management appropriately – the directors and Group Company Secretary are responsible for ensuring such information is properly disclosed in accordance with 4.5 above. Such information includes (but is not limited to): sales or profit figures, anticipated numbers of large orders, margins, market share information, new product development and significant litigation by or against the Group. In many countries unauthorised disclosure of price sensitive information is a criminal offence.
We do not allow insider dealing and we do not indulge in ‘market abuse’
4.7 In the UK, trading in the shares of any company (or encouraging someone else to do so) whilst in possession of undisclosed price sensitive information about that company or its shares is a criminal offence punishable by a fine and/or imprisonment. There is similar legislation in most countries.
Under MAR it is also an offence (punishable by an unlimited fine) for anyone to participate in “Market Abuse”. The FCA definition of “Market Abuse” has been drawn very widely and it encompasses misuse of information, creating false or misleading impressions or distortion of the market and extends – for example – to putting misleading information about the company onto an internet bulletin board.
The Company will take a firm stand against any director or employee who takes part in “insider dealing” or “market abuse” whether in breach of the law relating to insider dealing or MAR. The Company reserves the right, after investigation, to treat any such breach as grounds for summary dismissal by reason of gross misconduct under its disciplinary procedure.
We deal in Mpac shares at appropriate times
4.8 Employees of the Company who have been issued with a copy of the Group’s Dealing Code (and “persons closely associated” – as defined by MAR, e.g. a spouse) may only deal in Mpac shares at the times and in the manner set out in the Dealing Code. The Dealing Code requires certain undertakings to be given and prior authorisation to be obtained, before shares in the Company can be bought or sold. Employees wishing to deal in the Company’s shares should contact the Group Company Secretary prior to dealing in the same.
We aim to help protect the environment
4.9 Mpac is committed not only to compliance with environmental legislation but also to the progressive introduction of appropriate measures to limit the adverse effects of its operations upon the environment. In particular, reasonable efforts should be made to minimise waste arising from its operations, to recycle materials wherever possible and to consider methods of design or operation that minimises waste. The Group aims both to reduce its costs by this means and to promote good practice in use of resources at sustainable levels.
We do not discriminate – we respect the individual
4.10 The Group values diversity among its employees. In their day-to-day behaviour employees are expected not to discriminate in their relationships with each other and with customers, suppliers and other business partners, and also to encourage others to behave in a proper manner. Employment and promotion opportunities will be offered on the basis of merit regardless of race, colour, religion, age, sex, sexual orientation, disability and/or national origin. The Group aims to ensure freedom from harassment and bullying for all employees. It is the responsibility of each employee to act in non-discriminatory ways at all times and if an employee sees an example of possible discrimination, harassment or bullying taking place to bring those concerns to the attention of the Group’s management (see Section 10 for guidance).
We co-operate with law enforcement officials
4.11 Mpac’s policy is to co-operate openly, honestly and courteously with all law enforcement officials acting within the scope of their duties, including officials responsible for health, safety and environmental matters. However, there are occasions when the circumstances or the Group’s policy and procedures may be innocently misrepresented by an employee with partial knowledge. Therefore, any investigation by government officials, including any request or requirement for an interview of any employee “under caution” (i.e. taking evidence relating to the business which may be used in any subsequent proceedings against the Group or any individual), must be referred immediately to the Group Company Secretary. If the Group Company Secretary is unavailable, the Group Finance Director should be contacted urgently. The request or requirement for such an interview should be courteously deferred until advice is obtained from the relevant person and the Group Company Secretary’s details should be passed to the relevant official.
We keep confidences
5.1 Employees must at all times maintain confidentiality concerning the affairs of the Group, its customers, its suppliers and other employees. In particular employees must not during or after their employment disclose any confidential information about the operations, transactions, designs, accounts, finances or other affairs of the Group or employing business without express prior written consent.
5.2 See section 4.6 above for comments on unpublished price-sensitive information.
We are careful in what we say to the media
5.3 No information will be given to the following except by, or as authorised by, the Chairman, the Chief Executive, the Group Finance Director or Group Company Secretary:
- the London Stock Exchange and associated regulatory news services;
- shareholders, other investors and investment advisers;
- newspapers or other media with national or other wide public circulation, including wide circulation in business and financial fields.
