This Code is intended to:
a) Establish an agreed set of ethical principles for the conduct of the Board and employees of The Irish Air Navigation Service trading as AirNav Ireland (‘the Company’)
b) Promote and maintain confidence and trust in the Company, and
c) Prevent the development or acceptance of unethical practices in the Company.
In certain instances, the Board has adopted more particularised policies and procedures to supplement the requirements as stated in this Code.
2.1.1 The Board has a dedicated Policy on Conflicts of Interest.
2.2.1 Employees of AirNav should not involve themselves in outside employment or business interests which are in conflict, or in potential conflict, with the business of AirNav, or would prevent them from carrying out their duties.
2.2.2 Where a question arises as to whether or not a case involved a conflict of interest for an employee, the matter should be brought to the attention of his / her immediate superior. Where such cases warrant it, the Chief Executive shall determine the question and his / her decision shall be final.
2.2.3 Employees of AirNav must declare in writing to the Company Secretary - who maintains a confidential record - any personal or family interest or possible conflict of interest that might affect their impartiality in carrying out their duties immediately if such exists or as soon as it occurs.
3.1 Board members and employees of AirNav must not accept or give gifts, hospitality, preferential treatment, or any other benefits or favours which might affect or appear to affect the ability of the donor or the recipient to make independent judgement on business transactions.
3.2 Some suppliers, consultancies / service providers and contractors may send unsolicited gifts to named employees with whom they have contact. In such cases employees may accept gifts of small value (less than €100) of this nature provided:
a) The gift is unsolicited
c) Not more than one such gift may be accepted in a year from any one contractor / supplier of goods / services.
3.3 Details of all gifts received by an employee must be notified at once to his / her superior.
3.4 Entertainment of Company employees by suppliers is acceptable within normal commercial criteria. These are defined as follows:
a) A meal may be accepted at a local venue (but this must not include residential stay).
b) A ticket for a sports or other public entertainment event at a local venue may be accepted.
c) Under no circumstances may cash or cash vouchers be accepted by any employee.
4.1 Under no circumstances may any employee, acting in a professional or personal capacity, solicit or request a gift, donation or support from suppliers of goods or services to the Company, or from a user without the express written permission of the Chief Executive or an officer nominated by him. This rule also applies to members or officers of clubs and societies in AirNav Ireland.
5.1 Where a question of the giving of a gift to people or organisations doing business with the Company arises, the approval of the Chief Executive or of his delegated nominee should be sought beforehand. Gifts of this kind must be token and should not normally exceed €100 in value.
6.1 The Board has a dedicated policy on approaches to Directors.
6.2 Approaches may be made to employees to waive various Company policies or requirements. Such approaches may be made formally or informally. In many cases there will be no personal benefit to the employee and nothing to gain from supporting the approach.
6.3 For this reason the employee may not be alert to breaches of his/her obligations to the Company.
6.2 It is important to remember the reason why the Company has developed policies and procedures and specified safety requirements. Not only do they perform stated functions, but many have also been designed to protect the Company. Company policies or procedures are required, unless there are specific provisions allowing for exceptions to be made.
7.1 The Company is committed to competing vigorously and energetically but also ethically and honestly.
7.2 Board members and employees should not acquire business information or the business secrets of competitors or potential competitors by improper means.
7.3 Board members and employees should not use the Company's resources or time for personal gain, for the benefit of persons or organisations unconnected with AirNav or its activities, or for the benefit of competitors.
7.4 Board members should use their reasonable endeavours to attend all Board meetings.
8.1 The purchasing activities of the Company are to be conducted in accordance with best business practice.
8.2 The Company has approved detailed Tendering and Purchasing Procedures, as well as approved levels of authority for approval of expenditure and these must be strictly adhered to. The Tendering and Contract procedures are compatible with and complement EU Public Procurement Directives as well as other relevant international trade control mechanisms.
8.3 The Tendering and Purchasing Procedures are designed to provide an objective framework to assess the products and value-for-money of suppliers, and to provide the organisation with goods and services at competitive prices.
8.4 Tendering procedures and approval levels are fully documented and must be seen as the backdrop to this Code of Business Conduct.
9.1 AirNav will provide access to general information relating to its activities, in a way that is open and enhances its accountability to the general public.
9.2 Members of the Board and employees of AirNav must at all times maintain the confidentiality of information obtained in the course of the Company’s business.
9.3 Members of the Board and employees of AirNav must respect the confidentiality of sensitive information held by AirNav. This includes:
a) commercially sensitive information, including but not limited to, future plans or details of major organisational or other changes such as restructuring
b) personal information; and
c) information received in confidence by the Company.
9.4 There must be appropriate prior consultation with third parties where, exceptionally, it is proposed to release sensitive information in the public interest.
9.5 The Company must comply with the requirements of the Data Protection Act. It should also be noted that, although the Freedom of Information Act does not apply to the Company, communications with the Department of Public Enterprise and other public bodies may be disclosable under the Act.
10.1 Members of the Board and employees of Company must acknowledge the responsibility to be loyal to the Company and be fully committed in all its business activities, and to conform to the highest standards of business ethics.
11.1 The Company is fully committed to:
a) The fulfilment of all its regulatory and statutory obligations
b) The operation of controls to prevent fraud, including adequate controls to ensure compliance with prescribed procedures in relation to the claiming of expenses for business travel
c) Ensuring that its accounts and reports accurately reflect its business performance and are not misleading or designed to be misleading
d) Compliance with employment equality and equal status legislation
e) Fairness in all business dealings
f) Valuing customers and treating all customers equally.
g) Placing the highest priority on promoting and preserving the health, safety and welfare of its employees
h) Ensuring that community concerns are fully considered, and
i) Minimising any detrimental impact of its operations on the environment.
11.2 All members of the Board and employees of the Company are required to bear these principles in mind in the conduct of their duties.
12.1 It is essential that the provisions of this Code be understood and observed by all employees of the Company and in particular by all members of the Board, Management and Supervisory Personnel, i.e.:
a) Anyone who is directly or indirectly involved in the specification, tendering or purchasing process for goods, services and / or construction contracts.
b) Anyone who places contracts or directs work to contractors, professional services or any such third parties
c) Anyone who supplies services to users, licences, etc.
d) Anyone who supervises and / or quality controls work done by contractors, suppliers, installers or dealers, or is responsible for accepting work done by contractors, suppliers, installers or dealers.
e) Anyone who recommends or approves payment for goods, services or work provided by outside agencies.
f) Anyone who directs work, facilitates the provision of services, or completion of work by manufacturers, installers or suppliers.
g) Anyone advising or interfacing with users and / or facilitating the completion of work by suppliers, contractors, other outside agencies, etc.
12.2 The Code will also be adopted in any subsidiaries of the Company.
12.3 It is not possible for a set of rules or guidelines to provide for all situations which may arise. Members of the Board and employees of the Company and any subsidiaries will bear in mind, therefore, that it is primarily their responsibility to ensure that all of their activities, whether covered specifically or otherwise in this document, are governed by the ethical principles described here.
12.4 A copy of this Code of Business Conduct will be circulated to all current members of the Board and employees of the Company and to all new Board members and employees on their appointment. Board members and employees should acknowledge that they have received and understood the requirements of this Code:
a) In the case of Board members, to the Company Secretary
b) in the case of employees, to Human Resources Division.