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Introduction
ICIS’ business is founded on its reputation for independence, impartiality and objectivity. Our customers rely on ICIS for accurate information and base commercial decisions on that accuracy. Customers must feel confident that information relayed by ICIS, whether verbally, in print, on screen or in data form, has not been influenced by any commercial, personal or other interests.
This imposes a special duty of care on employees of ICIS concerned with information-gathering, analysis and publication not to engage in any activities, or be perceived to engage in any activities which might be prejudicial to ICIS’ reputation for independence.
This code of conduct is therefore intended as a supplement to the Reed Elsevier Code of Conduct and Business Ethics and should be read in conjunction with it.
All employees reporting via any management structure to the ICIS Editorial Directors must sign and acknowledge compliance with this code upon completion of their probation and on an annual basis as part of the PDP process. Violations of the code should be reported to one or both of the Editorial Directors as soon as employees become aware of them.
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Definitions
ICIS Sectors: Markets or industrial manufacturing sectors about which ICIS gathers and publishes information, including but not limited to: markets and industries surrounding chemicals, oil, fertilisers, natural gas, electricity, coal, sulphur, paper/pulp and emissions.
Information Staff: Employees whose management chain of command leads to the ICIS Editorial Directors, including but not limited to: market analysts, news analysts, market reporters, news reporters, web editors, and all managers of the above.
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Conflicts of Interest
ICIS Information Staff must notify senior management if they have any commercial or other direct interest in any company or organisation which is a legitimate subject for market-related information-gathering by any part of ICIS worldwide in the ICIS Sectors. Such companies are those whose primary or substantial focus is the manufacture, buying, selling, broking or trading of commodities in the ICIS Sectors.
Companies whose buying of commodities in the ICIS Sectors is not their primary focus (for example, soft drinks manufacturers, who are large consumers of plastics) are exempt from notification.
Notifiable interests include: direct financial interests, such as shareholdings or other investment in the company or organisation; work as a consultant or advisor to the company or organisation; and close family/partner employment by the company or organisation.
Employees need not notify management of holdings in generalized investment funds which may or may not take holdings in ICIS Sector companies.
As a general principle, financial interests as outlined above will preclude an ICIS employee from working in the ICIS information group. As an exception, employees may hold inactively traded shareholdings, for example in mutual funds, in companies active in ICIS sectors (but such holdings should still be notified).
Failure to notify such holdings shall be deemed Gross Misconduct under the terms of RBI employment and may result in an employee’s dismissal.
All Information Staff must make a declaration of any relevant financial interests on joining the company, to be updated annually as required. As a rule, new employees will be expected to dispose of any financial holdings in ICIS Sectors within six weeks of employment.
In exceptional circumstances, the ICIS Editorial Directors may at their discretion decide whether it is appropriate for an individual to continue an information-gathering relationship with a business or organisation active in the ICIS Sectors. Such exceptions are likely to be granted, for example, where a family relationship exists between a member of the Information Staff and an employee of a company in the ICIS Sectors which is active in an industry or market on which the ICIS staff member does not gather or publish information.
In the event that ICIS expands its business into new Sectors, employees will be asked to dispose of any financial holdings they may have in those Sectors within a six-month time-frame.
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Work outside ICIS
Information staff may wish to pursue opportunities to work freelance in areas outside their employment by ICIS, and on their own time. The freelance work should not constitute areas which overlap with the scope of the business in order to avoid potential conflict of interest, or even the appearance of one. Information staff must at all times inform their manager of their intent to pursue such opportunities and obtain written permission to do so, and such permission will not be unreasonably refused.
Where such work is potentially in conflict with or prejudicial to the interests of ICIS as a business; challenges the ability of the member of Information Staff to fulfill their ICIS duties; or a conflict of interest exists as defined in the Reed Elsevier Employee Code of Conduct, permission will not be given. The Editorial Directors are the arbiters of such permission.
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Public speaking
ICIS Information Staff, as market experts, are both expected and encouraged to deliver public speeches and presentations on ICIS or the markets we cover. All content must be cleared by senior management in advance of delivery.
