Code of Conduct
1. Why this exists
PioneerUnion works in places where essential systems are weak, regulation is developing, and the consequences of getting it wrong fall on people who have few alternatives. That raises the standard we have to hold ourselves to, not lowers it.
This Code sets out how we behave. It is written to be usable — short enough to read, specific enough to apply.
2. Who it applies to
Everyone who works for or on behalf of the PioneerUnion Group: directors, employees, contractors, agents, and consultants, in every country chapter and every group entity.
We also expect it of our suppliers, joint venture partners and subcontractors. Where a partner’s own standards fall below this Code on the matters covered in sections 4 to 8, ours applies.
3. Our values, and what they mean in practice
- Equity — access is a right, not a privilege. We do not price, staff or design in ways that quietly exclude the people we say we serve.
- Integrity — we do what we say. If we cannot do it, we say so before we are asked.
- Transparency — we are honest about progress and setbacks. Bad news travels up, quickly.
- Compassion — people before metrics. A target met by cutting corners on someone’s safety or dignity has not been met.
4. Honesty in what we say
This section exists because our work involves proposals to governments, materials for investors, and public reporting on impact.
- We do not overstate capability, capacity, track record, certification or progress.
- Figures are labelled for what they are: contracted, audited, estimated, projected, or target. An estimate presented as a fact is a false statement, however good the intention.
- We do not claim certifications, ratings or endorsements we do not hold.
- We do not imply a relationship — with a government, an investor, or a partner — that does not exist.
- When we get something wrong publicly, we correct it publicly and say that we did.
5. Bribery, corruption and improper payments
We do not offer, give, request or accept a bribe. There are no exceptions, no local-custom exemptions, and no thresholds below which it becomes acceptable.
- Facilitation payments — small payments to speed up a routine approval — are bribes. We do not make them. If a payment is demanded to obtain something we are entitled to, refuse, and report it.
- Gifts and hospitality must be modest, infrequent, transparent, and never offered or accepted around a decision point — a tender, a permit, an inspection, an award. If it could not be described openly to the other party’s employer, it is not acceptable. Anything of more than token value must be recorded and approved in advance.
- Public officials carry a higher bar than commercial counterparties. When in doubt with an official, the answer is no.
- Intermediaries — agents, facilitators, consultants — cannot be used to do what we could not do directly. We check who we engage and what they are being paid for.
6. Conflicts of interest
Declare anything that could reasonably look like a conflict — a family or personal relationship with a counterparty, an outside interest in a supplier or competitor, a second role, a personal benefit from a decision you influence.
Declaring a conflict is not an admission of wrongdoing. Failing to declare one is.
7. Fair dealing
We compete on the merits of what we build. We do not fix prices, rig tenders, or divide markets. We do not misrepresent competitors. We do not obtain confidential information about them improperly.
We comply with applicable sanctions and export controls, and we check counterparties before we engage them.
8. People
- Safety comes before schedule and before cost. Anyone may stop work they reasonably believe is unsafe, and no one will be penalised for doing so.
- No child labour and no forced labour, in our operations or our direct supply chain.
- We do not retain passports or identity documents. Workers hold their own documents.
- Wages are paid in full and on time, in the amounts agreed, with deductions explained.
- No harassment, bullying or discrimination on grounds of race, nationality, religion, sex, disability, age, or any other characteristic irrelevant to the work.
- Instructions and safety information are provided in a language the worker actually reads. A rule someone cannot read is not a rule, it is a liability transferred to the person least able to carry it.
- Freedom to raise concerns without going through the person the concern is about.
9. Environment and community
We work to reduce environmental harm from what we build and operate, and we comply with environmental permits and conditions in full.
Where a project affects an inhabited island or community, we engage with it before work begins, not after. We do not treat community consultation as a formality to be completed.
10. Information, data and confidentiality
We protect personal data of clients, employees and community members, collect only what we need, and never collect the categories our privacy notices say we do not collect.
We protect confidential information belonging to counterparties, and we honour confidentiality obligations after a relationship ends.
11. Records and company assets
Records are accurate and complete. We do not create false or misleading records, backdate documents, or keep transactions off the books. Company assets and funds are used for company purposes.
12. Political activity and donations
The Group does not make political donations, in cash or in kind, in any country. Individuals’ private political activity is their own, conducted in their own time and never on behalf of, or identified with, PioneerUnion.
13. Raising a concern
If something here is being breached, or you think it might be, report it. See our Whistleblowing Policy for the channels and for the protection you have when you use them.
We do not retaliate against anyone who raises a concern in good faith. Retaliation is itself a breach of this Code and is treated as seriously as the original matter.
14. When the Code is breached
Breaches are investigated and acted on. Depending on severity that can mean training, a warning, dismissal, termination of a supplier relationship, or referral to the authorities.
“I was told to” is not a defence. Neither is “it is how things are done here.”
15. Ownership and review
This Code is owned by the group board and reviewed at least annually.
Questions about it: info@pioneerunion.com