The purpose of this policy is to convey to all employees and interested parties that Oxford Analytica, part of FiscalNote, maintains an unequivocal stance towards the eradication of bribery and a commitment to ensuring that the company, including the wider FiscalNote group, conducts its business in a fair, professional and legal manner.

Bribery is, in the conduct of the Company’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence. Oxford Analytica prohibits any form of bribery. We require compliance with the highest ethical standards and anti-bribery laws applicable from everyone connected with our business.

Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by Oxford Analytica employees or by third parties acting for or on behalf of Oxford Analytica.

This policy applies to all employees of Oxford Analytica, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement.

We will seek to apply this policy to all suppliers; contractors working on our behalf and/or supplying services to us.

Definitions of bribery and corruption:

• Corruption is the misuse of office or power for private gain.
• Bribery is a form of corruption which means in the course of business: giving or receiving money, gifts, meals, entertainment or anything else of value; as an inducement to a person to do something which is dishonest or illegal.

Oxford Analytica is committed to minimising the environmental impact of our operations wherever possible. As a minimum, we will comply with all relevant environmental legislation.

The following policy reflects our primary areas of concern and demonstrates our commitment to environmentally responsible business activities.

Our objectives are to:

1. Conduct our business in a responsible manner in order to comply with all relevant environmental legislation.
2. Seek to measure and continuously reduce the environmental impacts of our activities.
3. Work to reduce the carbon footprint of our business, through more efficient use of energy in our operations, the specification of more efficient equipment and through the purchase of renewable energy where feasible.
4. Aim to reduce waste within our business and to promote recycling and re-use wherever possible.
5. Seek to achieve the most efficient use of resources, such as energy, paper and water.
6. Ensure that environmental criteria are taken into account in the procurement of goods and services.
7. Regularly review our business travel arrangements to look for opportunities to reduce transport emissions and to maximise the use of technologies, which reduce the need for travel.

To implement the policy we will:

1. Ensure that senior managers within our business have clear accountability for environmental issues and that relevant employees are provided with the appropriate information, training and tools necessary to implement responsible environmental practice.
2. Measure our environmental performance against key objectives and targets to work towards improved environmental performance.
3. Ensure that environmental issues are considered in our business planning processes.
4. As part of our Advisory Service offering to Clients we include analysis of sustainability issues.
5. Report on our environmental performance to key stakeholders.

This policy will be reviewed by the Board on an annual basis. The Director of Operations is specifically tasked with keeping the Board advised on compliance with the policy and ensuring that suitable support is available to the business.

Last updated: April 2018

Whistleblowing is the name given to the act of the disclosure of information to the employer or the relevant authority by an individual who knows, or suspects, that the Company is responsible for or taken part in some wrongdoing. In other words, Whistleblowing is when an employee reports suspected wrongdoing at work. Officially this is called ‘making a disclosure in the public interest’.

Those making qualifying disclosures are protected against dismissal or detriment by The Public Interest Disclosure Act 1998.

This policy applies to employees, contractors and any person working for or on behalf of Oxford Analytica.

Certain disclosures are prescribed by law as ‘qualifying disclosures’. A ‘qualifying disclosure’ means a disclosure of information that the whistle-blower genuinely and reasonably believes is in the public interest and shows that the Company has committed a ‘relevant failure’ by:

• committing a criminal offence
• failing to comply with a legal obligation
• a miscarriage of justice
• endangering the health and safety of an individual
• environmental damage or
• concealing any information relating to the above.

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen.

Oxford Analytica will take any concerns that you may raise relating to the above matters very seriously.

Employees must reasonably believe that the disclosure is ‘in the public interest’. We encourage you to use the procedure to raise any such concerns.

The company recognises the importance of having a procedure in place so that you can raise any concerns you have. However, it must also ensure that information and matters that are confidential to the company are not necessarily disclosed to the outside world.

You should therefore report any concerns you may have to the Director of Operations, Director of People & Development or the Global Managing Director who will treat the matter with complete confidence.

Where you have a genuine concern, which constitutes a protected disclosure you should not be afraid of bringing it to the attention of someone within the company. If you make such a disclosure you can be assured that the matter will be taken seriously, that it will be investigated thoroughly and as promptly as circumstances will allow.

If there is a reason why you cannot tell the Company directly or if you are not satisfied with the outcome of actions taken by the Company, you should raise the matter with the appropriate official organisation or regulatory body.

Before instigating this procedure, you should first consider whether the matter should more appropriately be dealt with under the Company’s grievance or harassment procedures.

Providing that you follow the whistle blowing procedure, you will not be disciplined or suffer any other  detriment. However, if a false accusation is made maliciously this will result in disciplinary action being  taken.

TREATMENT BY OTHERS

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action, including potentially summary dismissal

FURTHER INFORMATION

Please review Whistleblowing for Employees UK Government Guidance.

Last updated: June 2018