Last Updated: 01 January 2025
IMAPAC Code of Ethics and Business Conduct
To all directors, managers, employees, contractors, consultants and representatives of IMAPAC and its affiliated companies.
1. Introduction
This Code of Ethics and Business Conduct (the “Code”) sets out the standards of integrity, professionalism and ethical conduct expected of everyone acting for or on behalf of IMAPAC.
The Code cannot provide an answer to every situation that may arise. Everyone is therefore expected to exercise sound judgment, act honestly and responsibly, and seek guidance whenever there is uncertainty about the appropriate course of action.
The purpose of this Code is to help prevent improper conduct, protect IMAPAC and its stakeholders, and promote a professional culture based on integrity, accountability, respect and responsible business practices.
The Code cannot provide an answer to every situation that may arise. Everyone is therefore expected to exercise sound judgment, act honestly and responsibly, and seek guidance whenever there is uncertainty about the appropriate course of action.
The purpose of this Code is to help prevent improper conduct, protect IMAPAC and its stakeholders, and promote a professional culture based on integrity, accountability, respect and responsible business practices.
2. Fairness, Respect and Professional Conduct
Everyone working with IMAPAC must treat colleagues, customers, suppliers, partners and other stakeholders fairly, professionally and respectfully.
IMAPAC encourages an atmosphere of openness, cooperation, consultation and constructive communication.
Employees are expected to act honestly, fairly and professionally toward colleagues, assist one another where appropriate, share relevant professional information responsibly and contribute to a productive and respectful working environment.
Employment and advancement decisions should be based on appropriate factors such as ability, performance, qualifications and business requirements.
IMAPAC does not tolerate unlawful discrimination, harassment, bullying, victimisation or other conduct that undermines the dignity or wellbeing of others.
IMAPAC encourages an atmosphere of openness, cooperation, consultation and constructive communication.
Employees are expected to act honestly, fairly and professionally toward colleagues, assist one another where appropriate, share relevant professional information responsibly and contribute to a productive and respectful working environment.
Employment and advancement decisions should be based on appropriate factors such as ability, performance, qualifications and business requirements.
IMAPAC does not tolerate unlawful discrimination, harassment, bullying, victimisation or other conduct that undermines the dignity or wellbeing of others.
3. Your Relationship with IMAPAC
Conflicts of Interest
Everyone working for IMAPAC is expected to devote their professional efforts to IMAPAC during their contracted working time and avoid situations in which personal, financial or outside business interests conflict, or may reasonably appear to conflict, with the interests of IMAPAC.
A conflict of interest may arise where an individual's personal interests, relationships or external activities make it difficult to perform their responsibilities objectively, impartially or in IMAPAC's best interests.
Potential conflicts must be disclosed promptly.
Examples may include:
A conflict of interest may arise where an individual's personal interests, relationships or external activities make it difficult to perform their responsibilities objectively, impartially or in IMAPAC's best interests.
Potential conflicts must be disclosed promptly.
Examples may include:
- ownership or financial interests in another business;
- directorships or management roles outside IMAPAC;
- additional employment, consultancy or freelance work;
- involvement in a business owned or operated by a spouse, family member or close associate;
- relationships with customers, suppliers, partners or competitors that could influence business decisions;
- receiving a personal benefit connected with an individual's position at IMAPAC; or
- any other outside interest that may interfere with an individual's responsibilities to IMAPAC.
Where required, prior written approval must be obtained.
IMAPAC Business Opportunities
Employees and representatives must not exploit opportunities discovered through their position at IMAPAC, or through the use of IMAPAC information, customer relationships, commercial intelligence or resources, for personal benefit or for the benefit of another individual or organisation without proper authorisation.
Everyone has a responsibility to promote IMAPAC's legitimate business interests while carrying out their duties.
Employees must not, without prior written approval:
Everyone has a responsibility to promote IMAPAC's legitimate business interests while carrying out their duties.
Employees must not, without prior written approval:
- establish, operate, assist or promote a business that competes with IMAPAC;
- work for or provide services to a competing business;
- divert IMAPAC customers, prospects, sponsors, delegates, speakers, suppliers, partners or commercial opportunities;
- use opportunities discovered through IMAPAC for another organisation or for personal benefit; or
- assist another person or organisation to do any of the above.
