COMPANY POLICIES

Policy summary

Silver Bluemoon LLC has a ‘zero tolerance’ policy towards fraud, bribery and corruption. It will always seek to take disciplinary and /or legal action against those found to have perpetrated fraud (para 7).

Silver Bluemoon LLC is committed to developing an anti-fraud culture and keeping the opportunities for fraud, bribery and corruption to the absolute minimum (para 8).

Silver Bluemoon LLC will assess the risks of fraud, bribery and corruption, establish processes and controls to minimize these risks, and regularly review the effectiveness of its control systems (paras 11 and 15).

Silver Bluemoon LLC requires all staff to immediately report any incidents or suspicions of fraud, bribery or corruption to an appropriate manager or another person named in Raising Concerns. Silver Bluemoon LLC will not penalize anyone for raising a concern in good faith (paras 16, 17 and 19).

Silver Bluemoon LLC will take all reports of fraud, bribery and corruption seriously, and investigate proportionately and appropriately as set out in the Fraud Response Plan (para 21).

Policy brief & purpose

Our child labor policy is our position on employing minors and aims to ensure that our company, its subsidiaries and everyone we’re connected with follows the law and cares for children’s interests.

International, local and federal child labor laws are stricter today than they were years ago. But millions of children are still forced to work in bad conditions all around the world, even in developed countries.

As an organization, we want to do business in a legal, ethical manner adding value to society and the environment instead of doing harm. Helping stop child labor is fundamental to us. We want to make sure that our organization doesn’t take part in children’s exploitation and also helps end it to the best of our ability.

Scope

This policy applies to our entire organization and those we do business or partner with including suppliers, vendors and contractors.

The International Labour Organization (ILO) and the U.N Convention on the Rights of the Child guide our policy on child labor. When it comes to legal aspects, we always:

Follow the stricter law if more than one laws apply (e.g. state and federal, local and international).
Require suppliers, partners and vendors to follow the stricter applicable laws and recognize children’s rights. They must also require their own suppliers, subcontractors and stakeholders to do the same.

In this policy, we refer to “children” as people who are younger than [] years of age. “Young children” are people younger than [].

“Child labor” refers to work that deprives children of their childhood and affects their schooling, their potential and their dignity. It’s work that’s harmful to them mentally, physically and socially.

Policy elements

Young children

When it comes to young children (younger than []), we don’t want to stand in the way of their health, schooling or free time. That’s why we don’t and won’t employ anyone younger than [] of age and require our subsidiaries to do the same, regardless of the country they’re in.

We’re also committed not to do business with any organization that employs children younger than []. We’ll include this condition in every contract we sign and reserve the right to break the contract without penalty if our stakeholder violates this condition and refuses to agree on or follow through with an elimination plan.

Legal exceptions

[ ]

Parental employment. We might occasionally do business with family-owned businesses. Those businesses are usually allowed to employ the owner’s young children as long as the work isn’t too hazardous (e.g. mining, manufacturing). We accept this regulation, but we’ll still dissolve our contract if it comes to our attention that these children are exposed in danger or are working consistently during school hours.

Occasional work. Sometimes, parents bring their children to work to teach them skills and introduce them to a work environment. They may also hand them some tasks to complete (e.g. a painter may ask his child to help with a painting job he’s taken). This is an acceptable practice, as long as it doesn’t deprive children of school on a consistent basis or puts them in any danger. (For example, the painter shouldn’t allow his son to inhale toxic paint or ask him to climb on scaffolding.)

Older children

When it comes to employing children who are older than [], we’ll always follow the local and international laws. As a general rule, these children can have a job, but they should never do work that jeopardizes their health and safety or affects their schooling and development.

With this rule in mind, we may employ children older than [] for light work such as [] They will not use any heavy or dangerous equipment, chemicals or vehicles when working.

We’ll determine their work hours and wage based on applicable laws. We won’t employ children for more than the maximum weekly or daily hours allowed. []

These are mandatory conditions when forming partnerships or other business relationships. We’ll refuse to do business with anyone who employs children of any age in hazardous or exhausting jobs or doesn’t follow applicable laws on working hours or pay. We also expect them to communicate and enforce the no child labor policy to their own contractors.

