Ethics and Compliance Policies

Introduction

Lumin People Ltd ("Lumin People", "we") is a UK registered executive search firm placing senior finance, commercial, legal and C-suite leaders with energy and infrastructure businesses, mainly in the United States. These four policies set out how we expect everyone working for or on behalf of Lumin People to behave, and what we are doing to reduce our environmental impact.

Who these policies apply to: all directors, employees, contractors, associates and anyone else acting on behalf of Lumin People, wherever they are working (together, "our people").

Policy owner: James Feeney, Founder and Director, is responsible for these policies, for answering questions about them and for making sure they are followed.

Review: the policies are reviewed at least once a year, and sooner if the law or our business changes. Everyone joining Lumin People reads and confirms they understand them as part of onboarding.

Effective date: 1 April 2025

Next review: April 2027

Approved by: James Feeney, Director

1. Anti-Bribery and Anti-Corruption Policy

Lumin People has zero tolerance for bribery and corruption in any form, in any country, whether it involves public officials or private businesses. We win and place on the quality of our work and our candidates, never on improper payments or favors.

1.1 The law we follow

As a UK company working mainly in the US, we comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977 (FCPA), US federal and state commercial bribery laws, and the anti-corruption laws of any other country we work in. Where these laws differ, we follow the strictest standard.

1.2 What is prohibited

Our people must never, directly or through anyone else:

offer, promise, give, request or accept a bribe, meaning anything of value intended to improperly influence a business decision or reward improper behavior
offer or pay anything of value to a public official to obtain or keep business or any advantage
make facilitation payments (small unofficial payments to speed up a routine government action), even where they are customary locally
offer a client employee, hiring manager or decision maker any payment, kickback, fee share or personal benefit in return for engaging Lumin People, selecting one of our candidates or approving an invoice
accept any payment or benefit from a candidate in return for being put forward for a role; candidates never pay Lumin People for placement
use agents, referrers or other third parties to do anything we are not allowed to do ourselves
hide, disguise or falsely record any payment in our books and records

1.3 Gifts and hospitality

Reasonable, proportionate hospitality (for example a business lunch with a client or candidate) is a normal part of building relationships and is allowed when it is:

given or received openly, not secretly
modest in value and not lavish or frequent
not cash or a cash equivalent such as a gift card
not offered during a live tender, fee negotiation or hiring decision where it could look like an inducement
permitted under the recipient's own company rules

Any gift or hospitality given or received worth more than £100 / $125 per person must be approved in advance by the Director and recorded in the Gifts and Hospitality Register. Anything offered to a public official needs prior written approval, whatever its value.

1.4 Referral fees and third parties

Candidate or client referral payments are only made under a written arrangement agreed in advance, are recorded accurately, and are never paid to anyone employed by the client involved in the hiring decision. Before working with any agent, subcontractor or partner who acts on our behalf, we carry out proportionate due diligence and make sure they agree to act in line with this policy.

1.5 Political and charitable contributions

Lumin People does not make political donations. Charitable donations are made only to registered charities, openly, and never to influence a business decision.

1.6 Records

We keep accurate books, invoices and expense records showing the true nature of every transaction. All expenses must be supported by receipts and a clear business reason.

1.7 Reporting and consequences

Anyone who is offered or asked for a bribe, or suspects bribery, must report it straight away under the Confidential Reporting Procedure in Section 3. Breaching this policy is treated as gross misconduct and may lead to dismissal or termination of any contract, and may be reported to the relevant authorities. Nobody will suffer any detriment for refusing to pay or accept a bribe, even if it means Lumin People loses business.

2. Code of Ethical Conduct: Harassment, Discrimination and Equal Opportunity

Everyone who works with Lumin People, whether a colleague, client or candidate, is entitled to be treated with dignity and respect, free from harassment, discrimination, bullying and victimization. As a search firm, this matters twice over: it governs how we treat each other and how we treat every candidate we represent.

