Megger Group Code of Conduct 2026

Introduction from our Chief Executive 

Megger has been a leader in electrical test and measurement globally for 130 years. From power generation to the power outlets in your home, Megger products cover almost every application within the Electrical Supply Industry. 

Our products are categorised into seven core application segments: cable test and diagnostics, protection relays and systems, circuit breakers, transformer test and diagnostics, low voltage installations, general electrical testing, and motor and generator testing.  The Group also has a developing Grid Solutions business, including Partial Discharge and Grid Analytics, together with an investment in a software business specialising in Asset Performance Management solutions. 

We have manufacturing sites in various locations within Germany, USA, UK, and Sweden, with our headquarters based in Dover, UK, and sales offices across the globe. 

At the heart of our success has been an ethos of honesty and integrity, which are the core values of 

Megger Group’s Code of Conduct.  The way in which we deal with each other, and our external partners, not only defines the Megger Group brand across the globe, but develops standards which enable the Group to grow further. 

In many instances, high standards of business integrity are common sense, but every Group employee and external partner is ultimately responsible for their actions, which reflect on the Group as a whole.  If these standards are not met, the Group would be exposed to loss of reputation and future business, or for offending individuals, fines and/or imprisonment. 

Every relevant employee and business partner (defined overleaf) is to be provided with a copy of this Code and we expect them to safeguard its standards. Megger Group senior management are responsible for a communication plan, along with relevant training on a periodic basis, in which we expect applicable staff to participate.

As Chief Executive, I personally commit — together with the Group's senior leadership — to upholding this Code and to leading by example in everything we do. We will provide the resources, training and support needed to follow the Code, and we will never expect or reward results achieved by cutting corners on integrity. If anyone, at any level of the organisation, asks you to act in a way that is inconsistent with this Code, you should refuse, and you should raise it with the Chief Compliance Officer or through the Whistleblowing/Speak Up Policy channels. No one will face retaliation for speaking up in good faith. 

If you are aware of any breaches of this Code, you have a responsibility to report it. We have a Whistleblowing/Speak Up Policy which sets out details of how you can make your report and confirms the Group’s commitment to treat the report confidentially.  I would like to stress the importance of consultation if you are in any doubt or have any concerns. 

The reputation and future of Megger Group is in our own hands, I hope this Code allows us to continue to grow and build a bigger and more successful group in the future. 

Megger Group Code of Conduct 
Bodo Zeug, Chief Executive 

 

Background to the Code of Conduct  

This Code of Conduct (“Code”) sets out the ethical principles by which all businesses and employees of Megger Group (the “Group”) are expected to operate worldwide. Compliance with the Code helps to sustain and enhance our reputation and provides a strong message of integrity to all of our stakeholders. 

There are a number of parties who are specifically subject to the Code: 

  • All employees and other staff members, but especially those who interact with third parties (referred to as “Relevant Employees”).
  • All individual reporting entities within the Group, which might be a legal entity, profit centre, sales office or site, depending on the divisional structure (and referred to as a “Business Unit”).
  • All agents, contractors, distributors, associates and joint venture partners with whom we do business in Megger Group (who we refer to as “Business Partners”). 

Our major customers and suppliers (who we refer to as “Trading Partners”) rely upon Megger’s reputation for honesty, integrity and quality. 

Senior Managers must lead by example and give those who report to them the necessary resources and support to understand and follow this Code’s requirements. Each individual must exercise judgment and common sense applying this Code and in dealings with others.  If in doubt, seek advice from your line manager or [email protected].  

 

Core Principles of the Code  

Every employee and Business Partner has a critical part to play in ensuring the Code becomes part of the fabric of our organisation – “doing business the right way” is not about compliance, but culture. No employee or Business Partner should be afraid to express their concerns about perceived unethical behaviour and consultation is critical, even when they are unsure as to its importance or materiality.  In adopting the Code, encapsulated in the following Core Principles, we can work together to deliver growth and prosperity to the Group. 

Our ethos of honesty and integrity is a responsibility we carry as a Group to all our stakeholders and our commitment includes the following: 

  • Collaborative

    We listen well, speak up with respect, and build better together.

  • Consistent

    We show up ready and deliver with focus, care and reliability.

  • Customer Relevant

    We solve real problems by staying curious and focused on what matters most.

  • Confident

    We know our craft, share it clearly, and lead with calm authority.

  • Creative

    We ask better questions, challenge assumptions and drive progress through fresh thinking.

     

The Group will always operate within the legal and moral framework of the countries within which it is located and within which it trades. 

Consequently, the Group expects that all employees will maintain the highest professional standards in their dealings with third parties and with other Group employees and will ensure adherence to legal requirements, rules, procedures and proper practices. 

Individual Group sites will have their own written policies and procedures in place to implement this Group Code of Conduct in their Business Unit in accordance with local requirements / best practice. These documents will be included in the induction programmes of all new employees with commercial and managerial responsibilities. 

Relevant Employees, and high-risk Business Partners where appropriate, will be asked to certify their compliance with this Code and may be required from time to time to affirm agreement to comply with the standards set out herein. The Group may use this attestation process to confirm understanding of the Code, to identify potential issues, and to reinforce a culture of integrity and accountability. 

Compliance with this Code may be monitored, reviewed and audited periodically. The Group may carry out such monitoring and review through management oversight, internal audit and other appropriate governance processes, in each case in accordance with applicable law and the Group's data protection obligations. 

Any exception to, or waiver of, a requirement of this Code may only be granted in exceptional circumstances and will require the prior written approval of the Board or, where delegated, an executive committee or the Chief Compliance Officer. Any waiver and the reasons for it will be recorded, and disclosed where required by applicable law or regulation. 

Megger expects leaders at all levels of the organisation to promote a culture of integrity, ethical decision-making, accountability, and compliance with this Code. Leaders are expected to lead by example and foster an environment where concerns can be raised openly and addressed appropriately.

 

A:  Preventing corruption 

The way we deal with Business Partners, Trading Partners and Public Officials in all our countries of operation will direct our business growth as a Group in the long term.  The Group is committed to acting transparently and fairly. We do not offer or accept bribes or inducements, and we take no part in any corrupt business dealings or practices.  Attempting to improperly influence a person, Public Official or business outcome is also unacceptable. This section should be read together with the Group's Anti-Bribery and Corruption Code of Conduct (ABC Code), which contains the controlling rules on charitable donations, political donations and sponsorships.

 

Bribery and corruption 

Most countries have laws that prohibit bribery and corruption and there is international pressure for a strengthening of these laws across the globe.  In particular, many countries now have laws that extend beyond their borders, meaning an offence committed in an overseas territory can be prosecuted by the authorities in an individual’s or their employer’s home territory. 

