1. Our Commitment and Values
At LEO, we are committed to putting our customers first by providing excellent service and great communications experiences through state of the art technology and social networking media. This is what we do and this is why we exist. By focusing on our customers and we will create meaningful work for ourselves and provide something of lasting value for everyone within the LEO community as well as return on shareholder investment. As a result, we will be recognised as a great company.
In order to keep this commitment, we need to always honour our core values:
We respect everyone at every level of our business. We embrace diversity and individuality and listen when others speak.
Integrity is at the heart of everything we do. We are ethical, honest and forthright because trust is at the foundation of our relationships with our customers, our communities, our stakeholders and each other.
We perform to a very high standard. We value innovative ideas and the team work involved to make them realities. We never stop asking how we can improve and every day we find an answer.
We take responsibility for our actions as individuals, as team members, and as an organisation. We work together, support one another and never let the customer ¬or our co-workers ¬down.
We know that we will be judged by what we do, not by what we say.
We will keep pushing ourselves to achieve greater heights and our values will guide our every action.
2. LEO Code of Conduct, Ethics and Values
Our Code of Conduct, Ethics and Values is a statement of the principles and expectations that guide honourable business conduct at LEO.
LEO requires all employees and consultants to use their judgment, to be accountable for their actions and to conduct business with integrity.
This Code of Conduct, Ethics and Values reflects our changing business environment and our business objectives. The code governs the conduct of everyone within the LEO sphere of influence - employees, customers, competitors, suppliers, vendors, contractors and members.
The Code of Conduct, Ethics and Values may not be violated.
Failure to comply with any provision of this Code or company policy may result in disciplinary action, up to and including termination of employment or member agreement, as well as civil or criminal penalties. These consequences may apply not only to employees who commit misconduct, but also to those who condone misconduct, fail to report or take reasonable measures to prevent, detect and address misconduct or seek to retaliate against those who report potential misconduct.
Trust and Credibility
We earn credibility by keeping our commitments, acting with honesty and integrity and pursuing our company goals solely through ethical and professional conduct. By:
• acting responsibly and
• creating an open and supportive environment where employees and members feel comfortable asking questions, raising concerns and reporting misconduct.
• Clear and direct communication of behavioural expectations, modelled and demonstrated by example by everyone associated with LEO.
We achieve our goals solely through ethical and professional conduct.
We enjoy and encourage an open door policy and everyone should feel able to speaking his or her mind, particularly with respect to ethical concerns. You must report suspected and actual violations of this Code of Conduct, Ethics and Values, Company Policy and the Law. The Company is duty bound to investigate and act on reported instances of questionable or unethical behaviour.
In deciding whether a violation of the Code has occurred or is about to occur, you should first ask yourself:
• Could this conduct be viewed as dishonest, unethical or unlawful?
• Could this conduct hurt LEO and our good name? Could it cause LEO to lose credibility with its employees, agents, customers, suppliers or investors?
• Could this conduct hurt other people, such as other employees, agents or customers?
If the answer to any of these questions is "yes" or even "maybe," you have identified a potential issue that you must report.
Imminent Danger or Illegal Conduct
LEO does not tolerate violence or hostile behaviour or intent therefore you must immediately report any instance of violence, hostile behaviour, possession of weapons or any component of a weapon on company property, or related illegal conduct to the Compliance Director. In cases of imminent danger, you should contact 911/999 or local law enforcement first
Discrimination or Harassment
If you believe you are a victim of or a witness to discrimination or harassment, you must report it to the Compliance Director. If your complaint is about your manager or leader or you are otherwise uncomfortable reporting your complaint to your manager, you should report to the Compliance Director.
You may also address suspected discrimination or harassment directly with the person engaging in such conduct if you are comfortable doing so and you believe the conduct is unintentional.
Accounting, Internal Accounting Controls or Auditing Complaints
You must report any concerns or questions you have about the accuracy or integrity of the Company's financial statements, reporting, accounting, internal accounting controls or auditing matters to the Compliance Director.
Reports and complaints will be kept confidential to the extent permitted by law and by the company’s need to investigate the situation.