2.1 The law we follow

We comply with the UK Equality Act 2010 and the Protection from Harassment Act 1997, and in the US with Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Equal Pay Act, and applicable state and city laws (including New York, Texas and Florida law), along with the equivalent laws in any other country where we operate.

2.2 Equal opportunity

We do not discriminate on the basis of age, race, color, ethnic or national origin, nationality, religion or belief, sex, sexual orientation, gender identity or reassignment, marriage or civil partnership, pregnancy or maternity, disability, genetic information, military or veteran status, or any other characteristic protected by law.

This applies to hiring, pay, training, promotion and every other part of working at Lumin People. It also applies to our search work:

candidates are assessed only on their skills, experience and suitability for the role
we will not act on any client instruction to exclude or prefer candidates because of a protected characteristic, and we will challenge such a request
we will not ask candidates for protected information unless required by law, and we will not share it with clients without consent
we follow applicable salary history bans and pay transparency rules when discussing compensation
we make reasonable adjustments for candidates with disabilities during interviews and assessments when asked

2.3 Harassment and bullying

Harassment is unwanted conduct related to a protected characteristic that violates someone's dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. Sexual harassment is unwanted conduct of a sexual nature with the same effect. Bullying is offensive, intimidating or insulting behavior, or abuse of power, that undermines or humiliates someone.

Examples of unacceptable behavior include:

unwelcome sexual advances, touching, comments, jokes or messages
offensive remarks, slurs or "banter" about someone's background, appearance or identity
sharing offensive images, emails or social media content
shouting, threatening, excluding or repeatedly criticizing someone unfairly
treating someone badly because they rejected advances or made a complaint

This applies at work, at client and candidate meetings, at work events, while travelling, and online, including email, messaging, video calls and social media. Lumin People takes reasonable steps to prevent sexual harassment, including by clients, candidates and other third parties.

2.4 Wider standards of conduct

Our people are also expected to:

be honest and accurate in all dealings, never misrepresenting a candidate's experience to a client or a role to a candidate
treat candidate and client information as confidential and handle personal data in line with UK GDPR, the Data Protection Act 2018 and applicable US privacy laws
obtain consent before submitting a candidate's details to any client
comply with call recording consent laws in each US state and country we call into
avoid conflicts of interest, and declare any personal relationship or interest that could affect a business decision
respect clients' agreed off limits and non solicitation terms
compete fairly and never share confidential information belonging to a former employer, client or competitor

2.5 Raising a concern

Anyone who experiences or witnesses harassment, discrimination or other unethical behaviour should report it under the Confidential Reporting Procedure in Section 3. If you feel able to, you can also raise it informally with the person involved. All complaints are taken seriously, investigated promptly and fairly, and kept as confidential as possible.

2.6 Consequences

Harassment, discrimination, bullying or victimization by any of our people will lead to disciplinary action, up to and including dismissal or termination of contract. Where a client, candidate or other third party behaves this way, we will take appropriate action, which may include ending the relationship.

3. Confidential Reporting and Non-Retaliation Procedure

Anyone working for or with Lumin People can report a suspected violation of law or of our policies confidentially, and anonymously if they prefer, without fear of retaliation. We would always rather hear about a concern early than not at all.

3.1 What can be reported

bribery, corruption, fraud or financial wrongdoing
harassment, discrimination, bullying or victimization
breaches of data protection or confidentiality, including misuse of candidate data
health and safety risks
any other breach of law, regulation or Lumin People policy
any attempt to cover up the above

You do not need proof, only a reasonable belief that something is wrong. Concerns can also be raised by clients, candidates, contractors and suppliers.

3.2 How to report

Director: report to James Feeney, Director, by phone, in person or by email at hello@luminpeople.com, marking the subject line "Confidential".
Independent contact: if the concern involves the Director, or you are not comfortable raising it with him, report to Luke Grant or Jack Sharpe at Spirehouse Recruitment Ltd, shareholders in Lumin People, who will handle it independently.
Anonymous reporting: you can report anonymously in writing, by letter to Lumin People's registered office marked "Strictly Confidential" or from a personal email address that does not identify you. Please give as much detail as you can, as we cannot ask follow up questions of an anonymous reporter.