The Group prohibits any employee or Business Partner from making or offering any payment or other form of inducement to any person in order to attempt to influence them to perform their duties improperly or secure an improper commercial advantage for our business, or receive similar forms of inducement for doing the same.  We cannot do business with any Trading Partner who does not adhere to the same standards.  The Group extends its ethos of acting in a transparent and fair manner to all third parties through whom we do business – we cannot seek to avoid responsibility by asking others to act improperly on our behalf. 

We must be especially careful in our dealings with Public Officials, who operate under stringent rules, a breach of which could result in severe consequences for the Group and the offending employee or Business Partner. 

Relevant Employees and Business Partners may be asked to undertake periodical bribery and corruption training and to sign an attestation of their understanding of the Group’s bribery and corruption policies, together with the Code. 

 

Gifts, entertainment and hospitality 

The Group expects gifts to be given and accepted only in limited and appropriate circumstances, and with proper oversight and transparency.  The giving or receiving of cash or cash-equivalent items is never acceptable. However, non-cash gifts with a nominal value may be given or accepted subject to prior approval from a Senior Manager. 

Entertainment and hospitality are part of a global corporate culture, where companies seek to build relationships, improve their image and present their goods and services to prospective partners.  However, any hospitality given must be reasonable and proportionate and cannot be given to unduly influence a person to perform their role improperly.  All hospitality that is given or received by a Relevant Employee must be reported to their line manager and duly recorded.

Each Group site will maintain a register of gifts and entertainment, given and received. 

 

Relations with Government 

All information provided to government contacts must be transparent, accurate and appropriate for purpose.  Where we are in partnership with Public Officials, we must ensure the relationship is in full compliance with local law and any gifts and hospitality are employed purely in the interests of building and maintaining relationships, as opposed to being employed to directly secure a benefit for the Group. 

 

Donations policy

The Group does not make donations to political parties, candidates or campaigns, whether in cash or in kind. 

Charitable donations may be made by the Group from time to time, but only for bona fide charitable purposes and not in circumstances where the donation is, or could reasonably be perceived to be, a bribe or an inducement to secure or retain business or any other advantage.

All charitable donations made on behalf of the Group must be pre-authorised by the Chief Compliance Officer. Donations may only be made to a registered charity, and may not be made to, or at the request of, a charity that is connected with a customer, supplier, agent, distributor, joint-venture partner, government official, or a member of their family or other person associated with them, where the connection could give rise to a real or perceived improper advantage for the Group.

No sponsorship arrangement may be entered into, and no third party may be permitted to claim Group affiliation, sponsorship or endorsement, without the prior written authority of a Group Senior Manager. Any request received for sponsorship or endorsement, and any suspected false claim of Group affiliation, must be referred to the Chief Compliance Officer.

 

Local Approvals

We expect each Business Unit to employ comprehensive local approval limits for all applicable processes, including those contemplated by the Code.  A copy of these “Local Approvals” must be supplied annually to [email protected].

This will reinforce compliance with the Code and ensure the highest ethical standards are maintained.  

 

Facilitation of tax evasion

The Group does not tolerate tax evasion, or the facilitation of tax evasion by any person acting on our behalf. 

Relevant Employees and Business Partners must not:

  • engage in, aid, abet, counsel or procure the evasion of tax (whether UK or overseas) by any party;
  • fail to act on, or deliberately ignore, indications that a customer, supplier or other counterparty may be evading tax (for example: requests for invoices to be addressed to a party other than the one we are dealing with, payments routed through unconnected jurisdictions, or requests to mis-describe goods, services or values); or
  • structure transactions, contracts or payments in a way that is designed to assist any party in evading tax.

Any concern that a Business Partner or Trading Partner may be evading tax, or seeking the Group's assistance in doing so, must be raised immediately with the Chief Compliance Officer or through the Whistleblowing/Speak Up Policy channels. Suspected facilitation of tax evasion by a Relevant Employee or Business Partner may also constitute a criminal offence and will be treated as gross misconduct.

This section should be read alongside the Group's UK Tax Strategy, published annually on the Group's website in accordance with Schedule 19 of the Finance Act 2016.

 

Fraud

The Group has zero tolerance for fraud, whether committed by Relevant Employees, Business Partners or third parties.  For these purposes, fraud means any act of dishonesty intended to result in personal gain or to cause loss to the Group or another party, including (but not limited to) false accounting, falsification of records, theft or misappropriation of Group assets, expense or payroll fraud, procurement fraud (including kickbacks, collusive bidding and undisclosed conflicts of interest in supplier selection), and external fraud such as invoice redirection, payment diversion and CEO-impersonation requests.

Relevant Employees and Business Partners must:

  • record transactions accurately and completely, and never make or approve a false, misleading or unsupported entry in the Group's books and records (this section should be read together with the Books and records section in §C);
  • follow all Group authorisation, segregation of duties and approval limits, and never bypass a control to expedite a transaction or to favour a particular party;
  • verify changes to supplier bank details or payment instructions through an independent channel (not the channel by which the change request arrived) before any payment is made; and
  • protect Group assets – cash, inventory, IT equipment and intellectual property – from loss, theft or misuse.

Any suspected fraud, attempted fraud or material control weakness that could enable fraud must be reported immediately to the Chief Compliance Officer or through the Whistleblowing/Speak Up Policy channels.  Suspected fraud will be investigated, and substantiated cases will be treated as gross misconduct and, where appropriate, referred to law enforcement and pursued through civil recovery.

 

B:  Personal integrity

We must operate with the highest personal standards and ensure that transaction flows are earned through honest competition and endeavour.   

 

Anti-Money laundering 

Money laundering is the process of making the proceeds of criminal activity appear legitimate. The Group may be exposed to money laundering risk; for example, through unusual payment arrangements, atypical customer or supplier behaviour, or requests that obscure the true origin or destination of funds.

We are committed to ensuring that our business is not used — knowingly or otherwise — to facilitate money laundering or the financing of terrorism. 

All Relevant Employees and Business Units are expected to:

  • Apply reasonable care when onboarding new Trading Partners
  • Be alert to requests for unusual payment terms or third-party payment arrangements
  • Question unusual transactions - payments inconsistent with the scale of a transaction, split across multiple accounts, or made in cash without explanation should be queried before processing
  • Maintain clear documentation of transactions and commercial rationale, particularly where payment terms deviate from our standard arrangements

Relevant Employees and Business Units and Business Partners should not act together, or facilitate others, in breaking up payments in a way intended to avoid detection or reporting thresholds.

Red flags — things that should prompt a report

  • A customer or supplier requests payment to a third-party account unrelated to the transaction
  • Unusually large cash payments, or requests to receive or make payments in cash
  • A customer overpays and requests a refund to a different account
  • Reluctance to provide standard business information or documentation
  • Transactions with no apparent commercial rationale, or that seem inconsistent with a customer's stated business
  • Pressure to complete transactions unusually quickly, without proper paperwork
Important — tipping off: Tipping off is a criminal offence in most legal regimes. If you suspect money laundering, do not discuss your suspicion with the individual or business involved. Always report internally first.

 

How to report a concern

If you have a suspicion or concern — however minor it may seem — report it promptly to your line manager. You can also use the channels set out in our Whistleblowing/Speak Up Policy. Reports made in good faith will not result in any detriment to you, even if the concern turns out to be unfounded.

The Group’s anti-money laundering officer (MLRO) can be reached at: 

Email: [email protected] 

 

Conflicts of interest 

 A conflict of interest will arise where personal interests conflict with those of the Group.  Situations where there appears to be a conflict of interest should be avoided. 

 Conflicts of interest may arise through the following: 

  • Personal shareholdings, directorships and other financial interests.
  • A close relative or spouse working in an organisation that does business with or competes with the Group.
  • Benefitting from the sale, loan or gift of any business property.
  • Failing to give the Group the opportunity to benefit from a legitimate business opportunity.
  • Deriving any direct or indirect benefit, such as commissions, from a contract entered into by the Group or a Business Unit. 

Relevant Employees and Business Partners are required to disclose on appointment, or when the conflict arises, any interest which may affect the Group’s business. 

Relevant Employees and Business Partners must not take personal advantage of, or divert to themselves or to any other person, any business opportunity that is discovered through their position with the Group, through the use of Group property or information, or in the course of performing their duties for the Group. Any such opportunity must first be offered to the Group, and may only be pursued personally if the Group has declined it and any conflict has been disclosed and approved in accordance with this Code. 

 

C:  National and international trade 

The Group is committed to behaving with openness, transparency and integrity. This means that we will not act in collusion with our competitors and will be open and honest in our dealings in all markets, even where this is expensive or time consuming. 

 

Compliance with laws and regulations 

The Group and its Business Units must comply with the laws and regulations of the jurisdictions in which they work.  This extends to the intended spirit of the law, rather than relying purely on its written form. 

Each Group company must establish and enforce effective compliance procedures, where necessary through taking local advice.  Where differences arise between local customs, practices, laws or regulations and this Code, the individual is required to consult the Chief Compliance Officer. 

 

Competition legislation (anti-trust law)

Competition law protects free and open trading across the world and applies to all companies. The penalties for breaching competition law are severe and include substantial fines for the Group, personal fines, director disqualification and imprisonment for individuals involved. Senior Managers are required to be familiar with local competition and anti-trust legislation and communicate this to relevant employees. Such familiarity is critical to ensure that we avoid inappropriate behaviour within the Group and protect our interactions with Business Partners, Trading Partners and competitors. The laws of the UK, US and EU are especially stringent and extend beyond their geographic borders. If you are in any doubt about whether a proposed agreement, communication or course of conduct is permitted, seek advice from the Chief Compliance Officer or Group legal advisers before proceeding. 

There are a number of activities we need to be aware of and avoid: 

  • Agreements with competitors surrounding:
    • Bids and tenders.
    • Prices.
    • Production levels.
    • Customers and/or suppliers that we will or will not deal with.
    • Markets that we will or will not trade in.
  • Abuse of market power:  conduct such as:
    • Predatory pricing
    • Exclusive dealing
    • Refusal to supply
    • Tying
  • Resale price maintenance and vertical restraints, such as:
    • Agreements with distributors fixing resale prices
    • Exclusive territories
    • Restricting parallel trade
  • Exchange of confidential or competitively sensitive information with competitors, such as contract pricing, customer lists, future pricing intent, capacity plans or commercial strategy. Such exchanges can breach competition law even where there is no agreement to act on the information.
  • Mergers, acquisitions and joint ventures that meet competition authority thresholds may require prior notification and clearance; the Chief Compliance Officer must be consulted before any such transaction is progressed.

Group employees frequently encounter competitors at trade association meetings, industry conferences, standards bodies and similar events. These forums are legitimate and often valuable, but they are also the setting in which most inadvertent competition law breaches occur. The following practices must be observed:

  • Obtain a written agenda in advance of any meeting at which competitors will be present, and decline to attend if the agenda includes — or is unclear about — competitively sensitive topics such as pricing, customers, bids, capacity or commercial strategy.
  • Ensure that formal minutes are taken and retained, and check that they accurately record what was discussed.
  • If a sensitive topic is raised during the meeting, or in a side conversation, employees must object clearly so that it is heard by those present, leave the meeting or conversation, and ask for their objection and departure to be recorded in the minutes.
  • Report the incident to the Chief Compliance Officer as soon as possible afterwards, regardless of whether the conversation continued.

The same standards apply to informal contact with competitors — including social events, conferences, and conversations with former colleagues now employed by a competitor. The setting does not change the law.

Responding to a regulatory investigation or dawn raid

Competition authorities in the UK, US, EU and many other jurisdictions have the power to enter Group premises without notice to gather evidence — commonly known as a "dawn raid". If officials arrive at any Group site, or if an employee is contacted by a regulator in connection with a competition investigation, the following steps must be taken:

  • Contact the Chief Compliance Officer and Group legal advisers immediately, before officials begin their search wherever possible.
  • Cooperate fully with the investigators and verify their identities and the scope of their warrant or authorisation.
  • Do not, under any circumstances, destroy, delete, conceal or alter any documents, emails or electronic records. Suspend any routine document or email deletion processes immediately.
  • Do not mislead investigators, provide false or incomplete information, or warn other parties (including other Group companies or competitors) that an investigation is underway.
  • Do not answer substantive questions without a legal adviser present; employees may politely decline to comment until advice has been obtained.
  • Keep a contemporaneous record of what is searched, copied or removed, and request copies of any documents taken.

Obstructing an investigation, destroying evidence or "tipping off" third parties are themselves criminal offences in many jurisdictions and can result in personal liability, including fines and imprisonment, separate from any underlying competition law breach.

 

Export controls 

Export controls and sanctions regimes — including those administered by the UK (Department for Business and Trade, OFSI), the US (BIS, OFAC) and the EU — give countries the ability to control the movement of goods, software, technology and services across national borders, and to prohibit dealings with designated countries, entities and individuals. Controls apply to physical shipments, electronic transfers and the sharing of technical information with foreign nationals (including within the UK). Many of the Group's products are capable of being classified as "dual-use" items, meaning that they may have both civil and military applications and that an export licence may be required before they are shipped or shared.

Penalties for breaching export controls or sanctions are severe and include criminal prosecution, fines and imprisonment for individuals, in addition to product seizure, loss of export privileges and significant reputational harm. Liability can follow the product as well as the sale: if the Group sells to a third party who then re-exports to a restricted territory or end-user, the Group may still be held responsible. The Group will not trade, directly or indirectly, with sanctioned countries, entities or individuals. It is critical therefore that we know where our products are going, who the ultimate end-user is and what the end-use will be, and that we remain vigilant for potential breaches. Each Business Unit should:

  • classify its products against the relevant export control lists and identify those that are particularly sensitive or potentially dual-use;
  • identify the countries to which export bans, restrictions or licensing requirements apply;
  • screen all customers, agents, distributors and other counterparties against UK, EU and US sanctions lists before engaging in new business and at appropriate intervals thereafter; and
  • escalate any "red flag" to the Chief Compliance Officer before proceeding — for example, reluctance to provide end-user information, unusual routing or shipping arrangements, payment from a third country, requests to mark or describe goods misleadingly, or end-uses connected with military, nuclear, chemical, biological or missile applications. 

The Group subscribes to electronic screening tools to support counterparty due diligence, including World-Check, which must be consulted whenever engaging in new business and at appropriate intervals thereafter. A clear screening result does not by itself authorise a transaction where other red flags are present. 

Relevant Employees— particularly in sales, engineering, logistics and finance — will be provided with appropriate export controls and sanctions training, and records relating to classification, licensing, screening and shipments will be retained for the periods required by applicable law (typically five to ten years). Guidance on any export controls or sanctions concerns is available from the Chief Compliance Officer at [email protected]. 

 

Import controls 

Import controls give countries the ability to regulate the goods and services entering their jurisdiction, and operate in a fashion similar to export controls. Group entities are frequently the importer of record and bear legal responsibility for the accuracy of customs declarations — including the correct tariff classification, declared customs value, and country of origin of imported products — even where a customs broker or freight forwarder files on the Group's behalf. 

Particular care must be taken with: (a) tariff classification, since misclassification can lead to under- or over-payment of duty and to penalties; (b) customs valuation, especially on intercompany shipments between Group entities, where declared values must reflect the price actually paid or payable and be consistent with the Group's transfer-pricing policies; and (c) preferential origin claims under free trade agreements (such as the UK-EU Trade and Cooperation Agreement or USMCA), which must be supported by appropriate evidence and supplier declarations before being relied upon. Anti-dumping, countervailing and safeguard duties may also apply to certain products depending on origin.

Import controls also include prohibitions and restrictions on goods originating in sanctioned territories or produced under sanctioned conditions. The Group will not import goods that breach applicable sanctions, and will not import or knowingly handle goods produced wholly or in part using forced, prison or child labour. Group entities must apply appropriate supply-chain due diligence to identify these risks, in line with the Group's Procurement Policy, Supply Chain Code of Conduct and Modern Slavery Policy.

Customs records — including classification rulings, valuation evidence, origin documentation, broker instructions and shipment files — must be retained for the periods required by applicable law (typically four to seven years). Guidance on import duties, classification and valuation is available from the Group's Head of Tax and Treasury; questions involving sanctions, forced labour or other compliance concerns should be referred to the Chief Compliance Officer at [email protected].

 

Conduct of trade 

 

Books and records

The Group requires complete, accurate and timely records of all transactions. No Group employee or Business Partner may make any false, misleading or artificial entry in the Group's books, records or financial statements, maintain any undisclosed or unrecorded account, fund or asset, or process any payment without proper authorisation and supporting documentation. This obligation applies to financial records, regulatory filings, expense claims, time records, quality and test data, and any other documentation produced in the course of Group business, whether in paper, electronic or other format.

All Group employees and Business Partners must cooperate fully and honestly with internal and external auditors and must not seek to mislead, obstruct or improperly influence the auditors, or any audit, investigation, regulatory review or regulator. In particular, no person may take any action to fraudulently influence, coerce, manipulate or mislead any internal or external auditor, or otherwise seek to compromise the independence, objectivity or judgement of the auditors or the conduct or conclusions of any audit or review, whether by offering an inducement, applying pressure, withholding information, or providing false or incomplete information. Inaccurate books and records may give rise to criminal as well as civil liability; and may also constitute fraud or false accounting under local law.

Megger is committed to maintaining effective internal controls, accurate financial records, and robust governance processes to support the integrity, reliability, and transparency of its financial reporting and business operations.

All public statements, regulatory filings and other external disclosures made by or on behalf of the Group must be accurate, complete, fair and not misleading, and must be made only by those authorised to do so. Relevant Employees and Business Partners must not knowingly provide false or misleading information in, or omit material information from, any such statement, filing or disclosure, and must cooperate to ensure that the Group meets its disclosure obligations under applicable law and regulation.

Any concern about the integrity of the Group's records, or any request to make or conceal an entry that may be inaccurate, must be raised immediately with the Chief Financial Officer or the Chief Compliance Officer, or reported under the Group's Whistleblowing/Speak Up Policy.

 

Product safety, conformity and labelling

The Group’s products are designed, manufactured and tested to conform to the safety, performance and environmental standards and legal requirements applicable in each market in which they are sold. Conformity assessment will be carried out and supporting technical documentation maintained in line with each regime's requirements.

All product labelling, including safety and quality marks, country of origin, performance specifications and any accompanying documentation, must be accurate, substantiated and not misleading. The Group will not sell or market products into a territory whose mandatory requirements they do not meet, and will not relabel, repackage or reconfigure products to evade those requirements. Performance claims made in marketing, datasheets and calibration certificates must be capable of substantiation.

Where a Group product is found, or reasonably suspected, to be non-conforming or unsafe, the relevant Business Unit must promptly notify the Chief Compliance Officer and the site quality team, and the Group will take appropriate corrective action — including, where required, notification of the competent regulator and recall or withdrawal of affected products. 

 

D:  Doing business the right way 

The Group’s success is driven by its employees and all its external partners. Contracts, agreements and other arrangements with third parties should be transparent, fair and commensurate with the services provided. 

 

Company contracts 

Megger seeks to conduct procurement activities in a fair, objective, and transparent manner. Supplier selection decisions are based on legitimate business considerations including quality, service, cost, sustainability, compliance, risk, and long-term value.

The Group maintains a set of policies and procedures, which includes a set of due diligence procedures for use by Business Units to take appropriate steps to confirm that a third party is reputable and has the appropriate skills and qualifications to act.  Similarly, we only deal with Trading Partners who we know to be reputable, having made appropriate enquiries.   

 

Payments to Business Partners 

All payments made to Business Partners must be proportionate to the services they provide and in line with market rates. 

Two particularly important arrangements are: 

  • Consultancy assignments, which are defined as advisory services bought from external parties in the furtherance of Group interests.  These would include assignments associated with the securing of orders or contracts.
  • Commissions, which are defined as payments for services provided in the furtherance of Group interests and/or the potential securing of business for Group companies. All commissions must be paid in the best interests of the Group and must be commensurate with the circumstances. 

All payments made in such circumstances are required to be made in line with a formal written legal agreement, which makes clear the service provided, calculation of the payment and the performance obligations required in order to make a payment. 

 

E:  Protecting the Group 

The Group relies on the physical protection of its property, plant and equipment, along with its Intellectual Property.  To this end, the exchange of information must be made responsibly, with due regard to confidentiality and appropriate records maintained. 

 

External communications 

Media enquiries about any Business Unit should be routed to a Senior Manager.  No comment should ever be given to the media about Group matters and all enquiries directed to the Group Chief Executive, Bodo Zeug. 

 

Records management 

All company records must be maintained to a high standard, ready for scrutiny by internal Group functions or external regulators and auditors.  Copies of all communications with regard to major contracts should be kept for a period in line with local law and our local retention schedules.

 

Company property 

Company property must be handled with care to avoid loss, theft or damage and should only be used for business purposes.  Employees shall ensure that all Company property is: 

  • Treated with due care and respect
  • Regularly checked and, where appropriate, any damage / concerns with the safety / operation of the item is reported to the local line manager immediately
  • Not used if there are any grounds to believe that it is unsafe 

Employees shall not use any pieces of highly technical Company property that they have not been appropriately trained and/or qualified to use. 

Limited personal use is permitted at the discretion of Senior Management. 

 

Insider dealing and market abuse

In the course of their work, Relevant Employees may come into possession of information about the Group, its customers, suppliers, joint venture partners or other counterparties which is not generally available and which, if made public, would be likely to have a significant effect on the price of shares, bonds or other financial instruments. Examples include unpublished financial results, proposed acquisitions, disposals or major contracts, significant operational incidents, planned product launches or recalls, and confidential information received from a listed customer or supplier under a non-disclosure agreement.

This is known as inside information. It is a criminal offence in the United Kingdom (under the Criminal Justice Act 1993 and the UK Market Abuse Regulation) and in most other jurisdictions in which the Group operates to:

  • deal, or attempt to deal, in financial instruments on the basis of inside information;
  • recommend or induce another person to deal on the basis of inside information; or
  • disclose inside information to another person otherwise than in the proper course of one's employment ("tipping off").

These prohibitions apply regardless of whether the inside information concerns the Group itself or a third party, and regardless of whether any profit is made. They apply to dealings by Relevant Employees personally and to dealings by their family members, associates or any other person acting on information they have passed on.

Market abuse also extends to manipulating prices through false or misleading transactions, signals or information. Relevant Employees must not engage in, assist with, or fail to report any conduct of this kind.

Any Relevant Employee who believes they hold inside information must:

  • not deal, and not advise or encourage anyone else to deal, in the relevant instruments until the information has been made public or has ceased to be price-sensitive;
  • keep the information strictly confidential and disclose it only to those who need it for the proper performance of their duties; and
  • consult the Chief Compliance Officer in case of doubt.

Breach of these rules may constitute a criminal offence carrying personal liability, including fines and imprisonment, and will also be treated as a serious disciplinary matter that may result in dismissal.

 

Intellectual Property 

Intellectual Property Rights include copyrights, trademarks, patents, industrial design rights and trade secrets, both in electronic and written form.  It is critical that all Intellectual Property held by the Group is kept securely and its confidentiality maintained. 

If at any time during the performance of their duties, an employee creates or discovers any Intellectual Property, it shall immediately be disclosed to a Senior Manager to enable necessary protection to be secured. 

Third party Intellectual Property Rights shall be respected across all our global operations and improper use of such property is forbidden.   

 

F:  Our Environment and Human Rights

Megger Group is committed to the highest standards of quality for all of its products and services and for the safety and protection of its employees.  The Group is committed to equality and fair treatment of its entire workforce, which involves mutual respect for each other and to protect our working environment. 

 

Health, safety and the environment 

The Group is committed to achieving and maintaining the highest standards of safety for its employees and where relevant, Business Partners, Trading Partners and the public. The Group’s goals are to have no accidents, cause no harm to people and have the highest regard for the environment and our footprint. 

Each Business Unit must have in place a tailored health and safety programme designed to, at a minimum, comply with local regulatory requirements. 

The Group is committed to the protection of the environment by using renewable resources wherever possible, and developing manufacturing processes and procedures, which ensure that adverse effects on the environment are kept to a minimum. 

The Group continually looks for opportunities and adopts practices that create a safer and cleaner environment. Environmental concerns must be taken into account in all planning and decision making processes.  It is the responsibility of each Business Unit to have in place procedures to encourage the reduction of waste and emissions, and to take into account local environmental issues and the communities in which it operates.   

 

Human rights 

The Group is committed to respecting internationally recognised human rights across its operations and supply chain, and to conducting business ethically and with integrity.  This commitment applies to all employees, to every Business Unit, and to all Business Partners. 

We expect everyone working for or with the Group to treat colleagues, workers in our supply chain and other stakeholders with dignity and respect, and to comply with applicable laws on labour rights and working conditions.  Megger is committed to identifying, assessing, preventing, and mitigating actual and potential human rights risks within its operations, business relationships, and supply chain through a risk-based due diligence approach. In particular, the Group will not tolerate modern slavery, forced, compulsory, prison or child labour, human trafficking, unlawful discrimination, harassment, bullying or victimisation, or any infringement of the lawful right to freedom of peaceful assembly, association and collective representation.  The Group is equally committed to providing a safe and healthy working environment and to recognising mental as well as physical wellbeing. 

These principles are given practical effect through the specific provisions set out below and elsewhere in this Code, the Group's Labour and Human Rights Policy, the Supply Chain Code of Conduct, and the Group's health, safety and equal opportunity arrangements.  Any concern about a possible human rights or labour rights impact connected with the Group or its supply chain should be raised with a line manager, the Chief Compliance Officer at [email protected], or under the Group's Whistleblowing/Speak Up Policy. 

 

Modern Slavery Act 2015 

Megger Group is committed to operating all aspects of its supply chain to ethical, environmental, social and safe business best practice.  As such Megger requires all vendors supplying the company to operate to the same high standards, noting that vendors shall operate within the rules, laws and regulations applicable to the country of origin. 

