Code of Conduct
1 Foreword from the Managing Director
At Open eLMS, we are driven by more than profit; we aim to make a genuine difference. Our core values of honesty, fairness, and inclusion are central to the services we provide and how we treat our clients and employees.
Open eLMS leads by example—we do the right thing because it is the right thing to do. This is reflected in our commitment to immediate supplier payments, net carbon reduction, and profit sharing with our team.
I encourage you to read through this Code of Conduct and consider how it applies to your role. Are you honest in your dealings with others? Are you fair to your clients and colleagues? And are your decisions free from bias—unconscious or otherwise?
Thank you for your commitment to these standards.
Emil Reisser-Weston (Managing Director)
2 Objective
This policy outlines the standards of conduct expected at Open eLMS. These rules protect our employees, the company, and our customers. Inappropriate conduct risks compromising our services, our legal standing, and the trust of our learners and partners.
3 Overview
We are committed to protecting Open eLMS users (including employees, contractors, consultants, and temporary workers) and the business from illegal or damaging actions. Responsible business conduct is a company-wide commitment, and every associated person is responsible for understanding and following these policies.
4 Scope
This policy applies to anyone conducting Open eLMS business or interacting with our networks, systems, clients, or suppliers—regardless of whether equipment is company-owned, personal, or provided by a third party.
All employees and affiliates are responsible for exercising good judgement regarding information use, electronic devices, and professional behaviour, ensuring compliance with local laws and company standards.
5 Code of Conduct
5.1 Fair Treatment of Employees
Open eLMS fosters a diverse and inclusive culture built on respect, integrity, and ethical behaviour.
5.1.1 Anti-discrimination and harassment prevention
Employees will be treated fairly and with respect. Equal opportunity is central to our ethos; all employment decisions are based on merit, qualifications, skills, and achievements.
Discrimination based on age, gender, race, ethnicity, sexual orientation, national origin, disability, or religious beliefs will not be tolerated. This applies to all interactions with employees, vendors, customers, and temporary workers.
Harassment is unwelcome or offensive conduct that may interfere with a person's ability to perform their work. For full details, please refer to our Anti-Discrimination Policy.
5.1.2 Safe and healthy work environment
Open eLMS is committed to providing a safe environment for employees, partners, vendors, and visitors. Every employee is responsible for prioritising health and safety by:
- Promptly reporting all unsafe or hazardous conditions to supervisors.
- Complying with all applicable laws, regulations, and standards regarding working conditions.
- Adhering to all workplace safety and industrial hygiene policies.
Accordingly, employees must not:
- Undertake work-related activity while under the influence of alcohol or drugs.
- Continue any work that becomes unsafe or unhealthy.
- Assume that others will report a risk or concern.
5.2 Financial Integrity and Countering Corruption
5.2.1 Financial Integrity & Intellectual Property
Our intellectual property and confidential information are vital assets that must be protected against misuse or theft. To maintain financial integrity, employees and affiliates must adhere to the following policies:
- Password Policy
- Supplier Security Policy
- Data Protection and Information Security
- Information Classification Policy
- Social Media Policy
- Security Incident Management Policy
Internal training is provided to foster continuous improvement in protecting our data and IP.
5.2.2 Corruption and Conflicts of Interest
Conflicts of interest can significantly impact our business. These are categorised as actual, perceived, or potential conflicts. Any such instance must be reported to management immediately.
The following situations warrant reporting a conflict of interest:
- A family member or close personal contact serving as a public official.
- A family member or close personal contact who works for a competitor, customer, or supplier.
- A substantial financial interest in a competitor, supplier, or customer.
- Any interest in a supplier or customer if you or your team are involved in selecting or negotiating with them.
Accordingly, employees must not:
- Divert business opportunities that arise during their role at Open eLMS for personal gain.
- Allow personal, financial, or political activities to affect their professional objectivity.
- Provide services to competitors, customers, or suppliers without prior written approval.
