Code of Conduct

SEATRIEVER INTERNATIONAL HOLDINGS LIMITED with its subsidiaries such as Illoom Balloon Limited, is a rapidly growing, innovative and entrepreneurial consumer goods business with offices in Cheshire, China and the USA. Our award-winning business was founded in 2006 following a successful pitch on UK TV show Dragons Den by our CEO, James Halliburton. We operate around the world and we pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organisation.

OUR VALUES – People are our most important asset. We value:

  • Trust and mutual respect
  • Integrity and professionalism
  • Teamwork and mutual support
  • Open communication
  • Initiative and creativity
  • Passion and resilience
  • Individual and social responsibility

OUR SUPPLIERS – To build strong, mutually beneficial relationships based on trust, co-operation, innovation and sustainability.

We will achieve success by:

  • Ensuring that all our actions add value and make our Company sustainable
  • Following the highest standards of social responsibility in everything we do
  • Developing the potential, motivation and commitment of every individual
  • Staying ahead by constantly developing innovative products and applications
  • Making decisions based on data, facts and analysis, working closely with operations, development and commercial teams
  • Achieving defined quality standards to satisfy all our customers

Why the code matters:

Ethical behaviour is the key to sustaining our reputation and ensuring the financial success of our business and is the foundation of our compliance with laws and Group policies. Our aim is to avoid any situation where our actions undermine our reputation or contravene public standards.

In doing so we will avoid costly fines and even more costly breaches of trust. In short, ethical behaviour is a vital part of our future as a successful company.

This document sets out the high standard of behaviour we expect from ourselves and from others. We want to be the best business we can possibly be, which means going above and beyond the minimum legal requirements to really set us apart.

Complying with the Code is not voluntary; everyone at every level must take its message to heart. Similarly, any breaches of the Code will not be tolerated and may lead to disciplinary action, dismissal and in the very worst cases, criminal prosecution leading to a fine or even imprisonment.

Finally, this Code establishes the minimum standards of behaviour we expect in all our operations around the world.


As a company, we are committed to:

  • complying with the laws of the countries in which we work
  • respecting the traditions and cultures of the countries in which we work, while making sure we give priority to our own higher standard of behaviour
  • understanding and implementing the Group’s internal policies, procedures and guidelines that relate to our areas of responsibility
  • making every business transaction with customers, suppliers and other partners even-handed and honest.
  • Commercial interests must never influence our ethical behaviour.

Health and Safety

We aim to provide a clean, healthy and safe working environment that reflects best practice in our industry. We can all play our part in achieving this by ensuring we report all incidents. We believe all accidents can be prevented. That starts with taking all reasonable precautions to avoid injuring ourselves, our colleagues and members of the public.

Human Rights

We take our corporate social responsibilities seriously and are committed to supporting internationally agreed human rights. Any human rights concern you raise will be treated in the utmost confidence.

We only work with suppliers who share our beliefs. Before doing business with new partners we undertake a full review of their ethics, business practices and human rights standards.

Our commitment to human rights and employee standards guarantees you the treatment you have every right to expect. The result strengthens our business by creating a more effective, motivated and committed workforce.


We care about the environment and where possible, attempt to integrate sustainability considerations into our business decisions. As a minimum, we comply with all relevant country-specific laws and regulations. Where relevant we take additional internal steps to meet our sustainability objectives, protect the environment and reduce any impact.

Employment rights

We believe that promoting a diverse workforce where everyone is treated equally can only strengthen our Company. Consequently, we are committed to eliminating work-related discrimination on the basis of:

  • Race
  • Colour
  • Creed
  • Nationality
  • Age
  • Marital/partnership status
  • Pregnancy and maternity
  • Gender
  • Gender reassignment
  • Sexual orientation
  • Religion or other beliefs

We will:

  • provide a safe and healthy working environment by minimizing the causes of hazards
  • comply with the laws and regulations relating to employment in every country in which we operate
  • offer pay and employment terms of at least the legal or national industry minimum standard
  • comply with national employment law on working hours, and not require employees to work excessive standard hours on a regular basis
  • not engage or support forced labour. We won’t employ young people under the age of 15, or older if defined by law
  • ensure that recruitment is based purely on ability, creating a diverse workforce that reflects our international structure and the variety of the communities in which we operate
  • implement regular employee consultation and communication on each site to meet the specific needs of the business and its employees
  • provide learning and development resources so that employees can work safely and reach their full potential
  • respect the rights of employees to join, or not to join, a trade union of their choice. We will also provide facilities that enable recognized employee representatives to carry out their roles effectively, including collective bargaining in accordance with arrangements in each country. If country legislation or collective agreements go above our minimum standard, we will follow these
  • communicate with employees in an open and honest way. We do not tolerate abuse, harassment or intimidation under any circumstances. We also guarantee you can raise any concerns you have without fear of retaliation.

