Business ethics, and anti-bribery and corruption policies

As a Group we aim to act responsibly and ethically in all of our business dealings.

Through our ethics policy we aim to instil the highest standards of business behaviour across the Group and we focus on embedding a culture of ethical compliance so that all of our people understand the standards of ethical business practice that are expected of them. As well as protecting the reputation of the Group and safeguarding the investment of our shareholders, the business ethics policy aims to protect the interests of every employee by ensuring legal and regulatory compliance in all jurisdictions where the Group operates, as well as promoting responsible behaviour across the Group.

The Group has an established anti-bribery and corruption policy and has introduced a compliance programme which has the support of the Board and senior management within the Group. The programme includes communication of the statement and policy, training, risk assessment, monitoring and review processes. Employees assessed to be at risk are required to complete the training and to self-certify that they understand and agree to be bound by its provisions. By the end of 2017, over 1,000 employees had undertaken this training.

The Group does not permit bribery, nor illegal or corrupt business practices and our whistleblowing procedure allows employees to raise any malpractice concerns they may have in an appropriate forum without fear of recourse. On-going compliance is monitored by local compliance officers who are required to report to their local boards and to the Group Compliance Officer on at least a biannual basis. The Compliance Officers are responsible for ensuring that risk assessments, training and awareness are carried out where appropriate and are kept up to date. They are also required to monitor, record and report agency arrangements with third parties to ensure that all our business dealings are appropriate and within our ethical framework.