It is mandatory for all employees of SgurrEnergy to observe the Company rules and regulations mentioned below and circulated / amended as and when required. At SgurrEnergy doing the right thing guides how we work and live. Our Code helps us meet our ethical and legal commitments and stay on track when there are questions or situations where the right course of action may be unclear.


Regardless of business or location, we all are responsible for maintaining compliance with this Code and SgurrEnergy policies and procedures. In this Code, “we” or “our” refers to all employees including managers and directors working within SgurrEnergy We also expect our business partners, such as agents, consultants, advisors, contractors, intermediaries and representatives to follow the principles set out in this Code, and to share our commitment to our values.

Our shared expectations

To be successful, we all must act with honesty, openness and fairness. We have a responsibility to ensure that our individual behaviour and our work meet legal standards as well as the high expectations of our Code, policies and values.

You are responsible for reading, understanding and remembering the information in our code,

Everyone must:

  • Act in a manner that is safe, ethical and consistent with laws, regulations and SgurrEnergy values and behaviours.
  • Report concerns of any known, suspected or potential misconduct or Code violation, or ask questions about the right course of action.
  • Complete all required Code training as may be required in a timely manner.

Responsibilities of Managers

Managers / Team Leaders have the added responsibilities of both monitoring and enforcing compliance within their teams.

Managers / Team leaders must be committed to the highest standards for business conduct and demonstrate compliance with this Code and our values through their words and actions.

Managers / Team leaders must:

  • Create an open-door environment where direct reports and other employees feel comfortable asking questions, voicing concerns and reporting known, suspected or potential misconduct.
  • Ensure that team members understand and follow the standards in the Code and SgurrEnergy policies and procedures.
  • Ensure that team members are up-to-date with all required training and certification as may be required.
  • Promptly report all matters relating to ethical misconduct to the immediate reporting manager or human resource department.

Investigation of reports

SgurrEnergy is committed to answering all questions promptly and taking all reports and concerns seriously. SgurrEnergy will investigate reports professionally and promptly. Any concerns related to the Code, you may make a report anonymously, if preferred. However, keep in mind that, it is helpful for you to identify yourself so that the assigned investigation team may contact you for further information. If you are asked to contribute to an investigation or audit, you are expected to cooperate fully. Reported information is treated confidentially to the extent reasonably possible and allowable by local laws. While we strive to resolve matters internally, nothing in this Code or any other Company policy or procedure should be interpreted as preventing you from reporting suspected unlawful conduct to governmental authorities at any time.


You must feel safe to report any suspected violation of our Code. Therefore, SgurrEnergy does not allow acts of retaliation against any person for reporting a possible violation or participating in an investigation as long as the report was made in ”good faith.” Those who retaliate against someone for reporting or cooperating with an investigation may face disciplinary action up to and including termination.

Making a good faith report means providing all of information we know, to the best of our knowledge, regardless of whether our report turns out to be accurate or not.

Workplace safety and health

By taking personal responsibility for health and safety, we all ensure that everyone goes home safe and well.
You can demonstrate care and commitment by:

  • Always following the rules and procedures, including the Life Saving Rules.
  • Always behaving in accordance with our Safety Essentials.
  • Immediately reporting any injury or ill health that is related to our work.
  • Only performing tasks for which you are trained and competent to do.
  • Always reporting health and safety hazards and concerns to our team leader.
  • Always intervening and stopping the job if you believe that something is unsafe or a risk to health.
  • Never working under the influence of illegal drugs, alcohol or prescribed drugs that affect our ability to work safely.
  • Never bringing personal weapons that can harm others, such as guns, into the workplace.

Protecting the environment

We care about the communities in which we operate, and we strive to leave a positive legacy long after our operations have concluded. We are committed to minimising our impact on the environment through conserving resources, reducing waste and emissions and preventing environmental pollution.

You can protect our environment by:

  • Complying with relevant laws and regulations at all times.
  • Managing all environmental risks effectively.
  • Eliminating, or minimising where elimination is not possible, any negative environmental impacts resulting from our operations.
  • Working closely with SgurrEnergy’s personnel, regulators and other external stakeholders to promote continuous improvement in our industry.

Community Involvement

We care about the communities in which we operate and recognise our responsibility to respect, nurture and empower the people and locations we impact. SgurrEnergy’s employees contribute time and talents to make a positive impact on the communities where we live and work. You can facilitate opportunities to partner with the community and ensure our commitments are transparent, ethical and always in alignment with Company values.

