ETHICS

Our success is underpinned by our strong commitment to ethical conduct in the way we do business. We expect our employees to uphold the high ethical standards set out in our Code of Conduct, and we have a zero tolerance policy on bribery and corruption.

To meet these high standards, we must create a culture where employees understand what we expect of them, to recognize their responsibility to raise concerns and have the confidence to do so.

Setting high standards
Our Code of Conduct outlines our expectations and provides guidance for employees on how to behave with their colleagues, customers, business partners and other stakeholders. It supports our Business Principles, which require employees to act with honesty, integrity and fairness. Anti-corruption guidance helps to ensure employees act in accordance with our principles and all applicable laws and regulations. This is supported by a program of training, compliance and monitoring to ensure consistency across the Group.

Training
Ethics training is mandatory for new hires, and employees across the Group receive regular refresher training through online learning, face-to-face sessions and team briefings. Additional online anti-corruption and bribery training is also being rolled out, with face-to-face sessions in high-risk markets.

Reporting concerns
All employees and contractors have a duty to report any suspected breaches of our Code of Conduct. We encourage employees to report potential violations of the Code to their line manager or human resources manager in the first instance, or they can contact Group Corporate Security department directly via email. Employees and contractors can also report concerns anonymously via our third-party confidential 24-hour telephone hotlines or online reporting system.

Taking action
We investigate reported concerns with an aim to resolve issues promptly and take appropriate disciplinary action. Any cases of fraud reported or affecting more than one local market are referred to Group Internal Audit and Group Corporate Security.