Confidentiality
Everyone working with IMAPAC must maintain and protect confidential information belonging to IMAPAC, its customers, suppliers, partners and other parties with whom IMAPAC conducts business.
Confidential information is not limited to information specifically marked “Confidential”.
It may include:
Confidential information is not limited to information specifically marked “Confidential”.
It may include:
- customer, sponsor and prospect information;
- contact databases and CRM data;
- speaker and delegate information;
- pricing and commercial proposals;
- event concepts, programmes and strategies;
- sponsorship pipelines and sales opportunities;
- financial information;
- marketing plans and campaign information;
- supplier information;
- internal processes and systems;
- commercial negotiations;
- business development opportunities;
- research and market intelligence; and
- any other information that is not publicly available.
Confidential information must not be used, copied, transferred or disclosed for personal benefit or for the benefit of another individual or organisation without proper authorisation.
Protection of IMAPAC Assets
IMAPAC's assets must be protected and used responsibly for legitimate business purposes.
These include:
These include:
- computers and mobile devices;
- company email and communication systems;
- CRM and databases;
- software and information systems;
- intellectual property;
- customer information;
- financial resources;
- company accounts;
- documents and records; and
- other company property.
Employees must not make unauthorised use of IMAPAC assets for personal purposes or for an outside business.
Deliberate credential sharing, unauthorised system access, disabling or bypassing security controls, unauthorised extraction of company information, or misuse of IMAPAC systems may be treated as serious misconduct.
Deliberate credential sharing, unauthorised system access, disabling or bypassing security controls, unauthorised extraction of company information, or misuse of IMAPAC systems may be treated as serious misconduct.
Fair Dealing
Everyone representing IMAPAC must act with fairness, integrity and good faith toward customers, suppliers, partners and competitors.
Business and competitor information must be obtained only through proper and lawful means.
IMAPAC does not tolerate:
Business and competitor information must be obtained only through proper and lawful means.
IMAPAC does not tolerate:
- fraud or deliberate dishonesty;
- bribery or corruption;
- misleading representations;
- improper business manipulation;
- misuse of confidential information;
- unauthorised diversion of business opportunities;
- improper use of customer or competitor information; or
- other dishonest or unfair commercial practices.
Professionalism
Employees and representatives are expected to perform their responsibilities in accordance with appropriate professional standards and make decisions based on a reasonable factual basis.
Everyone is expected to:
Everyone is expected to:
- maintain the knowledge and competence required for their role;
- take responsibility for their work;
- act professionally toward customers and colleagues;
- maintain appropriate records;
- communicate honestly; and
- strive for high standards of performance and service.
Loyalty to IMAPAC and Its Objectives
Employees are expected to act loyally toward IMAPAC while carrying out their employment responsibilities.
Individuals must not knowingly act in a way that undermines IMAPAC's legitimate commercial interests or improperly benefits themselves, another person or a competing organisation.
Individuals must not knowingly act in a way that undermines IMAPAC's legitimate commercial interests or improperly benefits themselves, another person or a competing organisation.
Additional Occupations and Outside Business Activities
During IMAPAC working hours, employees must devote their working time to their responsibilities for IMAPAC.
Employees must not engage in unrelated activity during working hours, whether paid or unpaid, unless prior written approval has been obtained.
Any outside employment, consultancy, directorship, business ownership or other external activity that may:
Employees must not engage in unrelated activity during working hours, whether paid or unpaid, unless prior written approval has been obtained.
Any outside employment, consultancy, directorship, business ownership or other external activity that may:
- compete with IMAPAC;
- create an actual or potential conflict of interest;
- impair the employee's ability to perform their duties;
- involve IMAPAC customers, sponsors, prospects, suppliers or partners; or
- involve IMAPAC information, systems, resources or commercial relationships must be disclosed and approved in advance.
Personal Example
Managers and leaders are expected to demonstrate the standards set out in this Code through their own behaviour, decisions and communications.
No Misuse of Position or Status
No employee may use their position at IMAPAC to improperly advance their own interests or the interests of a family member, close associate or another organisation.
Employees must not use authority over colleagues or subordinates to require them to perform activities that breach the law, this Code or IMAPAC policies.