Equal opportunity

We are dedicated to fostering an inclusive work environment and treating everyone on the team equally, with respect and compassion. We care about our people and recognise that when people are cared for, they perform better.

You play a part in creating a rich, inclusive work environment by working collaboratively to achieve our goals, embrace diversity, and encourage contributions from all of our colleagues. SgurrEnergy has zero tolerance for discriminating for any reason.

You must never make employment-related decisions or discriminate against anyone based on a legally protected characteristic such as race or ethnicity, age or gender.

All employment decisions, including hiring, promotion and training, must be made on the basis of merit, talent and suitability and must comply with local laws.


We value and respect one another and believe everyone should be able to work in a welcoming environment without fear or intimidation. Contributing to an inclusive and welcoming work environment is part of our job. Harassment can come in many forms—including physical, verbal or sexual—and the intent behind the words or actions does not matter. Do not engage in behaviour that could be considered by someone as creating an unwelcome, intimidating or hostile work environment. Acts of violence, threatening remarks or gestures or other disruptive behaviour at SgurrEnergy are unacceptable. If you experience or witness any form of harassment or workplace violence, report it to your POSH representative.

Some examples of harassing behaviour include:

  • Bullying or threatening remarks or gestures
  • Unwanted touching, gestures or leering
  • Displays of sexually explicit materials
  • Repeated requests for romantic dates when the other person has refused
  • Disparaging or discriminatory jokes or slurs

Labour Laws

We are committed to promoting basic human rights by following applicable local labour laws. We do this because we seek to conduct our business in a way that respects the dignity of people.

We never exploit children or allow involuntary servitude or forced labour in SgurrEnergy and do not work with vendors or suppliers who do not follow all applicable labour laws.

Modern slavery and human trafficking

SgurrEnergy strives to protect and enhance the human dignity of our personnel and everyone who has dealings with our Company. You must respect and enforce the principles established in the Universal Declaration of Human Rights and commit to conducting our business in a manner consistent with all applicable employment and human rights laws and regulations wherever we have operations. You must commit to upholding employment standards in accordance with contractual arrangements. SgurrEnergy has zero tolerance for human trafficking or slavery of any kind may also report any suspicions of instances of wrongdoing to appropriate regulatory authorities.

The Universal Declaration of Human Rights is an international document that states the basic rights and freedoms to which all human beings are entitled.


Trade secrets and confidential and proprietary information are valuable assets. Protecting them is vital to our success. Our customers and employees expect us to maintain strict controls on the confidential information we hold or use. Sharing or using confidential information incorrectly can have serious consequences, including significant fines and penalties, criminal charges and loss of customer trust.

Confidential information can take many forms, such as technical information about our products and services, engineering designs, drawings and layouts, analyses and forecasts, customer and supplier lists, non-public financial information, employee information, company-specific know-how, and information relating to or supplied by our shareholders, customers and other business partners.

  • Do not reveal confidential information to anyone unless authorised or legally required to do so. Avoid discussing confidential information in places where you might be overheard, including restaurants, restrooms, taxis, airplanes or elevators.
  • Do not disclose confidential information to anyone who does not have a business need to know it.
  • Never accept or use the confidential information of our competitors; this may be illegal and would be considered serious misconduct.
  • Do not take confidential information with you if your employment with SgurrEnergy ends.
  • If you discover or suspect the unauthorised use or disclosure of confidential information, notify reporting manager / Human Resources / Director as the case may be

Data privacy

Clients and other individuals often trust us with personal data and confidential information. Keeping personal data safe represents a fundamental element of maintaining the trust of our employees, customers and stakeholders. At SgurrEnergy we are obligated to comply with all data privacy laws around the world, such as to keep all data secure and do not give anyone access to personnel information without proper authorisation based on a business-related need. Treat third-party data with the same care you treat SgurrEnergy information and respect our third parties’ privacy policies and information security requirements. Know and comply with all data protection laws that affect the acquisition, maintenance and use of personal data, and uphold our policies and procedures for data protection and privacy wherever SgurrEnergy does business.

Intellectual property (IP)

Our IP is a valuable asset and provides us with a competitive edge. IP includes intangible property such as copyrights, patents, trademarks, database rights, computer programs, design rights, service marks, logos and brands. Safeguarding our IP is one way we continuously improve, expand and protect our presence in the marketplace. Protect and enforce our IP rights at all times. Only disclose our IP for business purposes and under appropriate protections. Report any concerns regarding the misuse of our IP. Under our standard employment terms and conditions, SgurrEnergy will own the Rights to all IP created during Company time, using Company materials or within the scope of our duties. Do not take SgurrEnergy IP with you when you leave the Company, even if you created the IP.

