Last Updated
  • August 27, 2025

Downloads

Conduct, Business Ethics & Whistleblowing Policy

Sheehan Nagle Hartray Associates (SNHA) are committed to providing a safe, healthy, and productive working environment for all employees, contractors, customers and visitors involved in its operation. This policy sets out our aims in protection and safety in the workplace.

Conduct & Business Ethics

You are requested to comply with all Firm’s rules and operating policies and procedures and to maintain satisfactory standards of performance at work. This includes a high level of quality, accuracy and diligence.

We do not tolerate bribery of any kind and are actively committed to the prevention of bribery. A bribe includes any payment, benefit or gift offered or given with the purpose of influencing a decision or outcome. Bribery and the failure to prevent bribery are criminal offences and you must not offer, accept, receive or induce a bribe for any purpose. If you are aware or suspect that bribery is taking or has taken place then you have a duty to report this to your manager or an appropriate person. If you are found to have committed an act of bribery this will be considered as gross misconduct.

You are also required to use your best endeavours to promote the interests of the business and take all necessary steps required to safeguard our public image and preserve positive relationships with our clients and members of the public. Employees must treat our clients and members of the public with respect and conduct themselves responsibly at all times.

At times of special occasions such as Christmas, small gifts of nominal value may be accepted by prior agreement with your manager.

Whistleblowing

Legislation protects individuals who report allegations that are in the public interest and that relate to wrongdoing, such as issues of safety or money laundering. If you have concerns about any suspected wrongdoing at work, a breach of ethics or a failure to comply with our legal obligations, whether this be on the part of a colleague, manager, contractor or any other person associated with Sheehan Nagle Hartray Associates you should bring your concerns to the attention of any of the Directors. Some circumstances (such as the behaviour of your manager) will require you to raise the matter directly with another manager or senior person.