LEO does not tolerate and therefore prohibits retaliation against employees who submit or participate in the investigation of any complaints. If you believe you or others are the subject of retaliation for reporting suspected misconduct or participating in an investigation, you must report the matter to the Compliance Director immediately
Co-operating with investigations
Co-operation with investigations is a requirement of the company. You must be honest and forthcoming at all times during an investigation, and you must provide any investigator with full, accurate, timely and truthful information. Misrepresenting facts or failing to disclose facts during an investigation is strictly prohibited. You may never interfere with or obstruct an investigation conducted by the company, by any third party on the company’s behalf or any government agency. In addition, you may never disclose or discuss an ongoing investigation unless specifically authorized to do so.
If a police officer, other law enforcement personnel or government employee from any agency requests access to company premises or to company or customer information, you must immediately notify the Compliance Director for appropriate guidance.
Any documents, information or testimony you provide in response to a request by a government agency must be full, fair, accurate and timely, and reviewed in advance by the Compliance Director. If you discover or suspect any misrepresentation, misstatement, misunderstanding, omission or other mistake by yourself or another employee, you must immediately disclose it to the Compliance Director so that the company can take prompt steps to remedy the situation. These requirements do not apply to providing information or testimony, in your individual capacity, to a governmental body or agency on behalf of yourself or co-¬workers where protected by applicable law.
3. Maintain fairness and inclusion at LEO
We act with fundamental honesty and integrity in all company dealings, comply with all laws that govern our business, maintain an ethical and professional work environment and comply with all company policies. We treat everyone with respect, dignity, honesty, fairness and integrity.
Diversity and Equal Opportunity Commitment
We embrace differences and promote an inclusive organisation that values the diversity of employees, customers, suppliers and community partners because it’s the right thing to do and drives business success.
Discrimination and Harassment
We do not tolerate discrimination, sexual harassment or other harassment based on race, colour, religion, gender, sexual orientation, age, national origin, disability, military status, veteran status, marital status, citizenship status or any other unlawful discrimination or harassment based on categories protected under applicable law. Harassment includes but is not limited to, racist, sexist or ethnic comments, jokes or gestures, or any conduct or statement creating an intimidating, hostile or offensive work environment.
We will not tolerate any threatening, hostile or abusive behaviour in the workplace, or on company business, or by any persons on company property, and will take immediate and appropriate action against offenders, up to and including termination of employment or agent agreement and referral for criminal prosecution. We do not tolerate threatening, hostile or abusive conduct directed at employees or customers or agents by LEO personnel at any time or place. Damage to property is also expressly prohibited as is possession of a weapon on company business.
Any instance of violence, hostile behaviour or possession of weapons on company property to must be reported immediately to the Compliance Director.
Workplace Safety and Environment
We are committed to ensuring a safe workplace for all employees and agents and meeting our environmental responsibilities. You must perform your job in a safe and environmentally responsible manner in compliance with applicable policies and practices and the law.
You may never view or display any pornographic, obscene or offensive material through company systems.
Substance Abuse ¬Illegal Drugs and Controlled Substances
We are committed to maintaining a safe and drug-¬free environment for all LEO associates. While on company time, may never use, transfer, sell, manufacture or possess illegal drugs (which include any controlled substances that have not been prescribed for you by your doctor) or drug paraphernalia. You may not report to work under the influence of any illegal drug, or if tested would demonstrate that you have used or consumed an illegal drug.
You may not possess, serve, be under the influence of, or drink alcohol while on company premises property or while conducting business for LEO. The only exceptions are for LEO functions where alcohol may be served only with prior approval from MD or President level, or external events at which you are representing LEO. Although alcohol may be served at such events, consumption is completely voluntary, should always be in moderation, and never in a manner that would embarrass or harm the company.
You must immediately report to the Compliance Director any arrest pending final resolution or conviction for an alcohol¬ related offence relating to conduct while on company property or business or that may otherwise affect your ability to perform your job, or otherwise affect the company’s business.
Solicitation and Fundraising
Solicitation and fundraising distract from work time productivity, may be perceived as coercive and may be unlawful.
Solicitation during work time (defined as the work time of either the employee making or receiving the solicitation), the distribution of non ¬business literature in work areas at any time or the use of company resources at any time (emails, fax machines, computers, telephones, etc.) to solicit or distribute, is prohibited. Non¬ employees may not engage in solicitation or distribution of literature on company premises. The only exception to this policy is where the company has authorized communications relating to products, benefits or services.
