Inline engages with all external stakeholders in a transparent, honest and ethical manner. The principles of our Code are: high levels of transparency, honesty and professional standards. As a company, and as individuals, we aim to apply the highest professional standards in the service of all our clients. This Code is reviewed on an annual basis to ensure it is in line with industry best practice.
This Code specifically covers the activities of Inline Policy and its staff, consultants and advisers in relation to all United Kingdom, English, Welsh, Scottish and Northern Ireland central, regional and local government bodies and agencies, public bodies and political parties. However, it also applies to our activities in all global markets in which we operate, where we respect national laws, industry codes of conduct and any other applicable laws. Our Code applies equally to all clients, whether fee-paying or not.
All Inline Policy staff go through an induction process on beginning their employment at Inline Policy, and will be provided with this Code of Conduct, so that they can read and understand their responsibilities. They also have access to advice where necessary and are encouraged to raise any concerns with senior management.
We are committed to providing a working environment in which everyone feels valued and respected and is able to pursue a rewarding career whilst contributing to the success of our business. We believe that there are real benefits to having a diverse workforce and aim to ensure that everyone can enjoy equal opportunities in an environment which is free from discrimination, harassment, bullying and victimisation. We oppose all forms of unlawful or unfair discrimination on the grounds of colour, race, nationality, ethnic origin, sex, marital status, disability, part-time or fixed term status, parental responsibilities, age, religion/belief or sexual orientation.
All Inline Policy employees are bound by this code, which contains the following principles:
- We will not advise on or participate in any activity that we consider illegal, offensive or defamatory.
- If we become aware of client activities that breach the law we will bring this to the attention of the client and, if these activities continue, we will cease to act for that client.
- We will not make exaggerated or inaccurate claims to clients about the nature and extent of our influence. Similarly, we will not make exaggerated or inaccurate claims when making representations on behalf of our clients. Neither will we attempt to pass off the company or ourselves as being any other organisation for the purpose of gaining access to an individual or organisation.
- We will not attempt to have privileged access to any elected representative, or charge a stand-alone fee in relation to any one-off access to elected representatives.
- We will not compel any member of staff to work on an account or for a client whose business model represents a conflict of their personal, moral or religious views.
- To the best of our ability, we will comply with relevant codes of practice or regulations which apply to the conduct of our clients, as notified to us by them.
Confidentiality and Reliability
- Any knowledge of a client’s business, or information gained by Inline Policy will not be disclosed to a third party.
- We will preserve the confidentiality of the information we acquire, whilst also maintaining the intellectual property and copyright of our clients.
- To the best of our knowledge, the advice we dispense shall be fair, balanced and evidence based.
- We will not use confidential information unless it is given with permission, in which case we will strictly follow any conditions given alongside the permission.
- We will ensure that information gained from our clients, through representing them, or privileged information gained from our own activities is not used elsewhere to the detriment of our existing clients.
- It is acceptable to facilitate meetings and networking with reasonable hospitality. However, Inline Policy will not offer anything which could be misconstrued as an inducement or inappropriate, particularly when dealing with elected members, their advisers or public officials. We will not apply improper influence on an elected representative. We expect the same level of conduct for our employees receiving any hospitality.
- We shall never arrange individual or stand-alone meetings with Parliamentarians or public officials where attendance is dependent on payment of an entry fee or charge.
- We shall not employ or pay consultancy fees to any sitting elected representative or Peer.
- We will not procure or hold or use, for the purpose of business, any privileged pass or permit that allows access to non-public areas of a Parliament or Assembly, except where a specific pass exists for such purposes, such as for the European Parliament, for example.
Transparency and Openness
- We shall always meet our obligations as a member of the Register of Consultant Lobbyists in the UK, and will communicate clearly to clients if communications undertaken on their behalf will need to be logged when filing quarterly information returns.
- We shall always identify our clients and ourselves at the earliest opportunity when conducting and communicating with an elected representative or public official, or any person acting on behalf of an elected official.
- We reserve the right to second employees to clients, and to represent our clients under their banner. In these cases, at the point of initial contact, it will be made clear that Inline Policy employees are acting on behalf of our clients.
- We shall normally refer directly to the relevant client, enquiries about the nature of our work for them. The exception to this shall be where the client gives express, written permission for us to answer such queries, in which case we shall normally secure the client’s approval for our response before communicating it.
Conflicts of Interest
- Any conflicts of interest shall be reported to senior management as soon as possible.
- Where a conflict of interest does occur, we shall speak to all concerned immediately and either proceed with permission of all parties, remove the member of staff from the account, or resign one account.
Employees will abide by the principles contained in this Code across all international markets in which Inline operates. When operating overseas, we will also abide by local laws and industry Codes, as required and appropriate. For example, Inline Policy currently is registered on the EU Transparency Register and abides by the EU Transparency Register Code of Conduct for all interactions on behalf of clients with the EU Institutions.
Inline last reviewed this Code of Conduct in August 2017.