Employees must not use authority over colleagues or subordinates to require them to perform activities that breach the law, this Code or IMAPAC policies.
Professional Cooperation, Fairness and Integrity
No employee may use their position at IMAPAC to improperly advance their own interests or the interests of a family member, close associate or another organisation.
Employees must not use authority over colleagues or subordinates to require them to perform activities that breach the law, this Code or IMAPAC policies.
Employees must not use authority over colleagues or subordinates to require them to perform activities that breach the law, this Code or IMAPAC policies.
Culture of Discussion
Discussions should be conducted professionally and respectfully.
Employees are expected to address the substance of an issue rather than attack the individual involved and should avoid offensive, dismissive or unnecessarily confrontational communication.
Employees are expected to address the substance of an issue rather than attack the individual involved and should avoid offensive, dismissive or unnecessarily confrontational communication.
4. Cybersecurity, Data Protection and System Access
Everyone working with IMAPAC has a responsibility to protect the company's systems, accounts, information and digital assets from unauthorised access, misuse, loss, disclosure, fraud or cyberattack.
Employees, contractors and representatives must:
Employees, contractors and representatives must:
- keep passwords, authentication codes and login credentials confidential;
- use multi-factor authentication where required;
- never share passwords, authentication codes or company accounts with another person;
- never allow another person to use their IMAPAC account or identity;
- use only authorised devices, software, applications and cloud services for IMAPAC business;
- follow IMAPAC security requirements when accessing company systems remotely;
- exercise appropriate caution when opening links, attachments or messages that may be fraudulent or malicious;
- independently verify unusual payment instructions, bank-account changes, password-reset requests or requests for confidential information before acting;
- protect company devices from loss, theft and unauthorised access;
- lock devices when unattended;
- avoid downloading, copying or transferring company information to personal devices, personal email accounts, unauthorised cloud storage or removable media without approval;
- not attempt to bypass, disable, interfere with or evade security controls, access restrictions or authorised monitoring systems;
- not access systems, files, accounts or information beyond the level authorised for their role;
- not install unauthorised software, browser extensions or applications on company systems;
- report suspected phishing, malware, compromised passwords, unauthorised access, lost devices, data breaches or suspicious system activity immediately; and
- cooperate promptly with reasonable cybersecurity investigations and incident-response procedures.
Unauthorised Access and Use of Information
No person may intentionally:
- access another employee's account without authority;
- obtain or attempt to obtain another person's passwords or authentication credentials improperly;
- access confidential information without a legitimate business need;
- copy, extract, download or transfer IMAPAC information for an unauthorised purpose;
- introduce malicious software, scripts or code into IMAPAC systems;
- interfere with, damage or disrupt IMAPAC systems or services;
- use IMAPAC systems to gain unauthorised access to another organisation's systems; or
- assist another person to carry out unauthorised access, data extraction or cyber-related misconduct.
Serious or deliberate breaches may result in disciplinary action and, where appropriate, may be referred to relevant legal, cybersecurity, regulatory or law-enforcement authorities.
Social Engineering and Fraud Prevention
Employees must remain alert to attempts by third parties to obtain company information, credentials or payments through phishing, impersonation, social engineering or other deceptive methods.
Requests involving:
Requests involving:
- changes to supplier or customer bank details;
- urgent or unusual transfers of funds;
- password or authentication resets;
- confidential customer, employee or financial information;
- unusual supplier instructions;
- requests to download or install unfamiliar software; or
- messages appearing to come from senior management but using unusual communication channels
must be independently verified through an authorised method before action is taken.
No employee will be criticised for delaying a transaction or request for the reasonable purpose of completing security verification.
No employee will be criticised for delaying a transaction or request for the reasonable purpose of completing security verification.
Cybersecurity Incident Reporting
Any suspected cyberattack, data breach, compromised account, phishing attempt, malware infection, unauthorised access, lost device or misuse of company information must be reported immediately through the appropriate IMAPAC IT or security reporting channel.
Where the issue involves suspected intentional misconduct, fraud or unethical behaviour, it may also be reported confidentially to:
ethics@imapac.comWhere the issue involves suspected intentional misconduct, fraud or unethical behaviour, it may also be reported confidentially to:
Employees should not delay reporting because they are uncertain whether an incident is serious. Early reporting may help prevent further harm.