You may not gamble or participate in any games of chance (including raffles, sports pools or lotteries) on company premises, on company systems or while conducting company business
We acquire and retain personal information about agents, employees, customers and suppliers in the normal course of business and we are committed to ensuring that that information is vehemently protected.
You should never access, obtain or disclose anyone’s personal information to persons inside or outside of the organisation unless you are acting for legitimate business purposes and in accordance with applicable laws, legal process and company policies, including obtaining any approvals necessary under those policies.
In many jurisdictions, use of recording devices without the consent of both parties is unlawful. You may never record, photograph or videotape any LEO agent, employee, customer, supplier or competitor without that person’s knowledge and approval.
Misconduct Off the Job
Everyone associated with LEO must avoid conduct that could impair work performance or affect LEO’s reputation or business interests. Conduct that could affect the company’s reputation or business interests must promptly be reported to the Compliance Director. This includes:
- any arrest pending final resolution or conviction for any felony (or state or local law felony equivalent);
- any arrest pending final resolution or conviction for a crime involving dishonesty, assault or battery; or
- any other arrest pending final resolution or conviction which may affect your ability to perform your job or otherwise affect the company’s business interests.
Maintain Integrity and Fairness at LEO:
Our reputation depends on the actions and integrity of all LEO associates. It is imperative that you avoid any relationship or activity that might impair, or even appear to impair, your ability to make objective and fair decisions when performing your job.
It is your duty to advance our legitimate interests when opportunities arise. You must never use the company, property or information for personal gain or take personal advantage of any opportunity that arises in the course of your work.
Avoiding conflicts of interest
You must disclose any potential or actual conflict to the Compliance Director.
Personal conflicts of interest
You may not supervise/manage someone with whom you share a close personal relationship, such as anyone in your family or household, someone with whom you have or had a romantic relationship or other close personal relationship.
In addition, you should not use your position at the company to advance your personal interests or those of a friend or relative at the expense of the company’s interests.
Personal Political Interests
Your personal political contributions and activities must be kept separate from the company. If you make political contributions, you may not refer in any way to the company’s assets, including its name, in connection with your contributions, unless required to do so by law
Personal loans from the company to any executive officer are unlawful and strictly prohibited. Personal loans from the company to any other employee must be approved in writing in advance by the Compliance Director. Loans will only be given in exceptional circumstances or unforeseen hardship.
Protect LEO’s Assets and Reputation:
Our reputation is a key asset that must be protected
Preparing, Disclosing and Maintaining Accurate Records
We are committed to maintaining and providing truthful information that fully satisfies applicable legal requirements.
Creating Accurate Records
We always create accurate records that reflect the true nature of all transactions and activities (including, but not limited to, reporting of time, documenting attendance and absence, productivity, commissions and quality assurance).
You must resolve discrepancies in any records and make appropriate corrections. If you suspect or learn that records are misleading or contain errors, you must promptly inform the Compliance Director and, if applicable, customers and business providers.
Even a minor error can affect the truthfulness of a record and therefore you must report all errors, regardless of their size or how long ago they may have occurred. You must report your concern to the Compliance Director.
We do not tolerate falsification or improper alteration of records. It is never appropriate to direct someone else to prepare or approve a false or misleading record. It is also improper to intentionally take any action that leads to the creation of false or misleading records, such as withholding information from, or providing incomplete information to, someone who is preparing a record.
If you believe that a record was intentionally falsified or created to be misleading, you must advise the Compliance Director.
Complete and transparent disclosure
We are committed to transparency in financial reporting
You must not disclose any material information regarding LEO, its business operations, plans, financial condition, results or any development or plan. You should be particularly careful not to disclose such information if you make presentations or proposals to customers, business providers, investors or to any other third party.
Internal and outside auditors are engaged by the Company to ensure accurate reporting. You must cooperate with and provide any auditor or investigator accurate, timely and truthful information. You must not improperly influence, manipulate or mislead any auditor or investigator.
Failure to cooperate with any audit or related investigation will result in discipline, up to and including termination of employment or cancellation of agent agreement.
