About Us

Code of conduct

The Board requires the highest standards of corporate governance, operational excellence and financial reporting throughout the Group and from all directors and employees.

In turn this demands that the Company, its directors and its employees operate in an honest, professional and ethical manner which is essential for our reputation as well as building trust and respect with our key stakeholders including customers, business associates, employees, communities and shareholders.

This Code contains the fundamental business principles that set these standards and guides our conduct across the Group and in our business dealings. The Company expects all business associates to follow the principles set out in the Code.

1. Conduct

The Board is committed to the highest standards of corporate governance, operational excellence and financial reporting throughout the Group and from all directors and employees, and requires that the Company, its directors and its employees operate in an honest, professional and ethical manner. We shall trade lawfully and properly at all times and, as a minimum, will comply with all laws and regulations.

2. Integrity

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. Accordingly no director or employee may:

• pursue any personal or business interests which could interfere or be seen to interfere with the business or interests of any member of the Group; or
• accept or provide gifts or entertainment which cause inappropriate influence over the recipient, or gives the appearance of doing so.

In particular, all directors and employees are required to disclose any substantial interest that they or their immediate family might have in our suppliers, customers or competitors. We do not tolerate any form of bribery in our business or in those we do business with and the Company has in place an anti-bribery and corruption policy reflecting the standards that we expect of our staff and those who perform services for us.

3. Customers

We are committed to treating our customers in an open, honest and fair manner (including selling products and services that fulfil their needs and meet the appropriate quality criteria in accordance with regulatory requirements) as well as operating an effective complaints process to address any issues that may arise.

4. Competition

We are committed to fair and competitive sales practices and to treating our business associates properly and fairly and in accordance with relevant competition laws. We will not engage in or be party to practices or agreements that would unfairly limit trade or exclude competitors from the market place.

5. Employees

We are committed to creating a safe and healthy environment for all employees and contractors. We promote diversity, fairness and respect in our working environment and do not tolerate any improper behaviour or harassment. We believe that our employees are central to the success of our business and are committed to their development and providing recognition based on success and achievement.

6. Information

We ensure the recording of all business transactions is complete and accurate, and we protect against inappropriate access or use of confidential and privileged information relating to the Group. We provide accurate and timely information to external stakeholders in compliance with relevant laws and regulations.

7. Environment

We comply with environmental protection laws, including recycling and waste disposal requirements, and seek to minimise detrimental effects that our activities may have on the environment.

8. Communities

We contribute to the communities in which we operate including local charities and operating work experience programmes for local schools. The Group also supports a number of national charities.

9. Crime prevention

We take the matter of fraud and financial crime extremely seriously, and have measures in place for detecting, preventing, reporting and investigating suspected fraud and financial crime. We have effective anti-fraud and anti-money laundering systems and controls as well as an anti-bribery and corruption policy in place in addition to effective claims management and counter-fraud capabilities. We also share data with appropriate industry bodies and government agencies.

10. Regulators

We are committed to engaging with our Regulators in an open, honest and transparent manner which is essential in order to build trust and promote the regulatory framework in which we operate.

11. Reporting

Any questions, concerns or alleged breaches in respect of this Code or any other matter may be raised by employees through line management or the Company’s human resources department, Whistleblowing Policy or Grievance Procedure. Business associates may also raise questions or issues through their relationship manager at the Company. All reports are treated confidentially and investigated promptly and properly.