The GILL Group of Companies Limited is committed to ensuring that our business is conducted in all respects according to ethical, professional and legal standards.

This Code of Conduct sets out the principles and values that the GILL Group of Companies Limited will support, and be guided by, in the course of our business. This Code of Conduct is mandatory for all employees, and anybody conducting business on behalf of the GILL Group of Companies Limited. To this end, the GILL Group of Companies Limited expects equivalent standards of conduct from our business partners, clients and supply chain.

The main objectives of this Ethical Code of Conduct are set out under the appropriate headings. The list is not exhaustive, and shall be reviewed periodically. Any action that is unlawful, dishonest, or harmful to others, or is otherwise against the GILL Group of Companies Limited's policies and procedures, will result in disciplinary action.

In All of Our Dealings

In all of our dealings, the GILL Group of Companies Limited shall:

Ø  Comply with all applicable rules, laws and regulations, including the Bribery Act 2010;

Ø  Engage in honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

Ø  Maintain effective procedures to prevent confidential information being misused and make it clear that the use of confidential information for personal and corporate gain will not be tolerated;

Ø  Be alert to, and in accordance with, our whistle- blowing policy, report any fraudulent activities and maintain accurate company records to help prevent their occurrence

In Our Dealings With Customers

We are committed to being straightforward and honest in our dealings with customers. Personal contact and helpful and responsive actions are key features of the service we provide. Therefore, we will:

Ø  Treat our customers fairly and openly, in the manner we would wish to be treated;

Ø  Provide high standards of service;

Ø  Respect the confidentiality of information that we might obtain and retain in relation to customers;

Ø  Take all reasonable care to avoid untruths, concealment and overstatement in all advertising and other public communications;

Ø  Operate an effective complaints process to deal with situations where these standards are challenged

In Our Dealings With Employees

We are committed to high standards of employment practice. Therefore we will:

Ø  Provide a clean, healthy and safe working environment;

Ø  Provide fair and just remuneration packages;

Ø  Implement Human Resource Policies [for example grievances, 'work safe' etc] to ensure that specific standards and objectives are communicated clearly;

Ø  Embrace the principles of the Equality Act 2010

In Our Dealings with the Supply Chain

We are committed to developing relationships with our supply chain that are based upon mutual trust and shared values. Therefore, we will:

Ø  Maintain high standards of integrity in business relationships with suppliers;

Ø  Ensure that all employees will conduct business with our supply chain in a professional manner;

Ø  Expect our supply chain to operate with values and principles equivalent to ours

In Our Dealings With Competitors

We are committed to competing vigorously and in a lawful manner. In doing so, we will:

Ø  Avoid the disclosure of proprietary or confidential information in any contact with our competitors;

Ø  Not attempt to acquire information about a competitor's business by unlawful means, including industrial espionage, hiring competitor's employees to gain confidential information, urging competitor's employees to disclose confidential information, or any other approach that is not above board

In Our Dealings with the Community

On all our developments, we aim to build strong, balanced, long lasting and vibrant communities as we understand the interdependency between the success of our business and the wellbeing of the communities in which we operate. Therefore, we will:

Ø  Endeavour to make a positive, long term contribution to the quality of life of the community and take into account the concerns of the wider community, including both national and local interests;

Ø  Engage actively with local communities to ensure we understand their needs and aspirations

Compliance with this Code of Conduct


The GILL Group of Companies Limited aims to maintain high ethical standards when carrying out its business activities. Practices of any sort that are incompatible with the organisation's principles and policies will not be tolerated. Strict adherence to these policies and principles are a condition of employment within the GILL Group of Companies Limited.

Ultimate responsibility for compliance with this Code of Conduct rests with the Group Chairman. The Group Chairman will ensure that it is communicated to, and understood by, all employees, whilst day to day responsibility for its implementation is delegated to Senior Management.

Failure to comply with this policy may lead to disciplinary action and, where breaches of the law take place, may lead to criminal proceedings against the individual or individuals involved. 

Reporting of Potential Breaches

The GILL Group of Companies Limited expects all employees to report perceived breaches of any aspect of this Code of Conduct, whether by our organisation's employees, or other parties with whom they are dealing. No employee will be treated adversely for raising a concern with Senior Management where it is found to be valid or well-intentioned.  All concerns will be investigated thoroughly.

The GILL Group of Companies Limited welcomes reports from third parties (for example clients, our supply chain or other stakeholders) where there are perceived breaches of this Code of Conduct by employees of our organisation, or parties acting on our behalf. Supply chain members or clients will not be treated less favourably for raising such concerns where they are found to be valid or well-intentioned. All concerns will be investigated thoroughly and, where requested, feedback will be provided to the party making the report.

The GILL Group of Companies Limited shall, without exception, report perceived breaches of any part of this Code of Conduct to the Senior Management / Representative of the third party suspected of committing the breach, and shall request feedback from any investigation that the third party undertakes as a consequence of our report.


This section is intended to provide practical guidance to employees of our organisation to assist with the recognition of practices that breach this Code of Conduct, and to define the minimum standard expected by the Organisation. It is not an exhaustive list, and examples must be taken in context and on a case-by-case basis.

Ø  The promising, offering or giving of reward (monetary of otherwise) if it is known or suspected that this will involve a party performing a function or activity improperly or if it rewards that party for doing so;

Ø  The request for, or acceptance of, reward (monetary or otherwise) as inducement to perform a function or activity improperly or as reward for doing so in the past;

Ø  The acceptance of, or offering to others, a lavish, excessive or inappropriately frequent gift, entertainment or hospitality (with the intention of influencing, or being influenced by, a party to obtain or retain a business advantage);

Ø  The making or receipt of charitable donations with the intention of improperly influencing another party with whom the GILL Group of Companies Limited has a business relationship, or to mask corrupt activity by others;

Ø  Any 'facilitation payment'. A facilitation payment is a payment made to speed up an administrative or otherwise routine process by an official of a government body. (This does not include where legitimate and lawful 'fast tracking' options are available i.e. courier services or obtaining a passport etc). Employees are permitted to make 'facilitation payments' if in fear of their safety or at risk of loss of liberty, but these must be reported to the Company immediately

Signed: Mr Raj Gill, Group Chairman

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