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Wilson Perez Ethical Standards Policy

 

Statement of Policy

All our Company employees, servants or agents are expected to maintain the highest standards of integrity, honesty and fair dealing and to conduct themselves at all times so as to avoid actions which may unfavourably damage the interests or the good standing of the company or any of its subsidiaries companies including but not limited to supplier and debtor associates.

 

General Principles

 

1. All commerce must be conducted with respect for human dignity and rights and in accordance with the laws and regulations of the UK or all other countries in which Wilson & Perez does business.

2. Deceitful practices of any kind shall not be tolerated and no bribes, falsehoods, overstatements or inducements will be made to or accepted from any party.

3. All commercial transactions (including debtor payments and sales benefits) must be properly and accurately recorded by the actioning parties.

4. Company assets, intellectual information, property and confidential information must be fully sheltered in accordance with the companies established procedures. In particular, the aforementioned must only be used for the intentions for which they are provided or supplied (where supplied by a customer or third party) and must not be used by employees for personal gain.

5. Offerings, gifts, hospitality, donations and similar payments may only be made or received (as applicable) if sanctioned and in accordance with the companies appropriate Policy.

6. Employees must be made aware of and avoid conflicts of interest in their business relationships and personal activities.

7. Sales agents, company sales consultants and advisers may only be appointed in accordance with the Sales Agents and Consultants Policy. Any and all remunerations wages or paid for services rendered will be in accordance and consistent with the value of those services agreed in this policy.

8. Payments, made to facilitate or speed up events are likely to be considered as bribes. Consequently, such payments should not be made unless specifically permitted after just consideration and externally under the applicable local laws or regulations. Any such prohibited payments which are made under any form of duress must be promptly reported to the duly authorised Executive of the Company.

 

Practice

 

Each company entity or Firm must nominate an appropriate Executive or group of officers acting together for the purposes of:

Advising and assisting employees whenever ethical questions arise and overseeing compliance with the Ethical Standards Policy and the Corporate Hospitality

 

Policy and the Sales Agents and Consultants Policy.

 

Determining whether or not a conflict of interest exists in any given situation.

All companies must provide a protocol requiring employees to report possible conflicts. This must plainly state that it is the duty of each employee who thinks that any action which he or she has taken, or is instructed to take, might result in a breach of ethical principles or a conflict of interest, or who becomes aware of a situation which raises a rational question of such infringement or conflict, to report the facts to his or her boss and to seek guidance, if necessary, from the nominated Executive(s).

Alternatively, an employee is able to report any possible conflicts in accordance with the procedures referred to in the Employee Disclosure Policy.

All invitations to accept a bribe or any proposal or suggestion of such a nature must also be reported immediately to the nominated Executive(s).

The companies must provide appropriate training for its employees in connection with this policy on a continuing basis.

 

Corporate Hospitality Policy

Statement of Policy

The companies and their employees must carry out business in a competitive and reasonable manner, and must conform with the following general principles when determining whether or not to accept or offer any gifts, donations or other similar payments.

General Principles

1. No gifts, offering, hand-outs, entertainment, hospitality or donations shall be made or accepted by the company or employees in circumstances where it might be regarded as likely to influence the outcome of any business/ sales transaction or impact upon an employee’s reasonable business judgement.

2. Under no circumstances must any employee, in or relating to the course of his/her employment, accept or offer personal services, or any gifts of cash or cash equivalents (such as bank cheque or vouchers) to induce anyone.

3. Business-related gifts, entertainment or hospitality (such as lunch, dinner, sporting events) may only be permitted where: it is infrequent, reasonable, proportionate and of modest value;

• in the case of entertainment or hospitality, the provider of the entertainment or hospitality is present; and

• it is not otherwise prohibited by this policy

Group policy

4. Business-related gifts with a value of less than £50 (or local currency equivalent) and entertainment or hospitality with a value of less than £250 (or local currency equivalent) may be offered or accepted without the prior approval of the employee’s line manager, subject to the principles in 3 above.

Business-related gifts with a value between £50 and £250 (or appropriate local currency equivalent) and entertainment or hospitality with a value between £250 and £500 (or appropriate local currency equivalent) must not be offered or accepted without the prior approval of the employee’s line manager.

Business gifts and entertainment or hospitality in excess of £250 and £500, respectively, must not be offered or accepted without the prior written approval of the duly authorised Executive.

5.The offer or provision of a gift, entertainment or hospitality to an associated family member of the provider or employee of any value requires the prior written approval of the duly authorised Executive.

6. No gifts, entertainment or hospitality shall be made to or accepted from public or government officials without prior approval of a duly authorised Executive. The company, nor any employee in or relating to the course of his/her employment, shall make any payment or other contribution to any political party, political office holder and/or candidate.

7. Charitable donations by the companies may only be made where:

• the donation is made in compliance with applicable laws;

• the donation is not made to secure an improper business advantage; and

• the donation is made to a properly established charity and there is a valid charitable purpose for the donation.

8. Promotional expenditure should seek to improve the image of the company and to better present the company’s products or services or to establish cordial relations.

The provision of promotional items such as T-shirts, calendars, pens and other such similar items of modest value is permissible. Any other promotional expenditure (including sponsorship) must be reasonable and proportionate and the prior approval from the duly authorised Executive must be obtained at all times and recorded.

9. No offers of sponsorship shall be provided without the prior written consent of the duly authorised Executive and any use of the companies trademarks must be referred for approval of a company Director

Implementation

The company must appoint an appropriate Executive to whom employees can seek approval for gifts, corporate hospitality, sponsorship and other promotional expenditure as envisaged by this policy.

The company must retain a register and record within it any gifts and hospitality in excess of £50 and £250 respectively that are given and accepted, and all gifts and hospitality of any value that involve public or government officials, and which shall be monitored by the applicable Executive referred to below.

The appropriate Executive is appointed for the purposes of upholding the Ethical Standards Policy and shall also be responsible for monitoring and implementing the policy, and where appropriate seeking guidance from nominated Directors on any issues arising in connection with this policy.

Salesman, Agents and Consultants Policy

Statement of Policy

The Company must comply with the following general principles when appointing selling agents and consultants.

General Principles

1. Properly documented due diligence must be undertaken (e.g. obtaining appropriate and satisfactory references) prior to any commitment being entered into with a prospective salesman.

2. There must be a written contractual agreement setting out all the terms which must be available for audit if necessary.

3. The commissions paid and/or fees proffered to a salesman must be reasonable proportionate and further in the context of the products involved and the services to be rendered.

4. The appointments, terms and conditions, employee contracts and contractual arrangements the company has with the salesman and/or consultant must be legal constituted and governed by the laws of the country those salesmen/agents are domiciled in.

5. There must be clear provisions governing the period of the contract, its termination and the respective parties’ rights on termination, dismissal and resignation.

6. The contract must also require the sales agent/consultant to comply fully with the Ethical Standards Policy, failing which the company can terminate the contract.

7. No payments may be made other than in accordance with the contract.

8. No payments may be made in cash.

9. Properly documented and appropriately detailed financial records should be maintained for all transactions with the salesman or selling agent.

10. Before contracting or employing a salesman, agent or consultant, the company will take appropriate steps in order to eliminate risks of corruption, including: making them aware of the companies Ethical Standards Policy

• ensuring that external sales agents and consultants have anti- corruption policies and procedures in place, and requiring them to ensure that their sub-contractors comply with similar policies and procedures.

 

 

Each member of the Executive Committee, employee workshop or company is responsible for ensuring that this Policy is adhered to in his or her area of responsibility, that appropriate procedures are in place for ensuring that it is complied with and for making an annual report to an external body containing full honest and accountable information including compliances and non-compliances.

All reports will be signed off by the Managing Director with a statement that this Policy has been

Ethical Standards Policy

 

Declaration of intent

I on behalf of the Wilson Perez organisation we declare that we want to prove to all suppliers, consumer’s regulators and authorities that I take our responsibilities very seriously and at all material time commit ourselves to this company its systems of fair practises, fair trading, honourable procedure and ethical selling principles. In pursuit of this mission we hereby and of our own volition submit ourselves and the company to the following acknowledgments and pledges.

I David Cox hereby acknowledge my accountability to the organization for which I direct and to society as a whole to improve knowledge and practice and to adhere to the highest professional standards in all business relationships.

My concept of selling includes as its basic principle the sovereignty of all consumers in the marketplace and the necessity for mutual benefit to both buyer and seller in all transactions and products this company has a voice in.

I shall personally irrevocably maintain the highest standards of ethical and professional conduct in all my business relationships with customers, suppliers, colleagues, competitors, governmental agencies, and the public.

Further I on behalf of the company named above pledge: –

To protect, support, and promote the principles of consumer choice, competition, and innovation enterprise, consistent with all relevant legislative public policies standards.

We shall not knowingly participate in actions, agreements, or marketing policies or practices which may be detrimental to customers, competitors, or established community social or economic policies or standards.

We shall strive to ensure that products and services this company offers are distributed through such channels and by such methods as will tend to optimize the distributive process by offering maximum customer value and service at reasonable cost while providing fair and equitable compensation for all parties.

We shall support efforts to increase productivity or reduce costs of production or marketing through standardization or other methods, provided these methods do not stifle innovation or creativity.

We believe our prices will reflect true value for services to the customer, including the pricing of goods and services.

We acknowledge that in providing the best economic and social product value is consistent with the following:

(a) Recognizing the customer’s right to expect safe reliable and workable timeshare product products;

(b) Providing easily accessible channels for customer complaints;

(c) Investigating any customer dissatisfaction objectively and taking prompt and appropriate remedial action;

(d) Recognizing and supporting proven public policy objectives such as conserving energy and protecting the environment.

Our efforts to assure that all marketing, research, advertising, and presentations of products, services, or concepts are done clearly, truthfully, and in good taste so as not to mislead or offend customers. I further pledge to assure that all these activities are conducted in accordance with the highest standards and generally accepted principles of fair competition.

We will co-operate fully in furthering the efforts of all institutions, media, professional associations, and other organizations to publicise this creed as widely as possible throughout the timeshare industry.

We will unconditionally will submit to TCA audits and provide information to TCA who will test the quality of the service we offer and the claims we make.

We will discharge any and all claims on time and if and when due to all creditors employees and government agencies.

We will comply with the regulations which govern timeshare and the selling of the products we offer and will at all material time try to offer extending to such regulation which affords consumers greater protections.

We unconditionally and irrevocably submit to offer mediation in respect to any consumer issue and before taking legal action. That said if such an offer is not accepted by a consumer or met with silence we at all times and after the offer period has ended (21 days) reserve the right to issue proceeding to protect our own position.

We will supply all the data required by the TCA and give irrevocable permission to the TCA to publish that data so that consumers are able to judge us by our actions

Ethical Standards Policy

By for and on behalf of the

 

In summary.

It is not unethical to make a profit or to make a very good profit. It not unethical to better yourself or to enrich you company organisation or firm.

It is unethical to misrepresent, misrepresent the facts, sell the wrong product or to advance a product which you know will harm or adversely affect a buyer.

If you have a product which provide a solution to another person and will give the betterment which they expect is wholly right, you and your organisation should be paid for that service. Ethical trading is merely about what everyone knows in their heart of hearts. You know if what you are doing is wrong, as in truth it’s a short term gain which will cause you stress and a possible hurt in the future. Sometimes people eject forget what quite enjoyments is and they habitually embark of enterprises and adventure which come back time and time again to bit them. If entirely about how you would like to be treated about extending the family principles to incorporate the concept of the family of man as opposed to the introverted and short sighted me, me, me and mine, mine, mine, concepts.

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