Actions and Implementation

To make sure we enforce this policy and help eliminate child labor, we’re committed to:

Working with governments and other organizations to end child labor. We may sponsor or organize actions to educate communities, build schools or find ways to ensure children won’t be forced to work to support their families.
Educating our staff on youth work laws and show them how to report child labor if they see or suspect it.
Requiring hiring managers and HR to avoid hiring minors under the legal age for working. We also expect them to know and follow this policy and laws on wages and hours for older children.
Keeping and validating documentation verifying our employees’ age after they’re hired. If we discover that we’ve hired a minor under the age of 18, we’ll review applicable laws and adjust working hours accordingly. If we need to let the child go, we’ll assess their situation and make sure to provide for them to the best of our ability (e.g. pay him or her their would-be salary for a couple of months) when necessary.
Communicating our no child labor policy to organizations we’re connected with and ensure our contracts have the right stipulations.
Auditing suppliers and partners (especially those in industries with high child labor risk) periodically to ensure they aren’t involved in child labor, possibly with unannounced onsite visits too. We’ll require them to provide us with an updated list of all their business locations at all times. If we discover hidden business sites that employ children, we’ll dissolve our contract immediately.
Demanding and monitoring an elimination plan in cases where suppliers discover child labor in their business. We’ll also work together with the stakeholder to create plans to support children, keeping their best interests in mind, and make efforts to involve them and their families in the process.
Employing or consulting with experts on topics like child labor, health and safety standards or corporate social responsibility.

Children’s welfare is everyone’s business

We want to grow and thrive as a business, but we’re also committed to do good by the community we belong in. We ask all of our employees and partners to follow this policy, not just because we demand it as an organization, but because securing a bright future for children is everyone’s duty.

Silver Bluemoon LLC is committed to the conservation and improvement of the environment and recognises its responsibility to manage and minimise the environmental impacts of our activities, products and services. And operates its environmental procedures in accordance with BS EN 14001:2015

In order to achieve this Silver Bluemoon LLC has set the following key objectives:

to identify the significant environmental impacts of our activities;
to develop suitable objectives, targets and management programmes, applying appropriate operational procedures to minimise our significant environmental impacts during normal, abnormal and emergency conditions

comply with relevant legislation, regulation and other requirements relating to our significant environmental impacts

to prevent pollution, minimise our inputs of utilities and resources and the outputs of emissions to the atmosphere, effluents to waters/sewers and wastes to disposal facilities; endeavouring to re-use, recover or recycle materials where practicable, or safe disposal where not;

take into account the principles of sustainable development in conducting its administrative, commercial and social activities, using the procurement of materials from sustainable sources;

to ensure that environmental responsibilities are defined, communicated and understood at all levels within our organisation through the provision of appropriate training;

to ensure that suppliers and contractors understand the organisation’s Policy and assist them in developing appropriate systems and a responsible approach with regard to environmental issues;

to communicate, co-operate and respond to the views of interested parties, including stakeholders, customers and the general public, on environmental issues, where this is practicable and likely to result in an overall improved environmental performance.
to strive for continuous improvement in overall environmental performance.

Policy brief & purpose

Our professional code of ethics policy aims to give our employees guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgment, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act (e.g. in cases of conflict of interest). We will also use this policy to outline the consequences of violating our business code of ethics.

Scope

This policy applies to everyone we employ or have business relations with. This includes individual people such as employees, interns, volunteers, but also business entities, such as vendors, enterprise customers or venture capital companies.

Note that our code of ethics is slightly different than our code of conduct. Code of conduct may include elements such as dress code and social media use, whilst our code of professional ethics refers to legally or morally charged issues. Still, these two codes do overlap.

Policy elements

What is meant by code of professional ethics?

First, let’s define professional ethics: they are a set of principles that guide the behavior of people in a business context. They are essential to maintaining the legality of business and a healthy workplace.

So what is a of ethics? Our code of ethics definition refers to the standards that apply to a specific setting – in this case, our own organization.

What is the purpose of a professional code of ethics?

Having our business ethics in writing doesn’t mean that we don’t trust our employees. We strive to hire ethical people who have their own personal standards, so we expect that a written code won’t be necessary most of the time.

But, it can still be helpful. You may find yourself in a situation where you’re not sure how you should act. Life is full of grey areas where right and wrong aren’t so apparent. Some professional ethics also correspond to laws that you absolutely must know to do your job properly, so we will mention them in our code of ethics.

Additionally, every organization makes bad hires every once in a while. We also can’t predict how people are going to behave. When an employee behaves, or intents to behave, in a way that’s against our professional ethics, or applicable laws, we will have clear guidelines on what disciplinary actions we will consider.

For these reasons, we advise you to read this document carefully and consult with your manager or HR, if you have doubts or questions.

The components of our code of professional ethics:

We base our business code of ethics on common principles of ethics []:

Respect for others. Treat people as you want to be treated.
Integrity and honesty. Tell the truth and avoid any wrongdoing to the best of your ability.
Justice. Make sure you’re objective and fair and don’t disadvantage others.
Lawfulness. Know and follow the law – always.
Competence and accountability. Work hard and be responsible for your work.
Teamwork. Collaborate and ask for help.