Safeguard Company information
It is everyone’s responsibility to ensure that "entrusted company information" is safeguarded this includes and is not limited to Company business plans and strategy, internal telephone lists, presentations and correspondence and copyrighted material
Safeguard Company confidential information
In order to safeguard company confidential information all policies and procedures must be followed and contractual agreements for identifying, using, retaining, protecting and disclosing this information must be observed.
Your obligation to safeguard non-¬public information continues even after a relationship with the company is terminated. Without specific written prior authorization, you may never disclose or use company confidential information.
Intellectual property includes information protected by trademarks or copyrights, the use of which is restricted by applicable intellectual property laws. To safeguard intellectual property from illegal copying or other misuse, all company documents must be affixed with or identified by trademark, service mark or copyright symbols.
If you’re unsure whether or what protection is necessary or appropriate, or if you believe disclosure or use by a third party is improper, contact the Compliance Director.
Third party Intellectual Property
We respect the proprietary rights of others by complying with all applicable laws and agreements. Unless property owner’s specific prior consent is obtained, you may not copy, distribute, display, perform, or modify third -party copyrighted materials. A document may be protected by a copyright even if there is no notice on the work.
Maintain LEO’s integrity in the marketplace
Our integrity in the marketplace is a key component of our reputation for trustworthiness and service.
Our customers expect and deserve fair, honest and respectful service. You are accountable for your role in the delivery of that standard of service.
Customer Privacy and Communications
Our privacy policies inform customers about what information is collected about them and how it is used. Customers are also given the ability to limit certain uses of their information. You must respect these choices and always abide by the Data Protection Regulations
Integrity in sales
We always clearly and directly inform our customers of the terms and conditions of our services. Any attempt to deceive a customer will not be tolerated and may result in disciplinary action up to and including termination of employment or cancellation of member agreement. The following guidelines must be followed at all times:
- All advertising and sales materials must be truthful and accurate. Materials must not be false, misleading or have a tendency to deceive.
- All claims must be substantiated in advance with a factual basis and back up. No advertising or sales materials will be released without Company approval.
- When advertising the price of products and services, the customer must be clearly informed of all costs or fees and any other material terms and restrictions for obtaining the advertised rate in marketing and promotional materials. There will be no "hidden" charges.
- Comparisons to competitors must be accurate and substantiated at the time they are made. Do not disparage competitors. You should promote products and services through fair and accurate comparisons with its competitors, and sell on the strength of LEO products, services and reputation. Do not make misleading or inaccurate comparisons with competitors’ products and services; comment on competitors’ character, financial condition or potential legal or regulatory problems; or make negative remarks about entire groups of competitors and their products and services.
- There are strict rules regarding sales and promotions. They must be followed without exception.
Whilst every effort has been made to include all aspects of our requirements for ethical, honest behaviour, it is not possible to describe all unethical or illegal business practices in detail. The best guidelines are individual conscience, common sense and unwavering compliance with all company policies, applicable laws, regulations and contractual obligations. Seek guidance if you are unsure of what to do, ask questions and report wrong-doing. Company policy strictly forbids any retaliation against an employee who reports suspected wrong-doing.
Violations of the law, the Code and other company policies, procedures, instructions, practices and the like can lead to disciplinary action up to and including termination of employment or cancellation of member agreements. Such disciplinary action may also be taken against managers or executives, who condone, permit or have knowledge of improper conduct or fail to take action to prevent and detect violations, such as failure to provide training and failure to appropriately manage situations. No one may justify an illegal or improper act by claiming it was ordered by someone in higher management.
The following are examples of actions considered illegal or unacceptable:
- Theft or unauthorized access, use or disclosure of company, customer or employee records, data, funds, property or information (whether or not it is proprietary);
- Working under the influence of alcohol or illegal substances or abusing legal substances;
- Using any program or promotion in an unauthorized manner;
- Engaging in any form of workplace violence, including, but not limited to, any act of physical intimidation or assault, including threats of violence;
- Soliciting or giving the impression that you would expect gifts or gratuities from suppliers or customers;
- Disparaging or misrepresenting the company’s products or services or its employees;
- Falsifying a company record.