The supply chain code of conduct used and operated by Megger Group has been developed to detail the expectations from all vendors.  This is our minimum standard of practice expected, which includes appropriate due diligence to address the Modern Slavery Act 2015, implementing effective systems and controls to prevent and detect modern slavery.  All vendors must be capable of demonstrating their procedures for compliance upon request and during vendor audits which are regularly implemented in high risk countries.

Megger reviews its supply chains and operations on a continuous and ongoing basis to check compliance with the policy, ensuring the policy is implemented effectively. 

Further details of the Group’s policy can be found at: 

https://uk.megger.com/company/about-us/legal/modern-slavery-act 

 

Conflict minerals

The Group recognises that the extraction and trade of certain minerals — specifically tin, tantalum, tungsten and gold (collectively, "3TG" or "conflict minerals") — from the Democratic Republic of the Congo and adjoining countries has the potential to finance armed conflict, civil war and serious human rights abuses. Megger does not directly source 3TG from these regions and no products manufactured within Megger's own manufacturing facilities contain such materials.

The Group's Supplier Code of Conduct specifically addresses the responsible sourcing of conflict minerals and applies to all vendors supplying the Group. Vendors are required to have in place policies and procedures that reasonably ensure that materials consumed in their manufacturing processes do not directly or indirectly finance armed groups, terrorism, or any party responsible for serious breaches of human rights, and to exercise appropriate due diligence over their own upstream supply chains.

Vendors must, upon request, make their supply chain of in-scope materials available for inspection, and must cooperate with any Group enquiry, audit or supplier survey relating to the origin of 3TG. Concerns regarding conflict minerals in the supply chain should be reported to the Chief Compliance Officer at [email protected] or under the Group's Whistleblowing/Speak Up Policy.

 

Opportunity policy

The Group is committed to building a workforce in which every Relevant Employee is treated with dignity and respect and is able to contribute fully to the Group's success. We aim to ensure that no job applicant or employee receives less favourable treatment on the grounds of race, ethnic origin, nationality, age, trade union activities, sex, marital or civil partnership status, pregnancy or maternity, gender identity or expression, part-time or fixed-term status, sexual orientation, religion or belief, or disability. 

We comply with equal-opportunity and anti-discrimination laws in each jurisdiction in which we operate, applying the higher standard where local law sets a lower bar than this Code.

 

Inclusion

Equal opportunity is the floor, not the ceiling. The Group is committed to fostering an inclusive working environment in which differences are valued and every Relevant Employee can speak up, be heard and progress on the basis of merit. Recruitment, selection, training, development, promotion, performance management, reward and termination decisions must be made on objective, job-related criteria, free from bias. Managers are responsible for setting an inclusive tone within their teams and for addressing exclusionary behaviour, whether or not it meets the threshold of harassment.

 

Reasonable accommodation

The Group will make reasonable adjustments to working arrangements, the working environment and recruitment processes to enable applicants and employees with disabilities, long-term health conditions, neurodivergence or other protected characteristics to apply for roles, perform their work and access development opportunities on an equal footing. Adjustments may include changes to working hours or patterns, equipment, software, the physical workspace, communication formats or assessment methods. A request for an adjustment will be considered constructively and confidentially, in consultation with the employee or applicant; an adjustment will be made unless doing so would impose a disproportionate burden on the Group. The same approach applies to adjustments related to religious observance, pregnancy and maternity, and caring responsibilities, where consistent with operational requirements and local law.

 

Pay equity

The Group is committed to paying Relevant Employees fairly for the work they do. Pay, bonus and benefit decisions must be based on the role, the individual's skills, experience and performance, and applicable market data – and not on any protected characteristic. The Group will comply with all applicable gender, ethnicity and disability pay reporting requirements and will investigate and address any unjustified disparities identified.

 

Harassment 

The Group’s employees come from many countries with different backgrounds and cultures.  The Group values the diversity of its employees and respects their right to work in a safe environment of mutual respect, free from harassment and ensuring equal opportunity. 

Megger is committed to providing a safe, respectful, and inclusive working environment. Violence, threats, intimidation, coercion, or aggressive behaviour towards employees, contractors, customers, visitors, or other stakeholders will not be tolerated.

Harassment can take many forms and includes: 

  • Slurs, insults, name calling and ridicule.
  • Offensive or obscene comments, jokes, gestures.
  • Bullying, public criticism, undervaluing effort.
  • Unwanted physical contact, assaults or threats and intimidation. 

Harassment in any form, especially sexual harassment, creates a hostile and abusive work environment and will not be tolerated. 

 

Drugs and alcohol 

The Group is committed to ensuring that its employees, and where relevant, its Business and Trading Partners, are provided with a safe working environment. The consumption of alcohol (unless specifically approved by a Senior Manager and then only in moderation) or the use of controlled drugs on Group premises is incompatible with a safe working environment and with the proper performance of duties and as such, is prohibited.  Employees must take care not to bring the Group into disrepute when on third party premises and will be subject to disciplinary action if they do.

 

G:  People and HR procedures

 

Disciplinary procedure

A breach of this Code may result in disciplinary action up to and including summary dismissal, and, where the conduct involves a criminal offence, may also be reported to the relevant authorities. In serious cases, conduct in breach of this Code will be treated as gross misconduct. The Group will deal with suspected breaches under the applicable local disciplinary procedure, which in each case will provide for: a fair and timely investigation; the right of the employee to be informed of the allegations and to respond before any decision is taken; the right to be accompanied at any formal hearing in accordance with local law and Group policy; proportionate sanctions; and a right of appeal. Where local law sets a higher standard of procedural fairness than this Code, the higher standard applies.

 

HR policies

This Code sits alongside, and does not replace, the suite of Group and local HR policies that govern day-to-day employment matters — including the Diversity, Equity and Inclusion Policy, the Anti-harassment and Bullying Policy, the Grievance Policy, the Disciplinary Policy, the Whistleblowing/Speak Up Policy, the Health and Safety Policy,[KK1]  and any local employee handbook. Where this Code and a specific HR policy address the same subject, both apply; if there is a conflict, the stricter standard applies. Relevant Employees should familiarise themselves with the HR policies that apply to their role and location, and may obtain copies from their local HR contact or the Group intranet. 

 

H:  Data protection 

 

Third parties 

During the course of Megger’s activities it will collect, store and process personal data about current, past and prospective suppliers, customers and others that it communicates with. Megger recognises that the correct and lawful treatment of this data will help maintain confidence and contribute to successful business operations. 

All data users must comply with the Megger Group privacy standard and each group company shall provide this to all workers, employers and contractors with the guidelines/notice explaining the scope and extent of Megger’s and the individual’s obligations. 

Each Megger company must take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. 