Here’s a more detailed overview of our code:

Respect for others

It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence is strictly prohibited and will result in immediate termination. You’re also not allowed to harass or victimize others.

What constitutes harassment or victimization? To answer this, we have a policy on harassment and a more specific policy on sexual harassment you can take a look at. As a general rule, try to put yourself in someone else’s place. How would you feel if someone behaved a specific way to you? If the answer is “I wouldn’t like it much” or “I would never let them behave like that to me”, then we don’t tolerate this behavior no matter the person it comes from.

If someone, be it customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to HR or your manager. You can also report rudeness and dismissiveness if they become excessive or frequent.

Integrity and honesty

First, always keep in mind our organization’s mission. We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organizational.

Be honest and transparent when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags and, if you’re discovered, you may face progressive discipline or immediate termination depending on the damage you did.

Stealing from the company or other people is illegal. If you’re caught, you will face repercussions depending on the severity of your actions. For example, if you steal office supplies, you may receive a reprimand or demotion (at a minimum), while if you steal money or data (e.g. engaging in fraud or embezzlement), you will get fired and face legal consequences. The decision is at HR’s discretion on a case-by-case basis.

Conflict of interest

Conflict of interest may occur whenever your interest in a particular subject leads you to actions, activities or relationships that undermine our company. This includes situations like using your position’s authority for your own personal gain or exploiting company resources to support a personal money-making business. Even when you seemingly act to the company’s advantage, you may actually disadvantage it. For example, if an employee uses dubious methods to get competitor intel and raise their sales record, their action will have a positive impact on the company’s revenue, but it will put us at a legal risk and promote unhealthy business practices.

If it turns out you have created a conflict of interest for yourself, you will be terminated. If the conflict of interest was involuntary (e.g. buying stocks from a company without knowing they’re a competitor), we will take actions to rectify the situation. If you repeat the offence, you may be terminated.

Justice

Don’t act in a way that exploits others, their hard work or their mistakes. Give everyone equal opportunity and speak up when someone else doesn’t.

Be objective when making decisions that can impact other people, including when you’re deciding to hire, promote or fire someone. Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example, when interviewing candidates, ask the same interview questions to all of them and avoid judging non-job-related criteria, like dress, appearance, etc.

Also, don’t discriminate against people with protected characteristics, as this is forbidden by law. If you suspect you may have an unconscious bias that influences your decisions (taking Harvard’s Implicit Association Test could help you determine this), ask for help from HR.

When exercising authority, be fair. Don’t show favoritism toward specific employees and be transparent when you decide to praise or reward an employee. You’re also obliged to follow our employment of relatives policy, which forbids you from having a reporting relationship with a relative.

If you need to discipline an employee, be sure to have prepared a case that you can present to HR. You must not retaliate against employees or applicants (such as in cases when they’ve filed complaints) as this is forbidden by law.

Be just toward customers or vendors, too. If you think our company was in the wrong in a specific instance, don’t try to cover it up or accuse the other side. Discuss with your manager to find solutions that can benefit both sides.

Lawfulness

You are obliged to follow all laws which apply to our organization. Depending on your role and profession, there might be various laws you need to observe. For example, accountants and medical professionals have their own legal restrictions and they must be fully aware of them.

When you’re preparing contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), please ask verification from [our legal counsel] before finalizing anything.

You’re also covered by our confidentiality and data protection policy. You must not expose, disclose or endanger information of customers, employees, stakeholders or our business. Always follow our cybersecurity policy, too.

Following laws regarding fraud, bribery, corruption and any kind of assault is a given. You are also obliged to follow laws on child labor and avoid doing business with unlawful organizations.

If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.

Competence and accountability

We all need to put a healthy amount of effort in our work. Not just because we’re all responsible for the organization’s success, but also because slacking off affects our colleagues. Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles.

We also expect you to take up opportunities for learning and development, either on-the-job or via educational material or training. If you are unsure how you can achieve this, have an open discussion with your manager.

Also, take responsibility for your actions. We all make mistakes or need to make tough decisions and it’s important we own up to them. Failing to be accountable on a regular basis or in important situations (e.g. a crucial mistake in our financial records) will result in termination. If you take responsibility and come up with ways to fix your mistakes where possible, you will be in a far better position.

Teamwork

Working well with others is a virtue, rather than an obligation. You will certainly get to work autonomously and be focused on your own projects and responsibilities. But, you should also be ready to collaborate with and help others.

Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.