Business Ethics, Supplier & Partner Code of Conduct

1. Binding Scope Across Workforce, Print Mills & Ecosystem Partners

Compliance with this Code of Conduct is a mandatory condition of employment, board service, supplier onboarding, and partner certification at British Noble. "Covered Parties" bound by this Code include: (a) all full-time and part-time employees, officers, and directors globally; (b) freelance developmental editors, copyeditors, indexers, proofreaders, book designers, and studio narrators engaged on British Noble Press commissions; (c) Certified Solutions, Prepress Studio, and Referral Alliance Partners; and (d) third-party infrastructure vendors, pulp and paper merchants, offset printing plants, specialty cloth/slipcase binderies, print-on-demand hubs, and logistics carriers.

Every Tier 1 and Tier 2 supplier must countersign contractual compliance covenants incorporating this Code prior to purchase-order issuance and flow equivalent ethical and labour standards down to its own upstream material subcontractors.

2. Anti-Bribery, Anti-Corruption & Public-Institution Rules

British Noble enforces strict compliance with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), the OECD Anti-Bribery Convention, and UAE federal anti-corruption legislation across every jurisdiction in which we operate. No Covered Party may directly or indirectly offer, promise, authorise, solicit, or accept any bribe, kickback, secret commission, undisclosed rebate, cash gift, or "facilitation payment" to obtain or retain publishing contracts, expedite customs clearance of printed pallets, or influence vendor selection.

Heightened scrutiny applies whenever interacting with Public Officials and State Cultural Entities, including national ministries of education or culture, state curriculum adoption boards, public university presses, municipal library consortia, and sovereign museum foundations. Modest, customary business hospitality (such as reasonable book-fair working meals or complimentary review copies of published books bearing zero cash resale inducement) must comply with local public-sector ethics caps, never occur during an active competitive tender blackout, and be logged transparently in the Corporate Hospitality Register whenever exceeding GBP 100 (or currency equivalent).

3. Modern Slavery Prevention & Ethical Print / Bindery Labour

Physical book manufacturing spans forestry harvesting, pulp and art-paper mills, offset pressrooms, foil-stamping and hand-cased slipcase binderies, and regional fulfilment warehouses. Pursuant to the UK Modern Slavery Act 2015 (Section 54), the ILO Declaration on Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business and Human Rights, all manufacturing and logistics partners must uphold the following non-negotiable labour standards:

• Freely Chosen Employment: Strict prohibition of forced, prison, bonded, indentured, or trafficked labour. Employers must never confiscate or withhold workers' passports, identity cards, or work permits, nor charge recruitment or placement fees to migrant workers.
• Zero Child Labour: No person below the statutory minimum working age (or age 15 under ILO Convention 138, whichever is higher) may be employed, and workers under age 18 must never perform night shifts or hazardous guillotine, chemical-solvent, or heavy-press operations (ILO Convention 182).
• Living Wages, Working Hours & Collective Bargaining: Wages, overtime premiums, and statutory benefits must meet or exceed legal minimums and local living-wage benchmarks without unlawful disciplinary deductions; working hours must comply with local law and ILO humane rest standards; and workers' freedom of association is respected.
• Pressroom Health & Safety (ISO 45001): Print plants and binderies must maintain guarded guillotine and folding machinery, adequate pressroom ventilation against ink/adhesive vapours, personal protective equipment, clearly unlocked fire exits, and documented emergency drills.

4. Respect for Authorship, Copyright Integrity & Anti-Spam Rules

British Noble exists to serve legitimate publishers, scholars, institutions, and human authors. Customers, authors, and partners using British Noble AI or British Noble Press warrant compliance with the Berne Convention, WIPO Copyright Treaties, and domestic copyright statutes. Using the Platform to ingest, typeset, or distribute pirated manuscripts, un-cleared photographic archives, plagiarised scholarship, or deceptive "companion/summary" clones designed to confuse readers searching for another author's work is strictly forbidden and grounds for immediate account termination.

To protect retail and library discovery across all 108 connected channels, British Noble strictly prohibits synthetic catalogue farming (mass-uploading low-quality, machine-generated spam titles, public-domain scraping without substantive scholarly curation, or purchased/fabricated retail review rings). Accounts flagged by partner channel integrity monitors for deceptive metadata or rights infringement face immediate dispatch suspension pending legal verification.

5. Fair Dealing with Authors, Royalties & Workplace Inclusion

Financial trust between publishers and creators requires mathematical honesty. British Noble designs its Sales & Royalties engine so every retail unit, currency conversion rate, return reserve holdback, and advance recoupment balance is auditable to the penny; we refuse any customisation request designed to obscure legitimate sales, apply undisclosed hidden deductions, or falsify author statements. Within British Noble Press, studio agreements are written in plain English with zero hidden rights grabs, zero mandatory sequel options, and 100% author retention of copyright and net retail proceeds.