Freedom of Association and Right to Collective Bargaining

We recognise and respect the right of employees to full freedom of association and collective bargaining.

We respect the rights of employees to engage in lawful activities related to forming, joining, or assisting a workers’ organization, or to refrain from doing the same, and will not discriminate or punish workers for exercising these rights.

We implement collective bargaining agreements where they exist. Where necessary, we negotiate with lawfully established workers’ organizations and/or duly selected representatives in good faith and with the best efforts to reach a collective bargaining agreement.

Money Laundering Prevention

We are committed to comply fully with all money laundering legislation globally.

Anti-Bribery and Corruption

We comply with all anti-bribery regulations around the world.  While we acknowledge the temptation to achieve short-term success through bribery and corruption we never put the financial success of our business above our commitment to ethics and legal behaviour. Therefore, we never accept, request or give bribes under any circumstances.

Gifts and Hospitality

Remember that you are acting on behalf of the Group when building relationships with customers, suppliers and other business partners. Use your judgment to ensure you are never influenced or offered a personal advantage.

We understand that gifts and entertainment may play a role in building relationships. However, we must only offer or accept gifts if there is no improper intent and we must remember that gifts and hospitality can easily be perceived as a bribe regardless of their value. Our Gifts and Hospitality policy rules out:

  • Anything intended to influence our professional objectivity
  • Anything that might embarrass the recipient or the Company
  • Anything in bad taste or sexually orientated
  • Anything that the recipient may not accept under local law, their Company policy, or their ethics code
  • Cash or cash equivalent as a gift

Our position is simple: we must not give or accept gifts or hospitality that could be construed as a bribe, kickback or payoff. We encourage our customers, suppliers and other business partners to adopt principles similar to these.

Conflict of Interest

We are all responsible for acting in the best interests of the Group, therefore it is essential we avoid any conflicts of interest that may damage the business.

We never allow interests, activities or investments to affect our performance or judgment.

We must never hold any direct or indirect financial interest in, make any loan to, or derive any benefit from a competitor, customer or supplier unless the interest is disclosed in writing to the head of the relevant business unit who judges that the interest does not present a material conflict or appearance of conflict. It is essential any such decision is recorded in writing.

Employees are free to participate in civic, charitable, political or professional activities provided these activities do not interfere with their business duties.

Competition Compliance

Competition is an integral part of doing business. However, it is essential we maintain the highest possible standards of integrity. Everyone must comply with the competition laws, and practice the highest standard of behaviour, in every country in which we operate.  Our ethical conduct should never be compromised; even to win a contract, meet sales targets or to keep a customer. If you do breach competition and anti-trust laws you could face severe penalties, including large fines and prison sentences.

Competition Law is international and applies in every country and jurisdiction. Compromising our ethics to win a contract is absolutely forbidden, while breaching competition and antitrust laws can have severe legal penalties, including large fines and prison sentences.

Internal Communications

We are committed to open, honest and timely communications to create an inclusive and supportive work place where everyone can reach their full potential.

Accuracy and Integrity of Group Records

We are committed to producing accurate and transparent accounting records that accurately represent the financial position and operating results of each Group company.

We will:

  • ensure the Group’s financial records accurately reflect all transactions
  • never engage in any conduct, or make any arrangement, that results in a false or artificial entry in any Group record, including employee expense reports
  • never make payments on behalf of the Group that may be used for a purpose other than as described in the supporting documents
  • never establish an undisclosed or unrecorded fund or asset for any purpose. The Group will record and report all transactions, including those where payment is made in cash
  • make sure the Group never knowingly evades tax obligations. All taxable benefits to which employees are entitled, or which employees obtain, will be listed and declared for tax purposes
  • make sure all Group records are protected and retained in accordance with Group policy and the law

Protecting Confidential Personal Information

We make sure all personal data is managed in a legal, secure, effective and confidential manner.

That means all personal data must be obtained and processed lawfully and stored securely, whether in manual or digital form. It should be accessible by a strictly limited number of people who have a legitimate reason to see the data, and controlled by appropriate security measures. We also undertake to update such data as circumstances change and dispose of data when it is no longer needed.

If you are responsible for managing or using information systems that hold personal data, you must abide by relevant local laws. You must also ensure that personal data is kept confidential, processed in a secure manner and is used only for its intended purposes.