Code of Ethics Policy

Introduction

1.1. The Company is committed to ensuring a fair and ethical working environment and the rights of our
colleagues are respected by the implementation of the Code of Ethics Policy.

Overview

2.1. The Code of Ethics Policy defines the broad principles with which we seek to conduct business and
the behaviours we expect from our colleagues, contractors, vendors, suppliers and partners.

2.2. Our policy is informed by the Institute of Business Ethics Organising for Ethics discussion paper

Responsibilities

It is the responsibility of all line managers to:

    • Be familiar with this policy
    • Be professional and supportive of employees

It is the responsibility of our colleagues to:

    • Be familiar with this policy
    • Follow the procedure in terms of keeping the company informed

It is the responsibility of the People Team to:

  • Maintain this policy and communicate any changes
  • Provide advice & guidance
  • Ensure that this policy and procedure is implemented effectively, in a consistent and fair
    manner

Principles

4.1. These are the principles that are supported by our Code of Conduct and that inform our other
policies:

  • Competence and accountability: take ownership for the quality of your work and your own
    skills development.
  • Environment: minimise our negative impact on the planet.
  • Integrity and honesty: tell the truth and avoid conflicts of interest.
  • Lawfulness: follow the law and ask for expert advice if unsure.
  • Respect for others: treat people as you want to be treated. Make sure you’re objective and fair
    and don’t discriminate against others.
  • Teamwork: collaborate, share your skills and knowledge, and ask for help.

Context

5.1. The Code of Conduct explores how all of these principles should be supported through individual
behaviour. The table below lists other policies and guides that respond to different principles:

Competence &
accountability
Code of Conduct
Drug Alcohol & Other Substances Policy
Flexible Working Policy
Learning & Development Policy
Training Policy
Environment Carbon Reduction Plan
Environmental Policy & Procedure
Sustainable Procurement Policy
Integrity and
honesty
Anti-Bribery Corporate Hospitality Policy
Conflict of Interest Policy
Whistleblowing Policy
Lawfulness Anti-Bribery & Corporate Hospitality Policy
Health & Safety Policy
Respect for others Anti-Slavery Human Trafficking Policy
Equality, Diversity & Inclusion Policy
Harassment Policy
Health & Safety Policy
Teamwork Health & Safety Policy
Teamwork Code of Conduct
Guide to Home Working

Terms & Conditions

6.1. All contractual terms & conditions are unaffected by this policy.

6.2. Where an employee has any questions or queries in relation to the Code of Ethics Policy, they are
encouraged to contact the People Team.