Business Ethics Policy

Bullitt Group is committed to ethical business practices, and it requires everyone who works for or with the company to share the responsibility for understanding and complying with the principles of ethical behaviour and carrying out business with integrity. 

The objective of the Business Ethics Policy is to ensure that staff, partners and suppliers: 

  • comply with local regulatory requirements in all territories where we operate;
  • do not promise, offer, authorise, give or accept bribes or any other means of obtaining undue or improper advantage, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage;
  • do not offer or accept the receipt of gifts or hospitality that could influence or be perceived as capable of influencing the outcome of transactions or decisions relating to our business;
  • conduct and record business dealings transparently and accurately to prevent fraud and ensure the correct and proper payment of taxes;
  • take appropriate steps to prevent the laundering of money and the funding of terrorist or criminal activities;
  • will not enter into commercial agreements or engage in any other practice which may affect trade within a given market and have as their object or effect the prevention, restriction or distortion of competition within that market where such behaviour is prohibited by law. Furthermore, should Bullitt Group be in a dominant market position, it shall not engage in any behaviour which abuses that status within a given market where such abuse is prohibited by law;
  • do not engage in transactions on behalf of Bullitt Group with third party organisations or individuals with which they have an interest that conflicts, or could conflict, with the interests of Bullitt Group;
  • respect the privacy and/or personal information of everyone that Bullitt Group does business with or uses our products, including suppliers, customers, consumers, and employees;
  • do not lobby political parties or governments for business gain;
  • ensure that the transfer of technology and know-how is done in a manner that protects intellectual property rights wherever applicable;
  • comply with all and local export and import legislation;
  • do not disclose commercial information regarding suppliers, customers or partners where contractual or other legal duties restrict such disclosure; and
  • strive to meet the aspirations of the United Nations Global Compact.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. Where we discover a breach of this policy in our supply chain, we would consider this a breach of contract which could result in termination of that contract and a claim for damages arising.

Supplier Code of Conduct

We include our supply chain in taking responsibility and improving the way we do business.

Our Supplier Code of Conduct sets out the standards of behaviour for our Suppliers to comply with at all times. We promote improvements and monitor the performance in the context of labour and human rights, health and safety, environment, business ethics and information security.

Download the Supplier Code of Conduct

Whistleblower program

We are committed to an open and honest climate for business, and we take any breaches of our policies and the Supplier Code of Conduct seriously.

We encourage all our employees, suppliers, customers and other people with whom we have dealings to report concerns where they genuinely and in good faith believe that illegal, unethical, or improper conduct involving Bullitt or our supply chain is occurring, has occurred or may occur.

A report can be made anonymously. Anyone making a report is encouraged to provide their contact details, so they can be contacted for further information, but their details will not be passed on to the investigation team unless they give their permission to do so. We will take all reasonable steps to protect the anonymity of anyone making a report. However, action taken as a result of any disclosure may lead to their identity needing to be revealed.

Our Ethics Committee will review such reports and arrange the investigations, including the appropriate follow up and rectification actions.