McLays understands the importance of having a clear set of Ethical guidelines for all staff to adhere to. They are listed below.


Our Ethical Policy is more than what we ‘could do’ in a legal sense. It is about what we as a company and as individuals ‘should do’ in an ethical sense, and in that way hold ourselves to the highest standards possible. The Ethical Policy should be regarded as more than a simple set of rules. It is a statement of beliefs that should guide employees' conduct in most situations.


  • McLays will comply with the law of every country in which we do business.
  • Employees are expected to comply with all laws affecting our business, and to act in every respect with honesty, fairness and integrity.


  • Each employee of McLays has an individual responsibility to deal ethically with our customers and suppliers, fellow employees and the general public. All employees are expected to do more than merely avoid unethical conduct. They must also take the initiative and assume positive responsibilities for quality, honesty and fairness.
  • Employees are expected to raise ethical concerns and report any actual or suspected ethical misconduct to their Manager or any Director as appropriate. If this is not appropriate, then the procedures outlined in the Whistleblowing Policy should be followed.
  • 'Looking the other way' on potential ethical questions is in direct contradiction to McLays’ commitment to honesty and integrity and is not acceptable. Honesty also requires that employees refuse to participate either actively or passively in any cover-up of such misconduct.
  • Each employee is expected to co-operate fully in any investigation of ethical matters by McLays.


  • As outlined in our separate Anti-Bribery Policy, it is McLays’ policy to conduct all of our business in an honest and ethical manner. McLays take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings wherever we operate.
  • This applies to all individuals working at all levels within the McLays organisation, including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, and any other person providing services to us.
  • This does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must comply strictly with McLays ethics in respect of gifts and hospitality. McLays will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a Client representative in the performance of their duties.


  • As described in the McLays Staff Handbook, we believe that all decisions about people at work should be based on the individual's abilities, skills, performance and behaviour, and our business requirements. Questions of an individual's race, colour, gender, marital status, age, religion or sexual orientation are never relevant to our business.
  • Harassment of individuals based on any of the issues listed in the Equal Opportunity Policy is neither permitted nor condoned. McLays’ policy is that all of its employees will enjoy a work environment free from any form of harassment. Any complaint of harassment of any form will be investigated and appropriate action, which may include dismissal, taken.


  • McLays is strongly committed to the prevention of illegal activities, and to the protection of its employees, McLays property and the public from any danger which might result from the use of drugs or alcohol. It is our policy to provide a safe drug-free and alcohol-free work environment. In the workplace, drug and alcohol abuse can create hazardous situations, lower productivity and can cause potential problems with outsiders with whom McLays does business.
  • The consumption or possession of illegal drugs on Company premises is a criminal act and will be treated as gross misconduct.
  • As outlined in section 5.2.8. of the Employee Handbook, McLays recognise that a number of employees may experience difficulties with alcoholism or addiction to drugs. We aim to provide appropriate support, assistance and guidance to such employees. Where an individual is unwilling to tackle their problems or their work performance and personal conduct are adversely affected, disciplinary action may be taken.


  • As outlined in McLays’ Environmental Policy, we understand that our activities have a significant impact on the environment i.e. though energy use, transportation and generation of waste, so we commit ourselves to continual improvement, prevention of pollution and minimisation of any environmental impacts of our business. Subsequently, we incorporate environmental management into our business and in doing so, gain accreditation to ISO Standard Environmental Management Systems.
  • McLays will continue to seek alternatives to hazardous methods, substances or products to assure protection of the environment and personal safety. Individuals who knowingly violate any environmental law or regulation will be subject to dismissal. Accidental incidents which affect the environment are to be reported immediately to the appropriate outside authorities as well as to senior management.


  • McLays is committed to human rights, ethical trading and the prevention of modern slavery in its business activities and employment practices. McLays will: 

            i.      conduct its business with integrity, recognising the economic, social, cultural, political and civil rights of those involved in the company’s operations and respecting the different cultures and the dignity and rights of individuals in the countries where it operates;

            ii.      comply with national laws and be guided by the general principles of international law, especially for the purposes of this policy with respect to human rights;

            iii.      accept that we have an obligation to promote respect for and observance of human rights and fundamental freedoms for all, without distinction as to race, creed, colour, nationality, ethnic origin, age, religion or similar belief, political affiliation, gender, gender reassignment, sexual orientation, marital status, family connections, membership or non-membership of a trade union disability or any other group;

            iv.      pay employees at least the national minimum wage or national living wage (as appropriate);

            v.      not employ underage staff;

            vi.      safeguard against human trafficking by conducting checks on the eligibility for all individuals to work in the UK;

            vii.      ensure that individuals are not forced to work against their will, as defined in section 1.1 of the Modern Slavery Act 2015:

1)     A person commits an offence if—

  1. the person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or
  2. the person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour;

            viii.      ensure transparency of supply chain within the organisation;

            ix.      refuse to support or conduct business with any company or organisation knowingly involved in slavery, human trafficking, or abuses of human rights;

            x.      encourage suppliers and subcontractors to abide by the same principles;

            xi.      ensure that for staff, subcontractors, and suppliers, the terms of engagement will be clear, fair and reasonable in comparison with those offered by similar companies;

            xii.      strive, at all times, to provide customers with the standards of products and services that have been agreed.


  • All financial reporting at all levels throughout McLays must be factual and open. Business integrity will be reflected in accurate and complete accounts and records. Employees are responsible for ensuring the accuracy and reliability of such accounts. Fictitious, improper, deceptive, undisclosed or unrecorded accounts of funds or assets are a serious ethical abuse and illegal. All transactions must be accurately documented and accounted for in the accounts and records of McLays.


  • McLays has a clear ‘whistle-blowing’ policy, outlined under section 3.1.4. of the Staff Handbook, and displayed clearly throughout all areas of the premises.
  • If an employee has information that suggests that there may be some wrongdoing or corruption in relation to some aspect of our business, they should make it known at a suitably senior level. If it is believed that the Directors are personally implicated in the issue, then the employee should raise the matter in writing with the Company Secretary. Should this not be appropriate then concerns should be raised with the appointed independent third party, anonymously if desired.


All employees are expected to be familiar with and to observe the ethical standards outlined in this code. Abuse of McLays’ ethical code may be grounds for dismissal and the abuser could be subject to legal action. Managers are responsible for ensuring the application of this ethical code by monitoring and enforcing the code within their areas. Application of the Code will be one of the performance standards by which all managers will be measured. All of McLays’ managers are expected to lead by example and communicate a real concern for the observance of these ethical guidelines.