5. Compliance with Law and IMAPAC Policies
Everyone acting for or on behalf of IMAPAC must comply with applicable laws, regulations and company policies relevant to their role.
No individual is expected to be an expert in every area of law.
However, employees must be able to identify situations in which legal, HR, compliance, cybersecurity or management guidance should be obtained before proceeding.
Lack of knowledge of a relevant legal or compliance obligation does not remove the obligation to comply with it.
No individual is expected to be an expert in every area of law.
However, employees must be able to identify situations in which legal, HR, compliance, cybersecurity or management guidance should be obtained before proceeding.
Lack of knowledge of a relevant legal or compliance obligation does not remove the obligation to comply with it.
6. Gifts, Benefits, Bribery and Corruption
Employees must not offer, request, give or accept improper gifts, payments, discounts, benefits, advantages or other inducements intended to influence business decisions.
Employees must not use their position at IMAPAC to obtain improper personal benefits for themselves, relatives or associates.
Any gifts, hospitality or benefits must be lawful, reasonable, transparent and consistent with IMAPAC policies.
Employees must not use their position at IMAPAC to obtain improper personal benefits for themselves, relatives or associates.
Any gifts, hospitality or benefits must be lawful, reasonable, transparent and consistent with IMAPAC policies.
7. Consultation in Cases of Doubt
If an employee is uncertain about the proper course of action in a legal, ethical, operational, cybersecurity or conflict-of-interest matter, they should seek guidance before proceeding.
Confidential ethics enquiries may be submitted to:
ethics@imapac.comConfidential ethics enquiries may be submitted to:
Where appropriate, IMAPAC may obtain advice from authorised members of management, Human Resources, legal advisers, cybersecurity specialists or other professional advisers.
8. Applicability of This Code
This Code applies to all directors, managers and employees of IMAPAC and may also apply to contractors, consultants and other persons acting for or on behalf of IMAPAC where appropriate.
A breach of this Code may result in appropriate action in accordance with applicable law, contractual obligations and IMAPAC procedures.
Depending on the circumstances and seriousness of the matter, this may include disciplinary action.
A breach of this Code may result in appropriate action in accordance with applicable law, contractual obligations and IMAPAC procedures.
Depending on the circumstances and seriousness of the matter, this may include disciplinary action.
9. Reporting a Concern
IMAPAC encourages employees, contractors, customers, suppliers, partners and other stakeholders to raise concerns where they know of, or have a reasonable suspicion of:
- unlawful conduct;
- fraud or dishonesty;
- conflicts of interest;
- undisclosed competing business activities;
- misuse of confidential information or company data;
- diversion of business opportunities;
- misuse of IMAPAC systems, resources or working time;
- unauthorised system access or data extraction;
- cybersecurity misconduct;
- bribery or corruption;
- harassment or serious misconduct;
- financial irregularities; or
- other significant breaches of this Code or IMAPAC policies.
A person raising a concern does not need to prove that misconduct has occurred.
However, reports should be made in good faith and should include the facts on which the concern is based.
Reports should provide enough detail to allow the matter to be assessed properly, including where available:
However, reports should be made in good faith and should include the facts on which the concern is based.
Reports should provide enough detail to allow the matter to be assessed properly, including where available:
- the identity of the persons or organisations involved;
- what occurred;
- relevant dates or time periods;
- how the reporter became aware of the concern;
- supporting documents or publicly available information; and
- any other relevant facts.
General accusations that contain no factual basis may not provide sufficient information for an investigation to be opened.
How to Report
Concerns may be reported confidentially to:
ethics@imapac.comReports may also be submitted anonymously.
Anonymous reports should provide as much factual information as reasonably possible.
The ability to investigate an anonymous report may be limited where IMAPAC cannot contact the reporter for clarification or additional information.
Anonymous reports should provide as much factual information as reasonably possible.
The ability to investigate an anonymous report may be limited where IMAPAC cannot contact the reporter for clarification or additional information.
10. Confidentiality, Anonymous Reporting and Protection of Reporters
IMAPAC is committed to handling ethics and compliance concerns sensitively, responsibly and with an appropriate degree of confidentiality.
Reports submitted to ethics@imapac.com will be treated as confidential and will only be shared with individuals who reasonably need the information in order to assess, investigate, obtain professional advice on, or respond to the concern.
