SME4Labour Code of Conduct

This Code of Conduct outlines the standards by which SME4Labour carries out consultant lobbying activities on behalf of clients. All directors, employees, and consultants involved in lobbying activities are bound by this code.

Company Values

Professional Excellence
We strive to maintain the highest standards of professional endeavour, integrity, confidentiality, financial propriety, and personal conduct in all our activities.
Honesty and Fairness
We are committed to conducting business with honesty and fairness, ensuring transparency and trust in our relationships with employers, employees, clients, fellow professionals, and the public.
Legal and Ethical Compliance
We respect and adhere to legal and regulatory frameworks, as well as ethical codes, in every country where we operate, ensuring that our business practices are responsible and compliant.

Principles

No Intentional Misleading
Employees must not intentionally mislead in any way.
Accuracy of Information
Only information that is accurate and true should be provided. Employees must make reasonable efforts to verify all statements and be transparent about any uncertainties. No information should be deliberately omitted or obscured if doing so would create a misleading impression during lobbying activities.
No Bribes or Inducements
Employees must not offer bribes or inducements, including gifts or excessive entertainment, regardless of intent.
Managing Conflicts of Interest
Employees must manage and avoid conflicts of interest. They are prohibited from representing two clients with competing interests. If a conflict arises—particularly involving personal political interests—the employee must cease relevant lobbying until the conflict is resolved. This includes holding elected office or engaging in voluntary political roles.
Confidentiality
Employees must respect confidentiality, including clients’ commercial information. Privileged information—especially involving politicians or civil servants known socially—must not be misused for commercial gain.
Respecting Rules and Regulations
Employees must adhere to the rules, regulations, and codes of conduct that apply in the institutions where they work, as well as to the professional codes of others.
Transparency in Lobbying Activity
Employees must respect the public’s right to know about lobbying activities. This includes being willing to identify themselves publicly, disclose on whose behalf they are lobbying, and disclose the interests of their clients.
Hiring or Contracting Public Officeholders
Employees must observe all rules, codes of conduct, and statutes concerning the hiring or contracting of elected representatives, public officials, and civil servants—including rules governing post-office employment periods.
No Misuse of Access Privileges
Employees who hold passes or have access to government institutions must not misuse these privileges for lobbying. Passes granted for other purposes must not be used for lobbying activities.

Complaints Procedure

If an employee, client, or individual being lobbied believes there has been a breach of this Code of Conduct, they may submit a formal written complaint to the Director, Ibrahim Dogus, within six months of the incident.

External Oversight

To ensure impartiality and transparency, SME4Labour will appoint an independent external arbitrator to oversee the complaints process. The arbitrator will be a qualified lawyer with expertise in corporate governance and dispute resolution, selected through a formal process involving nominations from the Executive Board and approval by majority vote.

The arbitrator will review complaints, conduct any necessary investigations, and issue binding decisions to ensure fairness and objectivity. A decision or resolution will be provided within one year of the complaint’s submission.

Sanctions

SME4Labour may take disciplinary action against any employee who intentionally or repeatedly fails to comply with this Code of Conduct. Disciplinary measures may vary depending on the severity of the violation and may include:

Demotion
Termination (in the case of serious offences)
Suspension of benefits for a specified period