Compliance Policy:
Company Secretary Charlotte Dillon
Charlie Dillon
Last Update 8 months ago
Document Version: 1.0
Effective Date:September 2025
Approved By: Head of Compliance & Board of Directors
Review Cycle: Annual
Objective:
To ensure Maltix Ltd strictly prohibits and actively prevents all forms of bribery, kickbacks, and corruption. This includes compliance with the Bribery Act 2010 (UK) and other relevant anti-corruption legislation.Gifts and Hospitality: Employees must neither accept nor offer gifts or hospitality that could be perceived as improperly influencing a business decision. Non-trivial items must be pre-approved by the Head of Compliance. Facilitation Payments: Strictly prohibited under all circumstances. Due Diligence: Mandatory due diligence must be completed on all third-party agents, consultants, and partners before engagement.
Objective:
To safeguard the privacy and confidentiality of all personal data processed by the company, ensuring full compliance with the General Data Protection Regulation (GDPR) and local data protection laws.Data Principles: Adhere to principles of Data Minimisation, ensuring all processing has a clear, documented Lawful Basis. Security Measures: Implement appropriate technical and organisational controls (e.g., encryption, access restrictions) to protect data.
Data Subject Rights: Procedures must be in place to promptly and correctly handle requests (e.g., Right to Access, Right to Erasure). Breach Protocol: Any suspected or actual data breach must be reported immediately to the Data Protection Officer (DPO).
Objective:
To protect the integrity of Maltix Ltd's decision-making by ensuring employees' personal interests do not interfere, or appear to interfere, with the company's best interests.Disclosure Requirement: All employees must disclose any existing or potential conflicts of interest immediately to their Line Manager and the Head of Compliance. This includes financial interests in competitors or outside employment.
Annual Certification: Employees must complete an annual declaration form certifying they are free from undeclared conflicts. To implement
Management Plan: Identified conflicts must be formally mitigated via a documented management plan approved by the Compliance team.
Objective:
To ensure compliance with securities laws and regulations by strictly prohibiting the use of Material Non-Public Information (MNPI) for personal financial gain.
Prohibition: Trading based on MNPI (or 'tipping' others to trade) is strictly forbidden. Trading Windows: Designated employees will be notified of specific trading windows and subject to blackout periods around key company announcements. Pre-Clearance: Designated employees must seek pre-clearance from the Finance or Legal department before any trade involving company securities.
Objective:
To maintain a safe and healthy working environment for all employees, contractors, and visitors, in full compliance with the Health and Safety at Work Act 1974 and all relevant local H&S regulations.Risk Assessment: Regular, documented risk assessments must be carried out across all premises and activities. Training: Mandatory H&S induction training and role-specific training must be provided to all staff. Incident Reporting: Employees must immediately report all accidents, near misses, and hazardous conditions to the designated H&S Representative. Emergency Procedures: Clear emergency protocols (e.g., fire, evacuation) must be established and regularly practised.
Objective:
To minimise Maltix Ltd's environmental impact through sustainable practices and ensure strict adherence to all relevant environmental laws, permits, and licences.Waste Management: Proper segregation, storage, and disposal of all waste (general, hazardous, electronic) must follow regulatory requirements. Resource Reduction: Employees are required to actively participate in efforts to reduce energy, water, and paper consumption. Permit Monitoring: All necessary environmental permits must be kept current, and their conditions strictly followed.
Objective:
To define the professional and ethical standards expected of all employees, promoting a culture of respect, fairness, and integrity.Workplace Standards: Adherence to policies on Equal Opportunities, Anti-Bullying, and Harassment is mandatory. Company Assets: Assets (physical and intellectual property) must be used responsibly and solely for legitimate business purposes. Confidentiality: Employees must maintain the confidentiality of all proprietary company and client information, both during and after employment.
Objective:
To establish a safe, confidential, and effective mechanism for employees to report actual or suspected violations without fear of retaliation.Reporting Channels: Multiple confidential and/or anonymous reporting channels are available (e.g., Line Manager, Head of Compliance, Legal Department). Non-Retaliation Guarantee: Maltix Ltd strictly prohibits retaliation against any employee who reports a violation in good faith. Investigation: All reported concerns will be promptly, thoroughly, and impartially investigated by the Compliance or Legal Department.
Disciplinary Action: Proven violations will result in consistent and appropriate disciplinary action, up to and including
Termination of employment and Terminati0on of Directorship