Information Staff should not as a rule accept personal fees for conference speaking (but see Briefings below), but if invited to speak at conferences, should ask to have their travel and accommodation expenses paid by the conference organizer.
In cases in which public speaking engagements are chargeable or payable, the fees are to be agreed with, negotiated and processed by Sales and/or Commercial representatives of the company, not the Information Staff. This general rule also applies to other paid-for type of work related to the business.
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Consultancy and Briefings
ICIS Information staff are increasingly in receipt of requests from customers for single client and multi-client consulting work: regular advice, presentations, retainer basis etc. While it is flattering that the industry is treating us as experts in our field, Information Staff should bear the following in mind.
- ICIS has a professional consulting group, which operates behind a “Chinese Wall’, separately from the Information group. Requests for formal project-type consulting work should be referred in the first instance to this group, in particular requests for single-client studies. Members of the Information groups could be called upon at times to participate in projects led by the Consulting Group should the relevant expertise lie within the Information groups. Staff are encouraged to participate in such studies and lend expertise in line with the prevailing Editorial Guidelines on Consulting Work. However, such work should never be allowed to compromise editorial integrity and will be subject to the Editorial and Consulting Guidelines, which clearly outline the boundaries editorial contributions. Such contributions should not interfere with the day-to-day work of the Information groups and if needed, alternative work arrangements need to be agreed upon by Editorial management.
- Sensitive and commercially important data found in multi-client and single client type studies and maps can only be used with the permission of management of the Consulting group in accordance with Data Governance Protocols.
- ICIS maintains an open door policy with regards to our price assessment methodology and this is reflected in our commitment to initiate dialogue with the markets. Presentations on ICIS methodology are encouraged either through webinars, in-house presentations, industry events or one-to-one meetings. Methodology presentations should be organized in consultation with the Managing Editors, Head of Market Reporting, the sectoral heads (of Fertilizers, Gas etc), and the Editorial Directors.
- ICIS Information Staff are barred from appearing as “Expert witnesses” in legal proceedings, they should not agree to do so without permission from the RBI Legal department and editorial management. ICIS information staff are, however, able to provide chargeable data/information to be used in court at the discretion of Editorial Directors.
- Under no circumstances may Information staff accept payment privately for consultancy-type activities.
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Communicating with the industry
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Professional standards
ICIS Information Staff are expected to behave at all times with professional courtesy and respect towards industry and market participants, whether customers of ICIS or not. Conversely, ICIS expects industry participants to show similar standards of respect in their communications with ICIS Information Staff. Employees should report any abusive or other inappropriate behaviour by industry contacts to their managers.
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Written communication
ICIS pledges to respond to all communications it receives in an appropriate manner. This includes timely responses to telephone calls and, where appropriate the delivery of a written response. Written responses to complaints about ICIS reports, queries about ICIS methodology, or questions relating to ICIS’ commercial interests should not be sent without prior management approval at the appropriate level. Email correspondence with clients and contacts should be from a company account.
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Advance or delayed disclosure of information
Information scheduled for publication in any form may not be disclosed to any industry or market participants, or to non-Information ICIS staff (for example sales or marketing personnel), in advance of publication. This includes in particular price assessments, market analysis, and any other items of information or news likely to result in market movements.
Information Staff are forbidden from delaying publication of information with the intent of enhancing its market impact. Real-time news items should be published as soon as they are ready for publication and not, for example, held back until “market opening”.
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Use of social media
As part of their job, ICIS Information Staff are encouraged to make use of social media (Twitter, LinkedIn, etc) that is consistent both with the company's objectives to draw visitors to icis.com, and with the policies on appropriate content and frequency of updates. Outside of work and under their own accounts, staff are asked to continue using prudence and discretion when using social media, including personal blogs, given that our sources, customers, competitors, regulators and anyone else will associate us with our employer - regardless of whether or not we as individuals believe ourselves to be speaking in a private capacity.
Accordingly, all staff are asked to refrain from expressing any comment or opinion on the sectors or markets we cover, or the participants in them, that could embarrass, harm, or otherwise lower the standing of ICIS. This would include making any forecast or expressing any opinion on market trends or strategies - especially related to pricing - that could harm our reputation for objectivity.