Physical property

We are responsible every day for the use, care and protection of physical assets belonging to SgurrEnergy and our customers. This property includes equipment, vehicles, facilities, funds, customer tools and documentation and uses it for business purposes only while taking care to protect it against theft, damage or misuse.

Information security

We must keep our confidential information, IP and all other data safe because they are valuable Company assets. Following all security measures and internal controls for our computer system or systems, portable electronic devices, laptops and other storage devices helps us to ensure this happens. Use our network and computer systems ethically and in accordance with SgurrEnergy policies. While occasional personal use of these systems is permitted, SgurrEnergy reserves the right to monitor your use, except when prohibited by local law. This includes all data and communications transmitted by, received by or contained in our Company email or voicemail accounts, as well as electronic documents maintained on SgurrEnergy network drives, computers, laptops and other mobile devices. Take care to properly secure computers, documents and other sensitive materials, including Company passwords or portable storage devices. At no time may you use the internet for unauthorised, illegal or unethical purposes or to download sexually suggestive or explicit material. Take care when communicating using email, and remember that electronic messages can be altered, forwarded and stored without our consent.

Social media

Social media is a powerful tool that can enhance our communications, business strategy and reputation, but it is essential that we use it thoughtfully, respectfully and appropriately.

We use social media thoughtfully, respectfully and appropriately by;

  • Remembering that electronic messages are permanent, transferable records and those messages can greatly affect our reputation.
  • Using good judgment by thinking about what you are saying before posting and by considering how the content would impact the Company.
  • Never giving the impression that you are speaking or acting on the Company’s behalf via social media unless specifically authorised to do so.
  • Never disclosing confidential information.
  • Respecting others by not posting discriminatory, harassing, inappropriate or embarrassing comments or images.

External communications

You may be asked to respond to questions from external individuals or organisations, or receive inquiries from the media, analysts or the investment community. In order to preserve our reputation for integrity, all external communications must be accurate and made by an authorised SgurrEnergy personnel only. Do not make public statements or respond to the media, analysts or the investment community unless designated as a SgurrEnergy spokesperson.

Anti-bribery and anti-corruption

Bribery and corruption damages the communities in which we work. We will not take part in activities that do not support the areas in which we live and work. We will carry out all business dealings ethically, following all anti-corruption laws. We support initiatives that are designed to eliminate corruption, protect global markets and ensure that money is exchanged lawfully.

Anti-corruption laws are global and complex and the consequences of violating them are severe. Seek guidance if you have questions. For more information, review the SgurrEnergy Anti-Bribery and Anti-Corruption Policy.

Do not bribe or attempt to bribe anyone whether he or she is a government official or commercial partner. Do not give government officials or commercial partners anything of value with the intention of influencing them. Do not give or take kickbacks. Think carefully before making a charitable contribution or donating money, resources or time, as all of these things can be seen as a bribe. Immediately report to Compliance any requests made by a government official or commercial partner for money or anything of value, including charitable or political contributions.

Political activities and contributions

While we are free to personally participate in the political process lawfully, on our own time, with our own funds and equipment, SgurrEnergy is politically neutral.

Do not use SgurrEnergy IT systems, printers, fax machines or facilities to spread a political message or support a political cause. Do not make contributions to political parties, leaders, or candidates using SgurrEnergy’s funds or on SgurrEnergy’s behalf. If you choose to participate personally in political activities, make sure your participation complies with Company policies and make it clear that your personal views and actions do not represent SgurrEnergy.

Gifts and hospitality

We strive to build healthy, lasting relationships defined by trust and integrity, based on our quality work and ethical reputation. Exchanging business gifts or entertainment is often a way to build or strengthen good working relationships with customers or suppliers, but we must use common sense and good judgment to ensure we do not do anything that could be seen as inappropriate or as a bribe. Never give or accept gifts, favours, entertainment, cash or cash equivalents (such as gift cards or vouchers) that are meant to influence us or which could be seen as intending to influence us or suppliers, government officials or business partners with government officials are stricter than those that apply to commercial partners.

Third parties and commercial intermediaries

Third parties and commercial intermediaries play an important role in helping us conduct our business globally, including helping us arrange negotiations and services and representing our interests more efficiently than otherwise might be possible. However, they present a significant risk to our company. We are ultimately responsible for the actions of anyone acting on our behalf. What they do can adversely affect our reputation and result in criminal penalties for SgurrEnergy.  Throughout the lifespan of any business relationship, SgurrEnergy must monitor our business counterparts to ensure we are collaborating ethically and safely. The rules around collaborating with third parties or commercial intermediaries are strict.

SgurrEnergy collaborates ethically and safely with third parties and commercial intermediaries by:

  • Engaging in fair and open competition
  • Ensuring suppliers or other third parties are reputable and qualified
  • Ensuring that the hiring of a supplier or other third party does not create an actual or apparent conflict of interest
  • Evaluating and approving commercial intermediaries in accordance with our Commercial Intermediaries Policy.

Conflicts of interest

  • Engaging in fair and open competition.
  • Ensuring suppliers or other third parties are reputable and qualified.
  • Ensuring that the hiring of a supplier or other third party does not create an actual or apparent conflict of interest.

We believe in keeping our personal interests separate from SgurrEnergy’s interests. A conflict of interest can affect our judgment and damage our reputation and the Company’s image. Avoid situations in which your personal interests are — or appear to be — incompatible with SgurrEnergy’s best interests. Avoid the types of situations where a conflict could arise by putting SgurrEnergy’s interests ahead of your own. Always keep in mind that having a conflict isn’t necessarily a problem, but you must speak up if you know of an actual or potential conflict and disclose it immediately to reporting manager/ human resource manager or higher authority of SgurrEnergy. Once disclosed, SgurrEnergy then has the opportunity to resolve any conflicts quickly and professionally.


We are committed to operating our business with high integrity while never conducting or participating in dishonest or fraudulent activities. Our reputation depends on the integrity of our actions and our business dealings. Fraudulent activities are not only unethical but may also be a violation of law. Never engage in dishonest or fraudulent activity, such as deceit or theft, in the performance of your work at SgurrEnergy Recognising red flags is part of your job at SgurrEnergy.

Examples of fraud include:

  • Dishonesty and embezzlement
  • Misappropriation of SgurrEnergy customer, supplier or contractor assets, including cash, supplies, equipment or any other assets
  • Misuse of your position with SgurrEnergy to make purchases for personal use
  • Unauthorised handling or reporting of business transactions
  • Falsification of business documents, inspection reports, records or financial statements

If you suspect fraudulent activity, immediately report your suspicion to your reporting manager finance team or human resource manager.

Accurate business records and business communications

Our records management, sales, bidding and marketing practises must be accurate, honest and ethical in order to maintain healthy business relationships and protect our reputation with our customers, the public and government. Never compromise the integrity of any business record by knowingly entering an untrue or inaccurate statement. Comply with all applicable laws and regulations and preserve any relevant records in case the Company needs them for litigation, audits or investigations. It is up to you to make sure every piece of data you submit into SgurrEnergy records – including personnel, time and expense documentation, and SgurrEnergy or customer inspection test reports – is honest and complete. You must be truthful when representing the quality and details of SgurrEnergy products, services and capabilities.

Competition laws

We are subject to various competition laws in the countries where we do business. These laws are designed to ensure that businesses compete to provide quality services at fair prices. We secure the trust of our customers and the global business community by understanding and following all applicable competition laws. Ensure that you engage with our suppliers / consultants / advisors and customers lawfully in ways that reflect our values and comply with competition laws. Competition laws can be complex, and they apply to everyone at every level of our business. Competition laws generally prohibit price fixing, dividing territories, and agreeing to contract terms with competitors that negatively impact the market. If a competitor attempts to discuss any of these topics with you, object immediately, stop the conversation and report the incident to Compliance or a team leader.

Government contracting

When national, state or local governments or governmental entities are our customers or when government funds are involved in a project, we must abide by more restrictive rules. It is your responsibility to make sure you are familiar with SgurrEnergy policies and procedures.

You are also responsible for:

  • Knowing and complying with all contract requirements.
  • Ensuring all reports, certifications and statements to the government are current, accurate and complete.
  • Understanding the rules when charging time and costs to a project.
  • Assigning all time allocations and costs to the proper category and appropriate contract.
  • Retaining records in accordance with contract requirements.
  • Retaining written records or other documentation until the required retention period has ended.
  • Using government property for specified purposes only.

It is also important to protect any government-classified information you acquire. You should make this information available only to personnel who hold the appropriate government clearance on a need-to-know basis.

Policy Interpretation and Review

The policy will continue to be in force unless superseded by a revised policy. SgurrEnergy reserves the right to interpret, amend, abrogate, modify, rescind / reinstate the entire policy or any part of it at any time.

Effective Date

This policy is effective from July 18, 2019.