Governance & Compliance Policy

1. Overview and Scope

This policy applies to all ASAT Labs board members, staff, consultants, contractors, interns, volunteers, and partners (collectively "representatives"). It covers all activities, decisions, and interactions related to ASAT Labs' mission and operations.

Establish clear ethical standards and behavioral expectations
Prevent corruption, conflicts of interest, and misconduct
Provide safe channels for reporting concerns and complaints
Ensure compliance with applicable laws and regulations
Protect the organization's reputation and public trust

2. Governance Framework

Board Oversight The Board of Trustees has ultimate responsibility for governance and compliance oversight.

Board reviews and approves all governance policies annually
Audit Committee monitors compliance and investigates serious breaches
Executive Leadership implements day-to-day compliance procedures
All representatives are accountable for adherence to this policy

3. Code of Conduct

All ASAT Labs representatives must demonstrate the highest standards of professional conduct and personal integrity.

Core Values

Integrity: Act honestly, transparently, and consistently with our mission
Respect: Treat all individuals with dignity, regardless of background or position
Accountability: Take responsibility for actions and decisions
Excellence: Strive for quality and continuous improvement
Collaboration: Work cooperatively and inclusively with others

Expected Behaviors

Comply with all applicable laws, regulations, and organizational policies
Use organizational resources responsibly and for legitimate purposes
Maintain confidentiality of sensitive information
Avoid discriminatory, harassing, or abusive behavior
Report suspected violations of this policy promptly

4. Professional Integrity Standards

Truthfulness: Provide accurate, complete information in all communications
Fairness: Make decisions based on merit, evidence, and organizational interests
Confidentiality: Protect sensitive organizational and personal information
Professional boundaries: Maintain appropriate relationships with colleagues, beneficiaries, and partners
Financial responsibility: Handle funds and resources with care and transparency

Note: Any concerns about professional conduct should be reported using the procedures outlined in Section 8.

5. Anti-Corruption Policy

ASAT Labs has zero tolerance for corruption, bribery, or any form of dishonest conduct.

Prohibited Activities

Offering, giving, requesting, or receiving bribes or improper payments
Facilitating payments to expedite routine services
Money laundering or handling proceeds of criminal activity
Fraud, embezzlement, or misappropriation of funds
Kickbacks or secret commissions

Gifts and Hospitality

Gifts over £50 value must be declared and may need to be declined
Hospitality should be reasonable, appropriate, and transparent
Cash gifts are never acceptable
All significant gifts and hospitality must be recorded in the register

Warning: Corruption violations may result in disciplinary action, termination, and referral to law enforcement authorities.

6. Conflict of Interest Policy

A conflict of interest occurs when personal interests could compromise professional judgment or organizational interests.

Types of Conflicts

Financial: Personal financial gain from organizational decisions
Professional: Competing loyalties to other organizations
Personal: Family or personal relationships affecting judgment
Political: Political activities that could compromise neutrality

Common Conflict Situations

Financial interest in suppliers, partners, or competitors
Board or employment positions with other organizations
Family members as contractors, suppliers, or beneficiaries
Personal relationships with colleagues in reporting lines
Outside consulting or business activities

7. Disclosure Procedures

All actual, potential, or perceived conflicts of interest must be disclosed promptly and managed appropriately.

Disclosure Requirements

Annual Declaration: Complete annual conflict of interest forms
Ongoing Disclosure: Report new conflicts as they arise
Meeting Declarations: Declare conflicts at the start of relevant meetings
Decision Recusal: Withdraw from decisions where conflicts exist

Management Actions

Avoidance: Eliminate the conflict where possible
Management: Implement controls to minimize impact
Disclosure: Transparent reporting to stakeholders
Recusal: Withdrawal from affected decisions

Process: Submit disclosure forms to governance@asatlabs.org within 7 days of identifying a conflict.

8. Whistleblowing Policy

ASAT Labs encourages the reporting of suspected wrongdoing and provides protection for those who raise genuine concerns.

Reportable Concerns

Violations of law, regulation, or organizational policy
Fraud, corruption, or financial misconduct
Abuse of power or authority
Discrimination, harassment, or bullying
Misuse of organizational resources
Threats to health, safety, or welfare
Cover-ups of wrongdoing

Reporting Channels

Direct supervisor (if not involved in the concern)
HR Department: hr@asatlabs.org
Governance Officer: governance@asatlabs.org
Board Chair: chair@asatlabs.org
Anonymous hotline: Available 24/7
External agencies: Regulatory bodies or law enforcement

9. Complaints Procedure

ASAT Labs is committed to addressing all complaints fairly, promptly, and confidentially.

Complaint Categories

Service complaints: Issues with programs or services
Conduct complaints: Inappropriate behavior by representatives
Policy complaints: Concerns about organizational policies
Discrimination complaints: Unfair treatment based on protected characteristics

Complaint Process

Informal resolution: Attempt to resolve directly where appropriate
Formal complaint: Submit written complaint with details
Acknowledgment: Receive confirmation within 3 working days
Investigation: Thorough, impartial review of the complaint
Resolution: Response and action plan within 20 working days
Appeal: Right to appeal decision to independent reviewer

10. Investigation Process

All reports and complaints will be investigated fairly, thoroughly, and confidentially.

Investigation Principles

Impartiality: Investigations conducted without bias or prejudice
Thoroughness: All relevant evidence and witnesses considered
Timeliness: Investigations completed as quickly as possible
Confidentiality: Information shared only on need-to-know basis
Fairness: All parties given opportunity to present their case

Investigation Outcomes

No case to answer: Complaint not substantiated
Informal resolution: Issue resolved through discussion and agreement
Formal disciplinary action: Sanctions applied according to severity
System improvements: Changes to policies or procedures
External referral: Matter referred to regulatory or law enforcement agencies

11. Protection and Support

ASAT Labs is committed to protecting individuals who raise genuine concerns in good faith.

Protection Against Retaliation

No adverse action for making good faith reports
Disciplinary action against those who retaliate
Confidentiality maintained throughout process
Anonymous reporting options available
Independent support and advice provided

Support Services

Counseling support: Access to professional counseling services
Legal advice: Independent legal guidance where appropriate
Workplace adjustments: Temporary changes to working arrangements
Regular check-ins: Ongoing support throughout the process

12. Compliance Monitoring

Regular audits: Internal and external compliance reviews
Risk assessments: Ongoing evaluation of governance risks
Performance indicators: Metrics to track compliance effectiveness
Board reporting: Quarterly governance reports to trustees
External oversight: Engagement with regulatory bodies and watchdogs

13. Training and Awareness

Induction training: All new representatives receive governance training
Annual refreshers: Regular updates on policies and procedures
Role-specific training: Targeted training for high-risk positions
Board development: Enhanced training for trustees and board members
External training: Access to specialist compliance courses

14. Policy Review and Updates

Annual review by senior leadership and board
Updates following significant incidents or legislative changes
Stakeholder consultation on major revisions
Version control and change documentation
Communication of updates to all representatives

15. Contact Information

Governance Officer: governance@asatlabs.org

HR Department: hr@asatlabs.org

Board Chair: chair@asatlabs.org

Anonymous Hotline: Available 24/7 via website portal

External Regulators: Contact details available from governance@asatlabs.org