Where appropriate, IMAPAC may involve authorised members of senior management, Human Resources, legal advisers, cybersecurity specialists, external professional advisers or other persons whose involvement is reasonably necessary to address the matter.
IMAPAC will take reasonable steps to protect the identity of a person who raises a concern and will not disclose that identity unnecessarily.
However, absolute confidentiality cannot be guaranteed. In some circumstances, information may need to be disclosed in order to:
Reports submitted to ethics@imapac.com will be treated as confidential and will only be shared with individuals who reasonably need the information in order to assess, investigate, obtain professional advice on, or respond to the concern.
Where appropriate, IMAPAC may involve authorised members of senior management, Human Resources, legal advisers, cybersecurity specialists, external professional advisers or other persons whose involvement is reasonably necessary to address the matter.
IMAPAC will take reasonable steps to protect the identity of a person who raises a concern and will not disclose that identity unnecessarily.
However, absolute confidentiality cannot be guaranteed. In some circumstances, information may need to be disclosed in order to:
- conduct a fair investigation;
- comply with legal or regulatory obligations;
- protect the rights of another person;
- contain or investigate a cybersecurity incident;
- obtain legal or professional advice; or
- respond to legal proceedings.
Anonymous Reports
Reports may be submitted anonymously.
Anonymous reporters are encouraged to provide sufficient factual detail to enable IMAPAC to assess and investigate the concern properly.
The ability to investigate an anonymous report may be limited where further information or clarification cannot be obtained.
Anonymous reporters are encouraged to provide sufficient factual detail to enable IMAPAC to assess and investigate the concern properly.
The ability to investigate an anonymous report may be limited where further information or clarification cannot be obtained.
Protection Against Retaliation
IMAPAC does not tolerate retaliation, victimisation, harassment or adverse treatment against any person who raises a genuine concern in good faith or assists with an investigation.
A person who believes they have experienced retaliation after raising a concern should report this promptly to:
ethics@imapac.comA person who believes they have experienced retaliation after raising a concern should report this promptly to:
Protection against retaliation does not apply to reports that are knowingly false, malicious or deliberately misleading.
Privacy and Responsible Handling of Information
Information received through the ethics reporting channel will be handled responsibly and retained only for as long as reasonably necessary for the purposes of assessing, investigating, documenting or responding to the concern, subject to applicable legal and regulatory requirements.
Individuals involved in reviewing ethics concerns are expected to maintain appropriate confidentiality and must not use information obtained through the reporting process for unrelated purposes.
Individuals involved in reviewing ethics concerns are expected to maintain appropriate confidentiality and must not use information obtained through the reporting process for unrelated purposes.
11. Transparency and Responsibility to Speak Up
Everyone working with IMAPAC is expected to act transparently in matters involving legal, ethical, cybersecurity or significant business risk.
Employees who become aware of conduct that they reasonably believe may constitute serious misconduct, fraud, a significant conflict of interest, a cybersecurity incident or another material breach of this Code are encouraged to report the matter promptly.
Raising concerns early allows potential problems to be addressed before they cause greater harm to individuals, customers, partners or the business.
Employees who become aware of conduct that they reasonably believe may constitute serious misconduct, fraud, a significant conflict of interest, a cybersecurity incident or another material breach of this Code are encouraged to report the matter promptly.
Raising concerns early allows potential problems to be addressed before they cause greater harm to individuals, customers, partners or the business.
12. Review and Publication of the Code
This Code will be made available to IMAPAC employees and may be published on IMAPAC's website.
The Code should also be provided or made accessible to new employees as part of onboarding.
IMAPAC will review the Code periodically and may update it to reflect changes in applicable law, business activities, cybersecurity threats, organisational structure and recognised good practice.
Everyone working with IMAPAC is expected to familiarise themselves with this Code and comply with its principles.For ethics guidance or to report a concern:
ethics@imapac.comThe Code should also be provided or made accessible to new employees as part of onboarding.
IMAPAC will review the Code periodically and may update it to reflect changes in applicable law, business activities, cybersecurity threats, organisational structure and recognised good practice.
Everyone working with IMAPAC is expected to familiarise themselves with this Code and comply with its principles.For ethics guidance or to report a concern:
