How we conduct business

Phil Lewis Associates

It is our policy to conduct all our business in an honest, professional, respectful and ethical manner.

Our values

Bribery and corruption
We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

What is bribery and corruption?
Bribery is offering, providing or receiving something of value as an inducement or reward for something improper. A bribe does not need to be actual money – it can be any form of advantage, offered, requested or received including cash, gifts, hospitality or entertainment. It is a criminal offence to offer, promise, give, request or accept a bribe.

Corruption can include bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement and money laundering.

Engaging in bribery and corruption can seriously damage our reputation and business relationships which we build based on trust and respect. We never offer, give or receive bribes or improper payments or participate in any kind of corrupt activity, either directly or through any third party.

Exchanging gifts and hospitality can build goodwill but may, or may appear to, create improper influence. Any gift or hospitality we accept or give will always be customary and reasonable in terms of value and frequency. Gifts shall never include cash or cash equivalent and shall never be accepted or given in secret. We ensure that our employees declare and keep a written record of all hospitality or gifts given or received.

We only make charitable donations that are legal and ethical under local laws and practices.

Our people

Anti-slavery and human trafficking
We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

What is modern slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Written contracts of employment or engagement shall be provided to workers in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours and other working and employment conditions.

Disciplinary policies and procedures shall be clearly defined and communicated to all workers and shall not include any inhumane disciplinary measure, including corporeal punishment, mental or physical coercion, or verbal abuse; nor shall the include sanctions that result in wage deductions, reductions in benefits or compulsory labour.

The use or threat of physical or sexual violence, harassment and intimidation against a worker, their family or close associates is strictly prohibited.

Our standards

The standards outlined within this ‘How We Conduct Business’ document apply to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, suppliers, service providers, third-party representatives and business partners.

Any employee who breaches any of our standards will face disciplinary action which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

How to raise a concern

We aim to encourage openness and will support anyone who raises genuine concerns in good faith in relation to the standards outlined in this ‘How We Conduct Business’ document.

You are encouraged to raise concerns about any issue or suspicion of malpractice or breach of the standards outlined in this ‘How We Conduct Business’ document you should notify Phil Lewis at

Last updated: June 2023.