5.4 In the case of local media and specialist trade journals, no information should be released without the prior clearance of the Managing Director of the relevant business. The Managing Director must exercise their judgement as to whether or not the information is potentially price sensitive, confidential or contains references to Group financial or strategic issues. If it does, or if there is any doubt, release should not be authorised without prior clearance from the Chief Executive, Group Finance Director or Group Company Secretary.
6. Avoiding conflicts of interest
We act in the Group’s best interests
6.1 Situations in which the Group’s interests and an employee’s personal interests are, or may be seen to be, in conflict must be avoided. In dealings with all current or potential customers, suppliers, contractors and competitors, all employees should act in the best interests of the Group, conscious that what we say and do represents Mpac.
We do not accept gifts or entertainment …..
6.2 Any gift, entertainment, special favour or other consideration for an employee or another party which is in any way related to their position as an employee must not be sought nor accepted, save as set out in 6.3. It should be declined as diplomatically and courteously as possible (referring to this policy may be helpful).
….. unless it is within these boundaries
6.3 Modest gifts (other than money) or entertainments which do not have any improper or corrupt motives may be accepted provided they are:
- consistent with the law and normal business practice in the locality; and
- notified promptly to the employee’s immediate superior and recorded in the business’ gifts register; and
- not likely to be perceived as imposing any informal obligation or duty on the recipient, nor to cause embarrassment if publicly disclosed; and
- suitably modest.
6.4 Gifts such as professional stationery, e.g. diaries or calendars, are normally acceptable (unless contrary to local practice).
We avoid conflicts of interest
6.5 Employees must not act as director or consultant to any business not connected with Mpac, nor be employed by any other employer, without written consent from their relevant Site or Regional Director, who will keep a central register of such employments. However, the Group encourages employees to be involved in charitable, educational or other social pursuits which contribute to the local community, provided they do not interfere with the performance of the employee’s duties. Care must be taken not to associate the Group with any particular cause except in accordance with a formal sponsorship arrangement approved by the Group Company Secretary or Chief Executive.
6.6 Employees must notify immediately their relevant line manager of any arrangement or circumstance (such as ownership by a close family member of a substantial interest in any business which does business or seeks to do business with the Group) which might cause them not to act in the Group’s best interest or which might be perceived as such.
We do not use the Group’s resources for personal or political activities
6.7 Group resources, including time, materials, equipment and proprietary information must be used for Group business’ purposes only and not for personal benefit, without proper permission from Group management. Employees are free to take part in party political activity which does not use time, facilities or equipment of the Group (which might be understood to be a political contribution).
7. Commercial activities
We are honest and show integrity
7.1 Honesty and integrity contribute to the Group’s and the individual’s credibility and also to the efficiency of business transactions, as well as helping to ensure the Group complies with its legal and regulatory commitments. Employees should strive for good, long term relationships with customers, suppliers and other business partners and should represent themselves and the Group’s business openly, in a way that does not mislead others. For example, when discussing the Group’s products and services, employees should not hesitate to clarify such matters as to what is or is not included in a proposed selling price, what extras must be charged for and the effect of a reduced/increased price on quality and performance.
We pay legitimate sales commissions
7.2 All sales commissions paid to agents must represent appropriate remuneration for legitimate services and be in line with good business practice in the relevant locality. Any such arrangements must be clearly recorded and available for inspection under conditions of confidentiality by auditors and duly authorised law enforcement officers. Each business in the Group must have a policy relating to the appointment and retention of agents, with the objective of minimising the risk of corruption or of giving or receiving improper advantage, whilst meeting the Group’s legitimate aims of appropriate and proper commercial representation. The appointment and termination of agents, and material changes to agents’ contractual arrangements, are subject to approval as documented in the Group Delegation of Authority.