Procedures and technologies must be put in place to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a data processor if it agrees to comply with those procedures and policies, or if it puts in place adequate measures itself.  Each Megger company must maintain data security by protecting the confidentiality, integrity and availability of personal data, defined as follows: 

  • Confidentiality: means that only people who are authorised to use the data can access it;
  • Integrity: means that personal data should be accurate and suitable for the purpose for which it is processed; and
  • Availability: means that authorised users should be able to access the data if they need it for authorised purposes. 

Details of the Group’s GDPR policy can be found on Megger Connect or consult the Group Company Secretarial department, which manages data protection policy and training. 

 

Employees 

The Group needs to retain information about an employee for purposes connected with their employment and for as long a period as is necessary.  The Group may also hold information about an employee's health for the purposes of compliance with health, safety and occupational health obligations. 

These uses are consistent with our employment relationship and with the principles of global data protection legislation.     

The Group will therefore: 

  • Comply with legislation impacting protection of personal data and ensure all employees are aware of their responsibilities in that regard.
  • Allow all employees to access their personal data on request, subject to any local legislation.  The Group will, however, determine reasonable limits when, where and under what supervision access will be granted.
  • Release personal data to third parties only if:
    • required to do so by law or court order; or
    • with the written consent of the employee; or
    • required for a valid business reason and permitted by law. 

 

I:  Information Management 

Employees who use the internet, email or any IT services provided by Megger Group must do so in a responsible manner, and not put the Group’s reputation at risk. Individuals should bear in mind that any transfer of information via these channels can easily fall into the wrong hands. Failure to comply with the Group’s IT policies may result in disciplinary action being taken and be regarded, in serious cases, as gross misconduct. 

 

Confidentiality 

The Group’s business depends on the proper protection of confidential information. Confidential information may include, for example:

  • financial, commercial and strategic information;
  • corporate records, plans and transactions;
  • technical, product, research and development information;
  • Business Partner and Trading Partner information;
  • personal data and employee information; and
  • any other information which is not publicly available and which a reasonable person would understand to be confidential. 

Relevant Employees must not use or disclose confidential information except where authorised, required by law, or necessary for the proper performance of their duties; and must take appropriate care to protect confidential information belonging to the Group, its employees, Business Partners and Trading Partners.

The classification, storage, handling and disclosure of Group information are governed by the Group’s Document Classification Policy and the “Document classification and information handling” provisions in this Code. Employees must follow those requirements when creating, accessing, sharing, storing, transmitting or disposing of Group information.

Confidentiality obligations apply during employment and continue after employment ends, unless and until the relevant information lawfully enters the public domain. Employees must also respect any confidentiality obligations owed to previous employers or third parties and must not improperly use or disclose confidential information obtained from any previous employment or engagement.

 

Data Security and Cyber Security

Data Security is an identified key risk for Megger Group.  Every employee is required to act with diligence and integrity and observe the Group's data policies.  This includes periodic training, under the leadership of the Group's Chief Compliance Officer.

Any actual or suspected loss, theft, unauthorised disclosure or compromise of Group information must be reported immediately to the Group's Chief Compliance Officer. Where the information includes personal data, the matter must also be reported to the Data Protection Officer (DPO) without delay so that the Group can meet its breach-notification obligations under applicable data-protection law. The DPO will take the matter forward in compliance with the Group Data Protection Policy. 

Group employees and other staff members must not:

  • delete, destroy or modify existing systems, programs, information or data (except as authorised in the proper performance of their duties);
  • download or install software from external sources without authorisation from their local IT department]. Downloading unauthorised software may interfere with our systems and may introduce viruses or other malware.  All software must have an appropriate licence for use.
  • attach any device or equipment including mobile phones, tablet computers or USB storage devices to our systems without authorisation from the Group Information Systems director.

The Group monitors all emails passing through our system for viruses. Group employees should exercise particular caution when opening unsolicited emails from unknown sources. If an email looks suspicious, do not reply to it, open any attachments or click any links in it.

Megger recognises cyber security as a critical business responsibility and is committed to maintaining appropriate technical, organisational, and governance controls to protect its systems, information, customers, employees, suppliers, and business operations.

 

Document classification and information handling

The Group maintains a Document Classification Policy that applies to all information created, received, stored or transmitted by the Group, in any format. Every employee is responsible for classifying the information they handle and applying the controls set out in that policy.

Regardless of tier, employees must observe the following minimum rules:

  • Group information may only be stored in IT systems, file shares and cloud services that have been approved by the Group's IT function. Storage on personal devices, personal email accounts, personal cloud-storage accounts or unapproved file-sharing services is prohibited.
  • Confidential and Strictly Confidential information must not be entered into, uploaded to, or processed by, any external or public artificial-intelligence, machine-learning or other online service that has not been approved by the Group's IT function for that purpose.
  • Confidential and Strictly Confidential information may only be disclosed to a third party where there is a clear business need, the recipient is bound by a written confidentiality agreement (or an equivalent professional duty of confidence), and the disclosure is made using a transfer method approved under the Classification Policy.
  • When access to Confidential or Strictly Confidential information is no longer required, the information must be returned, destroyed or securely deleted in accordance with the Classification Policy and the Group's Data Retention and Disposal Policy.

Failure to observe the Classification Policy may result in disciplinary action and, in serious cases, may be regarded as gross misconduct. 

 

Email 

All Group email systems and communications made on those systems remain the sole property of the Group and consequently should generally only be used for business related purposes. The Group reserves the right to inspect these systems at any time, subject to compliance with local laws. 

Employees must not send, forward, distribute or retain email messages that contain language that is abusive, aggressive or offensive.  Occasional personal use of the Group’s email systems is permitted. However, messages stored in these systems will be treated in the same manner as business-related messages. 

Employees must hold due regard for the Intellectual Property of the Group in all communications and holding proprietary company data for personal use is prohibited.

Confidential or Strictly Confidential information (as classified under the Group's Document Classification Policy) must not be sent to personal email accounts, auto-forwarded to external addresses, or transmitted via consumer file-sharing or messaging services. Where external transmission is necessary, the method must comply with the Classification Policy. 

 

Internet 

Internet access is provided primarily for business purposes.

We permit the incidental use of our systems to send personal email, browse the internet and make personal telephone calls, subject to certain conditions. Personal use is a privilege and not a right. It must not be overused or abused. We may withdraw permission for it at any time or restrict access at our discretion.

Personal use must meet the following conditions:

  • it must be minimal and take place substantially outside of normal working hours;
  • personal emails should be labelled "personal" in the subject header;
  • it must not affect your work or interfere with the business;
  • it must not commit us to any marginal costs; and
  • it must comply with our policies, including this policy, the Diversity, Equity and Inclusion (DEI) Policy, Anti-harassment and Bullying Policy and Data Protection Policy.

