Group Management Code
The Group Management Code articulates the standards that we expect everyone in the Group to meet. It includes the requirement to comply with laws, regulations and Group policies; the rejection of bribery and corruption; the promotion of ethical business practices; the fair treatment of customers; the confidentiality of information; and respect for our people, communities and the environment.
We raise awareness of the Group Management Code through our induction processes and all employees are required to abide by its precepts.
View our Group Management Code.
Anti-bribery and corruption
We expect the highest standards of conduct and integrity from all employees as well as third party distributors, agents and intermediaries. It is Group policy to conduct business free from bribery and corruption. We will not enter into contractual relationships with third parties who are known to engage in corrupt practices and will not be involved in giving or receiving bribes or favours.
Directors, senior manager and employees who have contact with customers or suppliers are required to undergo anti-bribery and corruption training, which is available in many languages, and pass an online test to demonstrate their understanding of the Group’s Anti-Bribery and Corruption Policy and its implementation. Our online ABC training module was completed by 317 employees in 2017, taking the total number of employees who have completed the training since its introduction in 2012 to 4,777. A further 659 employees completed an ABC refresher course during 2017.
View our Anti-Bribery and Corruption Policy.
Gifts, entertainment and hospitality
An online Gifts and Hospitality Register is maintained and all gifts and entertainment/hospitality given or received that exceed agreed levels (gifts exceeding £100 per person excluding sales tax, or entertainment/hospitality exceeding £250 per person excluding sales tax) must be entered into the Register and approved by an appropriate line manager.
All gifts and hospitality given or received must comply with the Group Anti- Bribery and Corruption Policy.
View our Gifts, Entertainment and Hospitality Policy.
Competition laws are designed to promote free and fair competition. Where this is achieved, efficient and innovative organisations, like ours, prosper and customers receive the best products at the best price.
The Group expects the highest standards of conduct and integrity from all employees, no matter where in the world they operate. Competition laws apply to every aspect of our business and at every level: national, European and international. All Group employees (including temporary or contract employees and consultants) must comply with these laws: compliance is non-negotiable.
View our Competition Law Compliance Policy.
The Group supports the human rights principles set out in the Universal Declaration of Human Rights and the Core Conventions of the International Labour Organisation. We recognise that all individuals have the right to lead a dignified life, free from fear and want, and free to express independent beliefs. Our Group Human Rights Policy includes the right of all employees to equal opportunities and non-discriminatory treatment, security of person, a safe working environment and a fair wage. We also recognise the rights of children and reject the use of forced or compulsory labour.
View our Human Rights Policy.
Sanctions, embargoes and restrictions
Sanctions and embargoes are political trade restrictions put in place against target countries or individuals with the aim of maintaining or restoring international peace and security.
The Group Sanctions, Embargoes and Restrictions Policy explains how sanctions and embargoes work and how they affect the Group (and all of its operating companies) in respect of international trade. The policy details the different types of sanctions and embargoes and contains an overview of the laws of export control.
We comply with all sanctions and export regulations, including dual purpose regulations. Where we trade in countries that are subject to UN, EU, USA or other country sanctions we do not supply to proscribed persons and do not supply products subject to sanctions.
It is the responsibility of all employees to alert their manager to any breach of Group policies or procedures or any wrongdoings or dangers at work, including:
a) criminal activity;
(b) failure to comply with any legal obligations;
(c) miscarriages of justice;
(d) danger to health and safety;
(e) damage to the environment;
(f) bribery under our Anti-Corruption Policy and Procedures;
(g) financial fraud;
(i) material breach of our internal policies and procedures including our Group Management Code;
(j) material conduct likely to damage our reputation;
(k) unauthorised disclosure of confidential information;
(l) the deliberate concealment of any of the above matters; and
(m) bullying, harassment and discrimination.
If an employee has reasonable ground for believing that an infringement has occurred and does not receive a satisfactory response, or feels unable to voice the matter with his or her manager, he or she is able to contact the Company Secretary in Cheltenham and provide details. Alternatively, employees can report infringements through a confidential, multi-lingual, third party whistle-blowing helpline that is available to all employees. The Company Secretary ensures that any allegations are properly investigated and that the employment of the person reporting the infringement is protected appropriately.
View our Whistle-Blowing Policy.