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Paid-for travel and hospitality
ICIS Information Staff should not accept paid-for travel and hospitality, or junkets, which would compromise editorial integrity. Commissioned paid articles, such as industry supplements and advertorials, will come under the remit of the Custom Publishing department.
ICIS Information Staff may of course accept modest hospitality from industry contacts (business lunch, for example) provided that commensurate mutual hospitality is offered by ICIS in return. ICIS staff should however, be sensitive to cultural differences where refusal of hospitality may be regarded as insulting behavior. In such cases, Information Staff should obtain advance permission from their manager to accept limited hospitality. Information Staff should inform their manager of all high-value invitations received from the industry.
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Paying for information
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Paying for market information
ICIS does pay for some market information, for example for foreign exchange rates or shipping data in shipping markets where ICIS has no reporting expertise. ICIS Information Staff should not subscribe to competitors’ publications, nor to publications produced by brokerage houses, banks etc, except where these are free of charge. It is permissible, with written management permission, to arrange a publication swap with a competitor, where the information exchanged is deemed to be of similar value, provided that the counter-party to the swap has obtained similar written permission from their management.
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Paying for conferences
Information Staff gathering news or other information for publication from conferences or other events should at all times request a free Press Pass from organizers. Where such passes are denied, Staff should inform their manager.
If staff are negotiating a press pass with a conference organiser, under no circumstances should any promise be made that impinges on the ability of ICIS to report on the event in a manner consistent with its standard content policies. For example, it would be acceptable to give an undertaking to mention in stories the name of the conference and include a hyperlink to a website; but it would be unacceptable to promise a certain slant to any article or to allow a conference organiser a right of veto over editorial content. The Editorial Directors should be consulted if doubt exists.
Staff attending conferences for purposes other than information-gathering may pay to attend with their manager’s permission.
In some markets where key conferences are organized by competitors to ICIS, paying to attend may be the only option. Again management permission should be sought.
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Competitors’ publications
ICIS enforces the strictest controls on violation of its copyright. Information Staff need to live up to the same standards, ensuring that any copyright information we hold has been legitimately obtained. This means:
- Information Staff may not share subscriptions to publications or log-ins to information services beyond the use limit permitted by the subscription.
Information Staff should be on their guard against industry participants who are in the habit of forwarding competitors’ publications. Such forwarding, except for the occasional purpose of pointing out conflicting information, constitutes illegal redistribution. Information Staff who are offered copies of competitors’ publications on a systematic basis should politely decline, and inform their manager. Information Staff who are sent email copies of competitors’ publications should delete them, and inform their manager. This includes obtaining competitors' publications via personal email addresses.
- It is acceptable to keep a few sample copies of competitors’ reports for comparative intelligence purposes.
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Plagiarism
ICIS takes a far stricter view of any activity resembling plagiarism than is perhaps current in the general media.
ICIS will treat as gross misconduct any evidence that a member of its Information Staff has reproduced in whole or in part market analysis, commentary, pricing, data or news information that originates elsewhere, including especially market commentary written by industry participants, even if that commentary has been sent to ICIS for its exclusive information. With regard to the last point, we have a duty of care not blindly to reproduce the views of market participants, which are likely inherently to be biased.
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Reporting on ICIS’ business or that of competitors
Where the business activities of ICIS or its competitors are of legitimate interest to ICIS customers, ICIS Information Staff have a responsibility to report such activities impartially, and should follow normal standards for independent and impartial news or other reporting, including where appropriate interviewing ICIS or RBI management.
ICIS Information Staff should not undertake reporting on ICIS or its competitors, however, without permission from their line managers, and reports of this kind should be reviewed by the Editorial Directors prior to publication.
ICIS Information Staff have a duty of care to ensure any such reporting cannot be interpreted by customers as attempts to further the business agenda of ICIS.
ICIS Information Staff should not comment to the industries we serve on competitors’ activities or methodologies.
ICIS Information Staff should not discuss ICIS methodology or other internal issues with employees of competitors.
ENDS
Last updated March 2013