CODE OF ETHICS
A copy of this C of E is given to all associates for them to read and accept, a signed copy is returned and held in their file.
1. Honesty
Everwell Associates Limited (Everwell) is committed to the highest standards of ethical conduct in all that they do. The Company complies with all applicable legal and regulatory requirements governing it’s business. Everwell believes that honesty and integrity engender trust and it conducts its business in accordance with all the applicable laws and regulations of the countries in which it does business and requires that its employees, agents and advisers also comply with such laws.
2.Prohibition of Bribery Corruption and Extortion
No personal gain must be made from any transactions or dealings with Customers or Suppliers.
All personnel can accept small items from customers or suppliers, such as a Diary, Calendar, Low value Promotional items such as Mugs, pens etc.
Low value Meals/Snacks can be accepted from Customers & Suppliers, but significant value entertainment that is not directly related to work is not acceptable.
Meals/Snacks can be provided to customers or Suppliers but this must be kept to a minimum and prior agreement must be sought from a Senior Manager/Director.
3. Competition
Everwell competes fairly and vigorously in its market sector and it does not engage in, nor is it a party to, any agreements, business practices or conduct that, as a matter of law, is anti-competitive or may be construed as participation in trade or associated cartels.
4. Integrity in Business Behaviour
Everwell expects their associates to act with integrity and impartiality at all times. Everwell associates who have access to privileged information must not use it to achieve personal gain for themselves or others and no associates shall engage in personal activities or pursue financial or business interests which might give rise to, or give the appearance of, conflicts of interest with Everwell, or which might compromise their ability to meet the responsibilities of their job.
5. Customer, Supplier and Sub Contractor Relationships
Everwell seeks to provide their customers with products and services which meet or exceed their requirement, to respond quickly to changing customer demand and to seek to continuously improve product/service quality, value and delivery times.
Everwell believes in working in partnership with suppliers and subcontractors to meet its customers’ expectations and ensure quality, value and timeliness of delivery. Payment to suppliers and subcontractors will be made promptly within the agreed terms of business.
6. Associates
Everwell selects associates on the basis of their qualifications, skills, aptitude and attitude and treats all its associates with respect and dignity. Harassment or bullying is unacceptable. Everwell complies with all relevant anti-discrimination legislation and regulations in the countries in which it does business in respect of its employment related decisions.
7. Health and Safety
Everwell is committed to conducting all their activities in a manner which achieves the highest practicable standards of health and safety.
8. Environment
Everwell is committed to a proactive policy on environmental issues. To meet this commitment, the company is working towards an Environmental Management System (EMS) operated in accordance with ISO 14001 requirements.
Compliance with legislation is a primary goal. A priority objective is the reduction and management of waste, energy resources and water supplies, as well as minimizing waste at source, and employing reuse or recycling techniques.
9. Human Rights
Everwell seeks to uphold all internationally recognized human rights wherever its operations are based.
10. Reporting and Internal Controls
Everwell records all business transactions accurately prudently and transparently in compliance with its accounting standards and utilizes appropriate internal controls to ensure that it is managed effectively and that the reported results are accurate.
11. Confidentiality
In the normal course of business, any person connected with the organisation has the potential to come into contact with confidential information. In some cases it is coincidental or incidental; in others it is an integral part of the job function. This information may be business related, personal, financial or other. It maybe computerised, in hard-copy, witnessed or oral in nature.
Everwell’s policy is to maintain confidential information in strict confidence, both while at work and when off duty. Therefore all associates who have access to confidential information are prohibited from disclosing such information in an unauthorised manner. They must use this information only in ways that are consistent with this commitment to confidentiality. Consistent with the principle of ‘need to know’, it is also incumbent on all who are exposed to confidential information to see that they only use as much of such information as is needed to perform their function.
12. Application and Compliance
This Code of Ethics applies throughout the Company and to all its associates, temporary contractors, third party sales advisors, agents, and consultants. Disregard or breach of the code may result in disciplinary action against an employee and sanctions/and or immediate dismissal for third parties representing the company.
Everwell seeks, wherever possible, to ensure that its key suppliers, business partners and any joint venture or offset project in which it participates, complies with the Everwell code of ethics or has in place a similar code and business process of its own.
Everwell expects associates to bring any suspected or actual breach of the Code promptly to management attention. Any associate making such information known to management through the appropriate procedures will not face any adverse or unfavourable treatment for such disclosure.
Code of Ethics Review: July 2026