Internally and across studio commissions, British Noble maintains a dignified, harassment-free environment providing equal opportunity regardless of race, ethnicity, nationality, sex, gender identity, sexual orientation, religion, disability, neurodivergence, age, or socio-economic background.

6. Conflicts of Interest, Print Tenders & Impartiality

British Noble personnel must act impartially in the best interests of our customers and the organisation, avoiding any situation where personal financial, outside employment, or familial relationships conflict (or reasonably appear to conflict) with objective operational judgement. Employees and directors must disclose promptly in writing to Legal@BritishNoble.com and recuse themselves from procurement or commercial decisions involving: (a) personal or immediate-family equity stakes exceeding one percent in any offset printer, paper merchant, bindery, ERP consultancy, or competing publishing software vendor; (b) undisclosed paid advisory roles, board seats, or literary-agency representation agreements with subscribing imprints; or (c) steering British Noble Press print runs toward a bindery for personal favour rather than objective print quality, FSC chain-of-custody verification, turnaround reliability, and transparent cost.

All offset print tenders exceeding GBP 25,000 (or currency equivalent) require documented multi-printer competitive quotes evaluated against a standardised technical scorecard stored in the procurement audit log.

7. International Trade Sanctions, AML & Anti-Tax-Evasion Controls

British Noble complies strictly with economic sanctions, export controls, and anti-money-laundering (AML) statutes administered by the UK Office of Financial Sanctions Implementation (OFSI), the European Union, the US Office of Foreign Assets Control (OFAC), the UN Security Council, and the UAE Executive Office for Control and Non-Proliferation. Automated screening verifies commercial counterparties, institutional buyers, and cross-border royalty payees against consolidated restricted-party lists prior to treasury onboarding while respecting statutory informational-materials exemptions strictly where applicable by law.

Pursuant to the UK Criminal Finances Act 2017, British Noble maintains zero tolerance for the criminal facilitation of domestic or foreign tax evasion by any employee, contractor, literary agent, partner, or supplier. All royalty disbursements require verified tax residency documentation (W-9, W-8BEN, W-8BEN-E, or local statutory equivalents), matching beneficiary bank account ownership, and immutable general-ledger audit trails.

8. Antitrust Compliance & Ethical Market Conduct

British Noble competes solely on engineering quality, reliability, and publishing service craft in full compliance with the UK Competition Act 1998, Articles 101 and 102 of the Treaty on the Functioning of the European Union (TFEU), and US Sherman and Clayton Antitrust Acts. Covered Parties must never enter into formal or informal understandings with competitors to fix software or studio pricing, coordinate discount floors, rig public university or ministry tenders, allocate geographic territories or publishing segments, or exchange confidential competitor pricing decks, including during trade-association panels or international book fairs in London, Frankfurt, New York, Bologna, and Sharjah.

Competitive intelligence is gathered exclusively from publicly published documentation, open standards bodies, and voluntary customer feedback without ever soliciting another vendor's NDA-protected materials.

9. Pre-Publication Embargo Integrity & Insider Information

Personnel and prepress partners handling unreleased manuscripts (particularly corporate histories, central-bank economic monographs, investigative reporting, prize shortlists, and high-profile memoirs) act as fiduciaries of strict embargo secrecy. Leaking unreleased titles, chapter contents, jacket proofs, advance figures, or literary-prize jury deliberations to journalists, social networks, retail forums, or external contacts is treated as gross misconduct resulting in immediate dismissal or contract termination alongside civil and statutory remedies.

Furthermore, under UK Market Abuse Regulation (UK MAR), EU MAR, and US SEC insider-trading statutes, no Covered Party may purchase, sell, or advise any third party to trade securities or financial instruments on the basis of material non-public information encountered inside an unpublished manuscript, acquisition P&L, or publisher workspace.

10. Tiered Supplier Due Diligence, Audits & Remediation Matrix

British Noble enforces proportionate, risk-tiered compliance verification across our physical manufacturing and digital supply chains:

11. Confidential Speaking-Up Channel & Strict Non-Retaliation

Every employee, author, publisher user, print-plant worker, or partner who suspects an actual or potential breach of this Code, labour abuse, bribery, accounting irregularity, or embargo violation is encouraged to report it promptly to our Corporate Governance & Ethics Desk at Legal@BritishNoble.com (marking the subject line CONFIDENTIAL ETHICS DISCLOSURE for direct routing to General Counsel and the Chair of Risk & Audit).

In full alignment with the UK Public Interest Disclosure Act 1998 (PIDA), EU Whistleblowing Directive (EU) 2019/1937, and US federal whistleblower protections, British Noble guarantees absolute non-retaliation: no individual reporting a concern in good faith shall ever suffer dismissal, demotion, contract cancellation, blacklisting, or harassment, even if subsequent investigation determines the concern was mistaken. Disclosures are acknowledged within forty-eight (48) hours and investigated impartially under strict confidentiality.