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Gemini is committed to doing business in an ethical way

Ethics code - our approach to business ethics

Gemini is committed to doing business in an ethical way. To achieve this goal, we have an established ethics code that underpins our day-to-day strategic decisions, management and professional practices.

This includes a strong focus on the ethical behaviour of our employees and on conducting ethical relationships with our clients, suppliers and sub-contractors.
Ethics and compliance are fully embedded in the culture of our business at all levels, and our strict ethics code of conduct is championed at Board level. Our strong ethical policy incorporates a zero tolerance approach.

Specific ethical actions within the business include:

  • Full communication of Ethics, Compliance and Whistleblowing policies to every employee.
  • Line management responsibility for re-iterating ethical principles and role modelling our Ethics and Compliance Policy across the business.

As a company we are aware of our responsibilities and Gemini Rail Group actively encourages its employees to respect and observe the principles detailed below. This Code applies to all employees.

This Code is based on five ethical Principles and core values, which constitute the main domains of responsibility, within which ethical issues are considered.

The manner in which they apply and the contexts that they apply in will inevitably change over time

Our five five ethical Principles and core values are:

  • Be reliable & trustworthy
  • Collaborate
  • Demonstrate passionate commitment
  • Demonstrate competence
  • Be a great professional partner

Each Principle is described in a statement of values, reflecting the fundamental beliefs that guide ethical reasoning, decision-making and behaviour.

Be reliable & trustworthy

  • Model personal ownership
  • Demonstrate honesty & integrity at all times
  • Be dedicated
  • Get a reputation for delivering your commitments


  • Be approachable, respectful & empathetic
  • Listen & have an open mind
  • Ask questions
  • Collaborate and achieve through team work

Demonstrate passionate commitment

  • Have a positive ‘can do’ attitude
  • Stay engaged
  • Go the extra mile
  • Face challenge with optimism

Demonstrate competence

  • Work smartly
  • Be proactive, flexible and embrace change
  • Become a subject expert
  • Be bold, innovative and constantly improve

Be a great professional partner

  • Look and carry yourself like a professional
  • Role model a strong work ethic
  • Set yourself high standards
  • Be loyal and committed

“Our approach to ethics and compliance underlines what we stand for as a business and as individual employees.”

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