Offers of entertainment
- Offers of entertainment must have the offering party1 to attend to host guests and have a business element. For example, it promotes good relationships or it follows a meeting.
- Offers of entertainment that might be seen as excessive, as putting you under an obligation, should be declined.
- Where doubts arise, reference should be made to your senior manager before the entertainment offered is accepted.
- Whether given or received, business gifts (including invitations to travel or attend events) must remain within reasonable limits.
- If an employee is embarrassed by receiving a business gift, he/she should report this to the Code Supervisor who will then decide how to proceed.
- Business gifts given by an employee or by Q-Park will only be sent to the business address of the person concerned.
As a general rule, invitations to speak at a commercially-sponsored conference should only be accepted when it provides a good opportunity for Q-Park to interact with a relevant audience. Where fees, expenses and/or gifts are offered, it should be dealt with in accordance with the Q-Park Code of Ethics. These rules also apply to the publication of articles and to media appearances.
Conflicts of personal and business interests
Without prior written permission from the Code Supervisor employees may not enter into private transactions with any person or organisation with whom they maintain contact as part of their job at Q-Park. Private transactions are also understood to include transactions for spouses, partners, relatives and relatives by marriage up to and including the third degree.
In order to avoid the semblance of a conflict of interest the Code Supervisor may impose further restrictions on a transaction. If the Code Supervisor gives his/her consent to the aforementioned private transactions, the same conditions, which will be published within the organisation, shall apply to each employee involved, thus avoiding a conflict of interest and enabling openness and control.
Property transactions - inside information
Employees may not conduct any property transactions without prior written consent from the Code Supervisor3. Property is also understood to include property investment funds in the widest sense; transactions are understood to include acquisition, development, disposal or participation. Conducting transactions using inside information as this is defined under the Financial Supervision Act is forbidden under all circumstances.
Employees must maintain complete confidentiality to third parties regarding all confidential business matters in so far as this does not conflict with a statutory duty to disclose that information. The duty to observe confidentiality remains in force even after termination of the employment contract. The Code Supervisor may grant a written exemption.
Employees may only accept a paid or unpaid ancillary position after obtaining written permission from the Code Supervisor if this might raise the semblance of a conflict of interests with those of Q-Park.
Use of Q-Park property
Employees may only use Q-Park property for business purposes and/or other purposes after obtaining written permission from the Code Supervisor4. Q-Park property includes computers, debit and credit cards.
If a specific situation arises that is not described here but is in conflict with the spirit of this Code of Ethics, the Code Supervisor will decide on the application of the code and if necessary will recommend the employer to take sanctions.
- Business contacts may of course also be personal friends. However, if any hospitality is in conflict with the spirit of Q-Park’s Code of Ethics, seek guidance accordingly.
- Sometimes it would be rude to refuse a gift. It helps to have thought about this in advance and have guidance prepared. For example, the gift could be accepted but returned later with a letter of explanation. Or, its value might be donated to charity. But the giver should be told what you have done and why, to avoid gifts of value being presented on other occasions.
- An exception is made for a private residence.
- An occasional private e-mail or phone call is not considered to be in breach of the code.