Our strong ethical culture and world-class business practices.
NGC Aims At High Ethical Standards In All Business Transactions
NGC prides itself on possessing a strong ethical culture whilst continuously striving towards alignment with world-class business practices and international governance standards. NGC strives to meet these high ethical standards through:
- strong, ethical leadership from the top;
- strong, knowledgeable and independent internal audit and compliance/governance staff;
- tendering rules and procedures that align to international standards;
- effective monitoring, detection and prevention systems;
- written policies and guidelines on acceptable business practices;
- employee training and awareness initiatives;
- enforcement of rules and policies and sanctions for non-compliance;
- generation of accurate and timely financial records;
- transparency in its award of contracts; and
- availability of its annual financial statements.
NGC has actively embedded requirements for professional and ethical behaviours in its policies, value system, guiding principles and business practices. Some of these doctrines date as far back as the early 1980s and remain an integral part of the Company’s future initiatives. There are clear written policies, guidelines and generally accepted company standards addressing a number of ethical issues including Transparency and Fair Trading in Procurement, Political Contributions, Gifts, Conflicts of Interest and Substance Abuse which are binding on all employees of the company, Directors and where applicable, third party service providers.
Transparency and Fair Trading in Procurement
NGC has developed a detailed set of Tenders Rules to govern its procurement of goods, works and services. These rules, which compare favourably with international standards, aims at ensuring transparency in the procurement process and fair treatment of all persons and entities seeking to supply NGC with goods and services. The Company has an established and operating Tenders Committee, comprising Directors of the Board, which has the overarching obligation to review and oversee the proper implementation of these rules within the Company. NGC has also established Management based committees, and a clear Delegation of Authority Manual, which supports the procedures and activities outlined in the Tenders Rules, at the Management level.
NGC’s Tenders Rules addresses enquires into any improper or untoward approach made to any tenderer, or any solicitation of any inducement or payment of money or other thing in kind or in action from any tenderer by any person in respect of any offer. The Rules also demands the cessation of business with potential contractors where such persons offer inducements to NGC’s Directors or officers/employees for the purpose of gaining any advantage or concession for himself or any other person.
Some of the other procurement activities that NGC enforces to ensure fair treatment and transparency include competitive bidding, sealed bids opened in the presence of all bidders and uniformity, consistency and transparency in all communications with tenderers on any substantive aspects of their bids subsequent to their submission.
NGC also is committed to ensuring that its Tender Rules reflect not only best practice, but also the requirements of the laws from time to time in force in Trinidad and Tobago. To that end the Company is currently considering amendments to its existing Rules to ensure the alignment of same with the proposed draft 2015 legislation governing the procurement and disposal of goods and services, which is proposed to come into force in 2019.
Conflict of Interest
This is deemed to exist whenever an employee is in a position, due to the nature or responsibilities of his job, to further any personal financial interest of the employee or a relative of the employee. This includes where an employee invests, or holds a financial interest in, or a position with, any supplier, contractor or other service provider, customer or competitor of the Company or where, as a result of his connection to third parties, he is impaired in his loyalty, judgement, objectivity or independence in relation to them. NGC’s policy requires employees, who believe that their interests could potentially conflict with that of the Company, to immediately declare such interest and remove himself or herself from direct or indirect involvement in the matter to neutralise any potential adverse effects of the conflict being reported.
All employees and Directors are required to make a declaration of all such interests on an annual basis to the Company to permit NGC to effectively monitor and manage potential conflicts.
Financial Reporting and Accountability
NGC’s policies recognise that the Company’s books, records and accounts shall accurately and fairly represent the transactions conducted by the Company during any reporting period.
NGC has published its audited annual accounts each year since 1992 and these accounts consistently meet the required international accounting standards. Once finalised, NGC distributes its audited financials to its shareholder and other stakeholders providing them with accurate and timely information regarding the financial performance of the Company. Copies of the Company’s latest Annual Reports are also available on its website for general viewing.
NGC debars employees from accepting gifts,fees, personal favours or preferential treatment, that could, in any way, influence or appear to influence, business decisions in favour of any person or organization with whom or with which the Company is likely to have business dealings. Commercial business entertainment, which is reasonable in nature, frequency and cost, is however permitted. Reasonable business entertainment would cover, for example, a lunch or dinner or occasional athletic or cultural event and gifts of nominal value not exceeding TT$700.00, or a total annual value of TT$700.00 if received directly or indirectly from one source.
Given its position as a State Enterprise, NGC is particularly rigorous with regard to political contributions. Its practiced guideline allows employees to contribute personal time and money to the political party of their choice, but it is the Company’s principle not to make any political contributions, directly or indirectly, in support of any party or candidate in any government election. For this purpose, the purchase of tickets for dinners, advertising in political programme booklets, use of the Company’s duplication facilities, compensated employee activity, employee contributions reimbursed through expense accounts and similar donations in kind are considered political contributions.
NGC recognises that the inappropriate use and abuse of psychoactive drugs (e.g. alcohol, marijuana and other drugs) seriously impair an employee’s performance, create unacceptable liability and risks, and undermine the confidence of our stakeholders. It therefore adopts a zero-tolerance policy for illegal use, possession or distribution of prohibited substances, and actively seeks to maintain a workplace free from substance abuse. It does so by prevention, education, counseling, detection and testing, rehabilitation, and corrective/disciplinary actions.