Ethical Policy.

Our standards of business practice

1.1 We are committed to high ethical standards in our business dealings to ensure the integrity of our employees and our organisation is maintained.

Bribery and corruption

1.2 True North Talent Limited is resolutely opposed to bribery and corruption in whatever form it may take. Our anti-corruption and bribery policy sets out our procedure and expectations in this respect.

Political contributions

1.3 TRUE NORTH TALENT LIMITED does not make contributions to political parties.

Treatment of customers

1.4 Mutual trust and confidence between True North Talent Limited and our customers is vital. All employees should strive to consistently deliver service excellence and value for money, meeting customers’ expectations and anticipating their changing requirements.

1.5 All suppliers are entitled to fair treatment and all potential suppliers should have a reasonable opportunity to win True North Talent Limited business. It is our policy to pay suppliers on time in accordance with agreed terms of trade.

Competition

1.6 True North Talent Limited will always compete vigorously, but in a fair and ethical way. Competitive success is built on providing good value and service excellence. When in contact with competitors, employees will avoid discussing confidential information and no attempt will be made to improperly acquire competitors’ trade secrets or any other confidential information. Employees must not discuss pricing strategies or undertake any arrangements or practices which would conflict with the laws applicable to the business concerned.

Our approach to corporate governance

2.1 True North Talent Limited is committed to protecting the interests of our shareholders and our organisation through compliance with the relevant legal and regulatory frameworks and careful management of business risks.

Compliance with the law

2.2 TRUE NORTH TALENT LIMITED will comply fully with all relevant national and international laws and will act in accordance with local guidelines and regulations, including those which are industry specific, governing our operations.

2.3 It is the responsibility of all managers to ensure, by taking legal or other expert advice where appropriate, that they are aware of all local laws and regulations which may affect the area of the business in which they are engaged, including tax and exchange controls.

External reporting

2.4 True North Talent Limited businesses may be required to make statements or provide reports to regulatory bodies, government agencies or other government departments. Care should be taken to ensure that such statements or reports are correct, timely and not misleading. Senior management must be made aware of any sensitive disclosure before it is made.

2.5 Care must also be taken when making statements to the media that information given is correct and not misleading. Enquiries from the media should be referred to company media relations experts and statements should only be made by designated spokespersons.

Policies and procedures

2.6 TRUE NORTH TALENT LIMITED recognises that there are risks associated with carrying out any business activity. Management is responsible both for ensuring that policies and procedures are in place to manage risks and for complying with those policies and procedures. Employees should ensure that they are aware of the risks associated with their activities and that they comply with policies and procedures in place to manage those risks.

Working Practices

3.1 It is the policy of True North Talent Limited to ensure that all candidate introductions are made on an honest and ethical basis. The CV content of all candidates will remain unaltered with the exception of personal details such as address, date-of-birth etc. which will be removed in line with normal recruitment business practices. Prior to the sending of candidate CV’s there will be a degree of cosmetic formatting that will ensure consistency and ease of assessment by the recipient. All candidates will be pre-screened and must give their prior consent before any introduction is made to any client. No candidate will be submitted, unless this information has not been given to the TRUE NORTH TALENT LIMITED consultant, to a client’s business that they have already approached either directly or through an alternative recruitment business.

Our commitments to our employees

4.1 True North Talent Limited is committed to optimising individual and business performance through employing the best people at all levels and creating an environment in which they want to and are able to contribute fully to the business’s success. To achieve a working environment in which team spirit and commitment to the goals and values of True North Talent Limited are maintained, the Company will ensure that individual employees are treated fairly, with dignity and respect.

Harassment and equal opportunities

4.2 True North Talent Limited takes issues such as harassment and equal opportunities extremely serious and these matters are dealt with by the relevant policies as set out in this Staff Handbook.

Health & safety

4.3 TRUE NORTH TALENT LIMITED places the highest priority on promoting the health and safety of employees whilst at work and encourages annual health checks in line with duties undertaken at the expense of the business.

Terms of employment

4.4 The business and their employees will work towards creating permanent long-term relationships.

Pre-employment screening and selection

4.5 In order to protect the interests of our employees and customers, and because of the nature of our business, True North Talent Limited will apply rigorous pre-employment screening and selection techniques.

Our employees’ commitments to True North Talent Limited

5.1 Employees must avoid situations where there is a potential for business impropriety to arise or be alleged, even where the circumstances might not otherwise specifically violate this Staff Handbook or where specific laws or regulations do not apply.

Confidential information

5.2 Employees must not make use of confidential information obtained through their employment for personal gain, nor disclose such information to any third party during or after their employment. ‘Confidential information’ is either information that has been specifically described as being confidential, such as in your contract of employment, or is otherwise obviously confidential from the surrounding circumstances.

5.3 The term “confidential information” does not include information in the public domain or information which the individual concerned is required by law to disclose.

Conflicts of interest

5.4 Every employee has a duty to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of the Company, or which divides his or her loyalty to the Company. Any activity which even potentially appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not unethical or improper, does not compromise integrity and is not detrimental to the reputation and standing of the company.

Implementation

6.1 This Ethical Policy must be adopted by all employees as a minimum standard.

Staff complaints and suggestions

6.2 Staff can expect that True North Talent Limited will encourage and give due consideration to their constructive suggestions and will provide a considered and objective review of genuine concerns and complaints. Such concerns include fraud, misrepresentation, theft, harassment, discrimination and non-compliance with regulations, legislation, policies and procedures including as set out in this Staff Handbook.

6.3 Concerns must be investigated impartially so that the employee’s rights are protected. Employees who have concerns about potential unethical behaviour should advise their line manager in the first instance. Employees may do this anonymously if they so wish. To ensure that confidentiality is maintained, employees should not discuss such concerns with colleagues or other third parties, unless specifically authorised or unless it is a legal requirement.

Compliance monitoring

6.4 We monitor, on a regular basis, compliance with this ethics policy and ongoing management reporting.

Adherence to policy

6.5 Since True North Talent Limited aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with the business’ principles and policies are not tolerated. Strict adherence to these principles and supporting policies is a condition of employment in the business. Any action by an employee, which deliberately or recklessly breaches this Ethical Policy, may result in disciplinary action under the Disciplinary and Capability Procedure and where appropriate, criminal proceedings may be instituted.

Approved by:
Emma Symonds & Amy Griffith
Directors, True North Talent

Date: 01.09.2026

Next Review: 01.09.2027