Code of Ethics

Summary

 Our code of ethics is based on principles that apply to those who hold public office and sets
out the standards we expect of you in your working life.

 You have a duty to comply with this code of ethics, act in good faith and not misuse your
position in any way.

 The code also includes specific duties relating to conflicts of interest, bribery including gifts
and hospitality, Personal Account Dealing, improper conduct and political activity.

Introduction

Our code of ethics sets out the standards we expect of you in your working life. The Code covers a
number of Compliance responsibilities that all staff should adhere to.

The code applies to all colleagues – employees, agency workers, seconded employees, contractors, and
consultants, who work with us whatever their employment status. Board members are subject to a
separate code of ethics.

The code forms part of your terms and conditions of service. It doesn’t deal with issues such as neglect
of duty, failure to obey a reasonable instruction or other forms of misconduct, which are covered by
our disciplinary policy.

Questions about the Code should be directed to the Compliance and Ethics team in the first instance.

The detail

The code is based on principles that apply to those who hold public office. These principles are:

 Selflessness. You should take decisions only in terms of the public interest, and not to gain
financial or other material benefits for yourself, your family or friends.
 Integrity. You should not place yourself under any financial or other obligation to outside
individuals or organisations that might influence how you perform your official duties.
 Objectivity. In carrying out public business including making public appointments, awarding
contracts, or recommending individuals for rewards and benefits, you should make choices on
merit.
 Accountability. You’re accountable for your decisions and actions to the public and must
submit yourself to whatever scrutiny is appropriate to your office.
  Openness. You should be as open as possible about all the decisions and actions you take. You
should give reasons for your decisions and restrict information only when required by law or
when the wider public interest clearly demands it.
 Honesty. You have a duty to be truthful, declare any private interests relating to your public
duties and to take steps to resolve any conflicts arising in a way that protects the public
interest.
 Leadership. You should promote and support these principles by leadership and by setting an
example.

Further details can be found at www.gov.uk, seven principles of public life.

The process

General duties and responsibilities

You have a duty to:

 comply at all times with the code of ethics and with any other rules relating to the use of public
funds
 perform your role reasonably and in accordance with the law
 recognise the ethical standards governing your profession
 act in good faith and in the best interests of the organisation
 not misuse your position or information you have access to in the course of your role for
personal gain or for political purpose, and
 not seek to use your role to promote private interests or those of people, firms or other
organisations you are connected to.

Each new member of staff is given the code upon joining and will receive details of any amendments
thereafter. These amendments may come through annual updates and be published on the intranet.
Each member of staff will be expected to confirm that they understand the Code and adhere to it at all
times. This will be completed on an annual basis and failure to comply may result in action being taken
under the disciplinary policy.

Specific responsibilities

Conflicts of interest

You’re entitled to conduct your own affairs in privacy, however your work must be carried out free from
any suggestion of improper influence. Conflicts of interest must be identified as soon as they arise so
they can be managed properly.

What is a conflict of interest?

A conflict of interest happens when your work for us could be affected by a personal interest or
personal association. It becomes significant if an independent third party might reasonably take the
view that there is a risk that our actions, or those of a personal associate, might be affected, whether or
not they are in fact affected.

Page 2 of 5
General principles
You must take steps to make sure that any personal interest or association you have doesn’t affect a
decision taken by the organisation. You must disclose all interests which could conflict with your duties
or our work.

You must not exploit, or appear to exploit, to your personal advantage, any personal or professional
relationships with an authorised individual or an employee of a relevant organisation.

Requirements for disclosure of interests

You have a duty to declare to your manager and notify the Compliance and Ethics team of any potential
conflict of interest that arises whenever it becomes relevant, for example at meetings or during
discussions.

Further details are described within our Conflicts of Interest Policies, available on the Intranet or from
the Compliance and Ethics team.

Bribery (including Gifts and Hospitality)

You will perform your role in an honest and ethical manner and take a zero-tolerance approach to
bribery and corruption. You will also commit to acting professionally, fairly and with integrity in all your
business dealings and relationships wherever we operate and to implementing and enforcing effective
systems to prevent bribery. For full details please refer to the intranet for the Anti-Bribery Management
policy. In addition, you must be cautious about accepting gifts and hospitality that could be grounds
for suggestion of undue influence. For full details please see the Gifts and Hospitality Policy on the
intranet.

Personal account dealing transactions

Throughout your day-to-day work you have access to information that is not available to the public. If,
for example, you were to use this information to buy or sell shares ahead of a transaction this may be
considered insider trading which is a criminal offence.

Therefore in both your own and the organisation’s interests it is essential that proper arrangements are
in place to allow both parties to show that your investment decisions have not been influenced by
confidential information available in the course of your work.

You must always seek prior approval to deal in shares and related investments. To do this, you
need to complete the “Application to Undertake a Personal Account Deal” form and get signed approval
in advance. This form is available on the intranet or from the Compliance and Ethics team.

YOU MUST NOT COMPLETE A DEAL BEFORE CONFIRMATION HAS BEEN GIVEN OR IF
CONFIRMATION IS REFUSED.

You must make sure you read, understand and comply with the Personal Account Dealing Policy. This
can be found on the intranet.

Page 3 of 5
Information Handling

While you’re employed by us or at any time after you leave, you must not use or disclose to any other
person, for any reason other than carrying out your duties, any confidential or sensitive information
belonging to the organisation. This also applies to any disclosure relating to any third party where we
have a duty of confidentiality.

The release of confidential information can be a Criminal offence of insider trading and/or other
offences under the Criminal Justice Act or the Pensions Act 2004 where this relates to Restricted
Information.

You must read, understand and comply with the Handling of Material Non-Public Information Policy,
which is available on the intranet.

Improper conduct

In line with the Whistleblowing Policy, you should raise any concerns you have if you believe that you’re
being asked to act in a way that is:

 illegal, improper or unethical

 in breach of a professional code
 possible maladministration, fraud or misuse of public funds, or
 otherwise inconsistent with this code

For further details please see the Whistleblowing Policy on the intranet.

You should also report:

 any evidence of any criminal or illegal activity

 if you become aware of other breaches of this code, or
 if you’re asked to act in a way which raises a fundamental issue of conscience.

Political activity

As an organisation we have to maintain political neutrality so with that in mind you’re not permitted to
occupy a paid post in a political party or a high-profile unpaid post. Beyond that you can take part in
political activities provided you are conscious of your public responsibility and exercise proper
discretion, particularly in regard to the work we do. You should not make political speeches or engage
in political activities that directly affect your work.

If you have any queries about your political activity you should talk to your line manager, HR or the
Chief Executive.

Clarification of responsibilities

If you are in any doubt about any part of this code of ethics, you should discuss it with your line
manager or Compliance and Ethics team.

Page 4 of 5
Related documents/additional guidance

 Disciplinary Policy
 Anti-Bribery Management Policy
 Conflicts of Interest Policy (Inventory)
 Gifts and Hospitality Policy
 Personal Account Dealing Policy
 Handling of Material Non-Public Information Policy
 Whistleblowing Policy

Document control

Reviewer Angela Pocock, Senior HR Business Partner

Date March 2021
Reason for (re)issue Updated Review Date
Approved by Sue Hall, Director of HR & OD
Date March 2021

Page 5 of 5