Open eLMS operates a zero-tolerance approach to any instance of corruption or bribery.
5.2.3 Financial Accountability
Open eLMS is committed to accurate financial reporting and meeting all legal requirements. All employees are expected to conduct their duties with care regarding financial matters. Suppliers are typically paid upon receipt of an invoice for completed services, with standard terms of 28 days.
5.3 Information Security
Please refer to the Data Protection & Information Security Policy for full details on information security conduct.
6 Corporate Social Responsibility
Corporate Social Responsibility is a set of actions that make our business more conscientious, impactful, and sustainable for our clients, suppliers, and the wider community.
6.1 Environmental Efforts
As environmental sustainability becomes increasingly critical, Open eLMS strives to minimise its footprint. Operating paperless reduces our environmental impact and enhances security; we encourage employees to remain mindful of paper use and recycle where possible.
We also focus on reducing energy consumption. Please ensure computers, monitors, and lights are switched off when not in use. We prioritise virtual meetings via Zoom or Teams to reduce travel.
As a net carbon reducer, Open eLMS offsets its footprint through a dedicated tree-planting initiative. We commit to offsetting 5,000 kg of carbon every month, which significantly exceeds our recorded business emissions.
6.2 Community Impact
Open eLMS aims to be a positive force within the local community. We are proud to sponsor Shinfield Cricket Club, supporting physical health and mental wellbeing. We welcome suggestions for local sponsorship opportunities.
6.3 Marketing Responsibly
Our marketing is conducted with integrity and transparency. Our efforts must:
- Adhere to all applicable marketing laws.
- Describe products and benefits truthfully.
- Respect modern standards of decency.
- Consider environmental impact (e.g., avoiding disposable corporate giveaways).
7 Remote and Flexible Working
We empower our employees to work in ways that enhance both productivity and wellbeing. Our flexible working culture is built on trust and autonomy.
7.1 Empowering Autonomy
Employees are trusted to manage their schedules responsibly. We encourage open dialogue with team leaders to structure hours in a way that maintains collaboration while respecting personal commitments.
7.2 Outcomes Over Hours
We prioritise results over rigid schedules. Success is measured by the quality and timeliness of outcomes rather than hours spent at a desk.
7.3 Remote Work Expectations
To maintain professionalism, remote workers are expected to:
- Maintain regular communication via Teams, email, or project platforms.
- Be available during agreed core hours.
- Ensure data security and confidentiality at all times.
- Maintain a work environment conducive to focus.
7.4 Technology and Support
We provide the digital tools and support required for effective remote collaboration, including access to learning platforms and cybersecurity resources.
7.5 Work-Life Balance
We respect personal boundaries. Employees are encouraged to disconnect outside working hours to support their mental and physical health.
8 Additional Policies and Standards
Additional Open eLMS policies are available internally to all employees and can be provided to clients upon request.
9 Sanctions
Open eLMS employs technical and administrative methods to monitor compliance with security policies. Violations may lead to disciplinary action, up to and including termination of employment or contracts.
10 Implementation
Technical teams are responsible for implementing the controls required for the secure operation of Open eLMS assets. These controls support our legal compliance, including GDPR, and our duty of care to all stakeholders.
11 Responsibility
Open eLMS
The company employs best practices to ensure the Confidentiality, Integrity, and Availability of all company assets.
Data Controller
The Data Controller is responsible for policy compliance, providing security guidance, and managing the exception process.
Business Management
Managers are responsible for implementing policies within their areas and ensuring staff adherence.
Personnel
All personnel must act in a manner that complies with these policies in both content and spirit, reporting any known violations.
12 Exception Process
Any exception to this policy requires prior written approval from the Data Controller. Questions regarding this policy should be directed to emilrw@openelms.com.
13 Document Approval and Ownership
The Data Controller owns this document and ensures it is reviewed annually. This policy is issued on a version-controlled basis under the authority of Open eLMS senior management.