8. Internal controls
We keep proper records
8.1 The Group must maintain accurate records and conduct its affairs responsibly to ensure management control and to protect shareholder value. This includes the appropriate retention of correspondence and documents, including e-mails. Guidance in respect of the retention of certain documents is given in the Group Finance Manual.
We follow our procedures
8.2 The Company maintains a Corporate Governance Manual, Group Finance Manual and authorisation procedures which are distributed to the appropriate senior management in each operating location. It is the responsibility of senior management to ensure compliance with these documents and that each employee is aware as appropriate of any requirements by which he or she may be affected. The following general principles however should be known and understood by all employees:
8.3 The Group must keep complete, accurate and detailed books, records and accounts of all business transactions and a system of internal accounting controls to assure that:
- transactions receive proper authorisation;
- transactions are recorded as necessary to allow timely and accurate preparation of financial statements and to maintain accountability for assets;
- actual assets and book assets are audited (in line with Group policy) and adjustments made in accordance with proper accounting practices;
- transactions with customers and suppliers are documented, recorded and reported properly; and
- supporting documentation and authorisations are retained for inspection for at least six years (Group Finance Manual refers).
8.4 Employees are expected to answer requests for information from management and internal or independent auditors openly and honestly. Negative or harmful information should not be hidden from an employee’s line manager but should be promptly discussed so that corrective action can be taken.
8.5 The Group’s internal audit function will audit relevant aspects of the Ethics Policy as part of its activities.
9. Slavery and human trafficking
9.1 Mpac operates to high professional standards and we are committed to ensuring there is no modern slavery or human trafficking in any part of our business. This Ethics Policy sets out key values which Mpac considers important to the way in which its business is operated.
9.2 We carry out reasonable and practical checks to test whether our standards are being implemented throughout our suppliers’ businesses and that local legislation and regulations are complied with. Any instances of non-compliance will be dealt with on a case-by-case basis and any remedial actions tailored appropriately.
9.3 In the first instance, an employee should raise any concerns about the actual or suspected existence of slavery or human trafficking within the Group’s supply chain to their immediate superior or Site or Regional Director provided they feel able to do so. Employees may also follow the guidance set out in section 10, below, in respect of such concerns.
10. Queries or concerns
10.1 Any queries about the meaning of this policy in particular circumstances should be raised with your line manager or referred to the Group Company Secretary.
What to do if concerned
10.2 An employee that has any concerns about the conduct of the Company or an individual should refer to the Group Whistleblowing Policy.
Modern Slavery Act Policy
Please click here to view the Company’s Modern Slavery Act Policy
Speak Up (Whistleblowing) Policy
All companies face the risk of things going wrong from time to time. As a healthy and successful organisation, Mpac is committed to engendering a culture where our employees and partners feel safe in reporting any concerns without fear of reprisal; be that from a safety, regulatory/compliance, or ethics perspective. Reporting of concerns is vital so that we can protect our employees, grow our business, and learn from our mistakes; helping to make Mpac a better place to work and to ensure we are living by our high ethical business standards.
The policy applies to everyone who works with Mpac, including:
• all Mpac employees
• contractors and subcontractors
• agency staff
• partners and consultants
Employees and our partners are encouraged to report even a reasonable suspicion of misconduct. Firsthand or full knowledge of the facts is not required to make a report.
Depending on the seriousness and sensitivity of the issue and who is suspected of the wrongdoing – concerns can be raised to:
• Line Manager
• A member of the Executive Leadership Team
• The internal Speak Up e mail address: Speakup@mpac-group.com
In general, people should feel free to raise matters with any of the above and be assured that confidences will be maintained on a need-to-know basis. However, if there are concerns about approaching any of the above, a
confidential and independent helpline and website provided by NAVEX Global is available.
At Mpac, we will not tolerate malicious or intentionally false reports. Nor will we tolerate any victimisation of anyone raising a concern and will take appropriate action to protect our employees when they raise a concern in good faith.
Any victimisation will be treated as a serious offence and dealt with under the disciplinary rules and procedure.
Click here to raise your concern via internal email: email@example.com
Click here to raise your concern via NAVEX Global: www.mpacgroup.ethicspoint.com
Adam Holland, CEO