Code of Ethics

1.0 Purpose and Scope

This Code of Ethics sets out the principles and standards of behaviour that Lendrim Limited, trading as Six Agency Group, expects from every director, employee, contractor and consultant working across the group, including our Six Digital, SixOn and CareerSix divisions.

We work with clients across recruitment, healthcare, finance and other regulated and sensitive sectors. The trust those clients place in us depends on us doing business the right way, not just the profitable way. This Code exists to make that expectation explicit rather than assumed.

This Code applies to all business activity carried out under the Six Agency Group name, regardless of which division is delivering the work, and regardless of whether the person carrying it out is a permanent employee, a contractor, or a third party acting on our behalf.

2.0 Our Core Principles

Four principles sit underneath every policy in this document. Where a situation is not explicitly covered
elsewhere, these are the standard to fall back on.

2.1 Integrity

We do what we say we will do. We do not overstate results, inflate reporting, or promise outcomes we
cannot reasonably deliver. If something has gone wrong on an account, the client hears it from us before
they have to ask.

2.2 Respect

Everyone we work with, colleagues, clients, suppliers and candidates, is treated fairly and without
discrimination. Disagreement is normal in business. Disrespect is not.

2.3 Accountability

We own our mistakes. A team member who flags a problem early is valued more than one who hides it and
hopes it resolves itself.

2.4 Compliance

We meet our legal and regulatory obligations as a minimum, not as an aspiration. Where a law or regulation
is unclear, we take the more cautious interpretation rather than the more convenient one.

3.0 Business Conduct

Conflicts of interest. Anyone with a personal, financial or family interest that could reasonably influence a business decision must declare it to their manager before the decision is made, not after. This includes personal relationships with clients, suppliers or candidates.

Gifts and hospitality. Modest, occasional gifts and hospitality that would not reasonably be seen to influence a business decision are acceptable. Anything beyond that, cash, vouchers, or hospitality disproportionate to the relationship, must be declined or referred to a director.

Anti-bribery and corruption. We do not offer, give, request or accept bribes in any form, in line with the Bribery Act 2010. This applies to facilitation payments as much as it does to cash bribes. No commercial outcome justifies breaching this policy.

Fair dealing. We compete on the quality of our work, not by making misleading claims about competitors or by misrepresenting our own results, case studies or client outcomes.

IN PRACTICE
If a decision would be difficult to explain honestly to a client, a colleague, or a regulator, that is a signal to stop and ask, not a signal to proceed quietly.

4.0 Client Relationships and Confidentiality

Client data, campaign performance, commercial terms and internal strategy documents are confidential. They are shared only with the people who need them to do their job, and never used for personal advantage or shared with a competing client without written permission.

Marketing claims we make on behalf of clients, and about our own services, are accurate and substantiated. We do not publish or approve advertising, SEO content, or PPC copy that we know to be misleading, in line with the Advertising Standards Authority’s CAP Code and Google’s advertising policies.

Where a conflict exists between two clients in the same sector, this is disclosed to both parties, and separate account teams are used wherever practical.

5.0 Data Protection

Six Agency Group processes personal data on behalf of clients across recruitment, healthcare and finance, sectors where the consequences of a data breach are serious. We handle all personal data in line with the UK GDPR and the Data Protection Act 2018.

  • Personal data is collected only for a specific, stated purpose, and is not reused for anything outside that
    purpose without consent.
  • Access to client and candidate data is limited to the people who need it for their role.
  • Any suspected data breach is escalated immediately to a director, not managed informally within a single
    team.
  • Data is retained only as long as necessary and disposed of securely once that need ends.

6.0 Workplace Standards

Six Agency Group is an equal opportunities employer. Recruitment, promotion, pay and every other aspect of employment is decided on merit, in line with the Equality Act 2010, without regard to age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation.

Bullying, harassment and victimisation of any kind are not tolerated, whether directed at colleagues, clients, candidates or suppliers. This includes conduct that takes place outside the office, at client events, or online. We take a proactive approach to health, safety and wellbeing, including reasonable adjustments for mental health as well as physical health, and expect the same standard from anyone working on our premises or on our behalf.

7.0 Raising a Concern

Anyone who witnesses or suspects a breach of this Code, by a colleague, a supplier, or the business itself, is expected to raise it. Concerns can be raised with a line manager, any director, or through the confidential whistleblowing channel maintained by the group.

NO RETALIATION
Nobody will be penalised, formally or informally, for raising a genuine concern in good faith, even if the concern turns out to be unfounded.

8.0 Compliance and Review

Breach of this Code is treated as a serious matter and may result in disciplinary action, up to and including dismissal for employees, or termination of contract for suppliers and contractors, depending on the severity of the breach.

This Code is reviewed annually by the board of Six Agency Group, or sooner if a material change in law, regulation or business activity requires it.

Legal entity: Lendrim Limited, trading as Six Agency Group
Company number: 12797318
Registered office: Unit 3 Derby Road, Liverpool, England, L5 9PR

Divisions covered: Six Digital, SixOn, CareerSix
Document owner: Board of Directors, Six Agency Group
Version: 1.0
Review cycle: Annual, or on material change