Responsible use of the internet is to be encouraged by all Group employees and includes the following guidelines: 

  • When accessing the internet from Group equipment, employees must ensure that they do not use the service in any way which may bring the Group or individuals into disrepute.
  • Employees should remember that although one person does not find material offensive, another might.
  • Publication of information about the Group or its employees will require approval from a Senior Manager, which will extend to the use of social networking tools. Potential publishers must comply with the Code in all communications and take care not to compromise the Group. 

The downloading of pornography or other offensive material is strictly prohibited. 

We may block or restrict access to some websites at our discretion.

 

Monitoring

Our systems enable us to monitor telephone, email, voicemail, internet and other communications. For business reasons, and in order to carry out legal obligations in our role as an employer, your use of our systems, including the telephone and computer systems (including any personal use), may be continually monitored by automated software or otherwise.

The Group may retrieve the contents of email messages or to check internet usage (including pages visited and searches made) as reasonably necessary in the interests of the business, including for the following purposes (this list is not exhaustive):

  • to monitor whether use of the email system or the internet is legitimate and in accordance with this policy;
  • to find lost messages or to retrieve messages lost due to computer failure;
  • to assist in the investigation of alleged wrongdoing; and
  • to comply with any legal obligation.

 

Personal use of social media

Occasional personal use of social media during working hours is permitted so long as it does not involve unprofessional or inappropriate content, does not interfere with employment responsibilities or productivity, and complies with this policy.

Relevant Employees and Business Partners must:

  • avoid making any social media communications that could damage the Group’s business interests or reputation, even indirectly
  • not use social media to:
    • defame or disparage us, our staff or any third party;
    • harass, bully or unlawfully discriminate against staff or third parties;
    • make false or misleading statements; or
    • impersonate colleagues or third parties.
  • not express opinions on behalf of the Group via social media, unless expressly authorised to do so by a Group senior manager. Megger staff may be required to undergo training in order to obtain that authorisation
  • not comment on social media about sensitive business-related topics, such as the Group’s performance, or do anything to jeopardise the Group’s trade secrets, confidential information and intellectual property. The Group’s logos and other trade marks must not be used in any social media posting or in any social media profiles of Relevant Employees or Business Partners.

The contact details of business contacts made during the course of the Group’s employees’ employment are confidential information of the Group. On termination of employment, Group employees must provide us with a copy of all that information, delete all that information from their personal social networking accounts and destroy any further copies of that information that they may have.

Social media content that disparages or reflects poorly on the Group should be recorded in accordance with the Whistleblowing/Speak Up Policy.

 

Responsible use of AI

Artificial intelligence and generative AI tools can support our work, but they also create risks for confidentiality, accuracy, intellectual property and the people who rely on the Group's outputs.  Relevant Employees and Business Partners must use AI tools responsibly and only where doing so is consistent with the Code, with this section and with any AI use guidance issued by the Group from time to time.

 

Approved tools and data

Only AI tools that have been approved by the Group may be used for Group business. Confidential, Restricted or personal data must not be entered into any AI tool that has not been approved for that classification of data.  Customer data, supplier data, financial information, employee data, source code, designs and any other Group intellectual property must be treated as Confidential by default for these purposes, unless the Group has confirmed otherwise.

 

Accuracy, oversight and accountability

AI tools can produce outputs that are inaccurate, incomplete, biased or fabricated, even when the output appears authoritative.  Relevant Employees remain responsible for the accuracy of any work product they create, sign, send or rely on, regardless of whether AI was used to produce it.  AI outputs must be reviewed by a competent person before being used in a decision that affects customers, suppliers, employees, regulators or the public, and must never be relied upon as the sole basis for a decision that has legal, financial, safety or significant commercial consequences.

 

Intellectual property and third-party rights

AI tools may generate content that infringes third-party copyright, trade marks or other rights, or that reproduces another party's confidential information.  AI-generated content must not be passed off as wholly original where doing so would be misleading, and any use of AI in customer- or regulator-facing deliverables must comply with applicable disclosure obligations and any contractual restrictions on AI use.

 

J:  Speak Up 

Megger is committed to maintaining the highest standards of integrity and ethical conduct.  Our Whistleblowing/Speak Up Policy provides a safe, confidential mechanism for Relevant Employees and Business Partners to report concerns about suspected wrongdoing that affects the Group, its stakeholders or the public interest. 

Group employees and Business Partners are encouraged to report concerns about wrongdoing (including non-compliance with this Code) in accordance with the channels set out in the Whistleblowing/Speak Up Policy.

Megger will not tolerate retaliation of any kind against any person who, in good faith, raises a concern, seeks guidance, reports actual or suspected wrongdoing, or participates or assists in an investigation. Retaliation includes dismissal, demotion, disciplinary action, threats, harassment, exclusion or any other detrimental treatment connected with such a report or participation. This protection applies even where the concern later proves to be mistaken, provided it was raised honestly. Anyone who believes they have been subjected to retaliation should report it immediately to the Chief Compliance Officer or through the Whistleblowing/Speak Up Policy channels; acts of retaliation are themselves a breach of this Code and a disciplinary matter. 

All reports will be handled discreetly.  Megger encourages individuals to raise concerns in good faith and is committed to ensuring that no person suffers retaliation for speaking up, seeking guidance, reporting concerns, or participating in an investigation. Anyone raising a concern in good faith is protected from threats, bullying, intimidation or any other form of retaliation.  Retaliation against a person who has raised a Speak Up concern is itself a disciplinary offence and may also be a Speak Up matter in its own right. 

Our Whistleblowing/Speak Up Policy provides a defined process for investigation of reported matters. The Group is committed to investigating in a fair, objective and independent manner.

 

K:  Consultation 

The Code contains a number of policies, rules and procedures, which support and promote the principles of transparency, honesty and openness which define the Group. Every employee and Business Partner is obliged to consult if they have any doubt about actions taken that might breach this Code. 

 

If you are unsure 

The Group’s success is determined by the behaviour of its employees and Business Partners, but there may be occasions when individuals are unsure of what is right. The following questions should act as a starting point: 

  • Does this fit with the Group’s Code of Conduct ?
  • Is this approach legal in the country I am dealing in ?
  • Is this approach safe for my colleagues and me ?
  • Does this fit with my personal values and instincts ?
  • What would our stakeholders think if this matter was to appear in the media ?
  • Have I consulted a Senior Manager ? 

 

Contact information 

If you become aware of breaches of the Code, Megger Group has arrangements in place for all employees to raise, in confidence, any concerns they may have. 

The Board of Megger Group has nominated Jeremy Simpson as Chief Compliance Officer, who can be reached at: 

Email: [email protected] 

Any employee who fails to report or provide further information about any improprieties will be in breach of the Code and may be subject to disciplinary action.