We have a wide range of policies in place across all of our divisions to ensure that our staff and management comply with all regulatory requirements and adhere to the highest professional and ethical standards in dealing with our customers, suppliers and each other. These include:
Our Dignity at Work Policy outlines the type of behaviour that the company considers to be unacceptable and to explain what solutions there are if any employee has experienced or believes someone else has experienced any discrimination, harassment or bullying at work.
We encourage our employees to report any activity that may constitute a violation of laws, regulations or internal policy, and reporting channels are provided to staff for this purpose within the framework of a whistle-blowing policy.
Our comprehensive whistle-blowing procedures comply with the rules that came into effect in September 2016. We have enhanced the existing policies by the appointment of a whistle-blowers’ champion and a confidential telephone whistle-blowing service, operated by a third party provider.
Our Health and Safety Policy ensures that we continue to provide a safe and healthy working environment for our employees and visitors in accordance with The Management of Health and Safety at Work Regulations 1999. The Health and Safety Committee continues to meet on a quarterly basis and we are proud of the ongoing progress in successfully raising the profile of health and safety across the business. This year we recorded 30 incidents across all of our sites, of which only two were reportable. We continue to use an online risk assessment tool to manage site-specific risks as appropriate and our Display Screen Equipment risk assessment programme.
Monitoring and enhancing our systems and controls to safeguard customers’ data and protect our business remains a high priority, and we continue to invest in expertise and technology to strengthen our internal capabilities. We also remain a member of the government’s Cyber Security Information Sharing Partnership, which provides early warning of potential system failure or cyber-attack and allows intelligence sharing across the industry.
We have implemented policies and procedures in accordance with anti-money laundering regulations and have dedicated money laundering reporting officers where required.
We operate a zero-tolerance approach to bribery and corruption, ensuring compliance with all applicable anti-bribery and corruption laws and regulations, including the UK Bribery Act 2010.
The board gives due regard to human rights considerations, as defined under the European Convention on Human Rights and the UK Human Rights Act 1998. We are aware of our responsibilities and obligations under the Modern Slavery Act, with the appropriate policies and training in place to ensure compliance across the organisation. The Banking division has also committed to the CIPS Ethical Code of Conduct, which supports our commitment to ensure modern slavery does not exist within our supply chain. Further details of our compliance with the Modern Slavery Act can be found here.
We are committed to complying with our tax obligations and doing so in a manner consistent with the spirit as well as the letter of tax laws. This includes a transparent and cooperative relationship with the tax authorities. Our tax obligations arise mainly in the UK where our operations and customers are predominantly based. Our straightforward business model reduces the complexity of our tax affairs and helps us maintain a lower risk tax profile. Further details of our approach to tax can be found here.