A report should include what happened, when and where, who was involved, and any documents or witnesses that might help.

3.3 What happens next

We acknowledge the report within 5 working days.
The person handling it assesses the concern and decides how it will be investigated, which may include using an independent investigator.
The investigation is carried out promptly, fairly and impartially. Anyone involved in the concern takes no part in investigating it.
Where appropriate and lawful, we tell the person who raised the concern the outcome, normally within 30 days, or explain why it is taking longer.
We take whatever action is needed to put things right, which may include disciplinary action and reporting to the authorities.
A confidential record is kept of every report, the investigation and the outcome.

3.4 Confidentiality

The identity of anyone who raises a concern is shared only with those who need to know to investigate it, unless the person agrees otherwise or the law requires disclosure. Reports and investigation records are stored securely and handled in line with data protection law.

3.5 No retaliation

Lumin People strictly prohibits retaliation against anyone who raises a concern in good faith or helps with an investigation, even if the concern turns out to be mistaken. Retaliation includes dismissal, demotion, loss of work or contracts, reduced pay, harassment, threats or exclusion. Anyone who retaliates will face disciplinary action up to dismissal or termination of contract. Deliberately making a false report is itself misconduct.

This protection reflects the UK Public Interest Disclosure Act 1998 and US whistleblower protections, including those under the Sarbanes-Oxley Act, the Dodd-Frank Act and Title VII.

3.6 External reporting

We hope our people will feel able to raise concerns internally first, but nothing in this procedure stops anyone from reporting to an outside body or seeking advice. This includes the whistleblowing charity Protect, Acas, the relevant UK prescribed person (such as the Information Commissioner's Office or the Serious Fraud Office), the US Equal Employment Opportunity Commission, the US Securities and Exchange Commission, state human rights agencies, or law enforcement. No agreement with Lumin People prevents anyone from making a protected disclosure.

4. Environmental Policy

Yes, Lumin People has goals and programs to reduce its carbon footprint. As a small, digital first search firm placing leaders into the energy transition, our main sources of emissions are business travel, electricity for our offices and IT equipment, and the small amount of waste we generate. We focus our efforts there.

4.1 Our commitments

Travel: we work remotely by default and use video calls for candidate interviews, client meetings and internal meetings. Travel between the UK and the US is limited to essential trips, and no more than six per year, with several client meetings combined into each trip, economy class flights, and rail or shared transport used in place of driving or domestic flights where practical.
Electric vehicles: all company vehicles are fully electric.
Paperless operations: CVs, contracts, terms of business, invoices and signatures are handled electronically. We do not print candidate materials or marketing.
Waste and equipment: we recycle paper, packaging and other office waste, keep laptops and phones in use for as long as practical, and dispose of old electronics through certified recycling (WEEE compliant in the UK) after secure data wiping.
Suppliers: where we have a choice, we prefer suppliers with clear environmental commitments.

4.2 Goals

Measure our carbon footprint (the greenhouse gas emissions from our travel, vehicles and electricity use). Target: First baseline calculated and shared with clients on request. Timing: By 31 March 2027, then annually
Business travel emissions. Target: 25% reduction per placement against the 2026 baseline. Timing: By end of 2028
Company vehicles. Target: All company vehicles remain fully electric. Timing: Ongoing
Paperless operations. Target: Zero printed candidate or client documents. Timing: Ongoing
Electronic waste. Target: 100% of retired IT equipment recycled or refurbished through certified providers. Timing: Ongoing
Net zero. Target: Commit to net zero operational emissions, with a plan set once the baseline is in place. Timing: Plan set by end of 2027

4.3 Responsibility and review

The Director is responsible for this policy and for tracking progress against the goals above. Progress is reviewed every year as part of the annual policy review, and the results are shared with clients who ask for them.