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Code of Conduct
Regardless of which part of the Pennon Group you work in, we play a crucial role in the lives of our customers and partners who rely on us to make the right decisions day in, day out.
This Code of Conduct sets out the principles that we as a company believe should guide our actions. It’s designed to support all of us in everyday decision making while we carry out our day-to-day business.
It’s difficult to predict all of the different ethical dilemmas that we might encounter, so this Code won’t have the answers to every question. It will, however, act as your guide and first point of call when deciding what the right thing to do is.
A message from our Chief Executive
At Pennon we believe in doing the right thing above all else. This means your decisions will be supported when they've been made in line with this Code and our company values. We should also be clear that colleagues will not be punished or penalised for doing the right thing, and we do not tolerate retaliation against anyone who raises a concern about any Code of Conduct issue.
Could I ask that you familiarise yourself with the principles set out here and make sure that you consider them fully if you’re ever placed in a difficult or unethical situation. Both the Board and I have fully endorsed the Code of Conduct and expect that all of you will do the same.
Chris Loughlin Chief Executive Officer, Pennon
Mission Together we’ll build the most trusted environmental solutions company in the UK, providing infrastructure and services that enhance our customers’ lives, protect the environment and deliver growth for our shareholders.
Our Pillars
Safety first The safety of our employees, customers and communities comes first. We’ll do everything safely and responsibly, or not at all.
Our people Our success comes from our talented people doing great things for our customers and each other.
Service and value We’re committed to delivering exceptional service and value for our customers and communities.
Efficiency in everything we do We work smart, keep things simple and invest money wisely.
Progress through innovation From the technology and science we use, through to the way we approach what we do – innovation drives us forward.
Sustainability matters We take our responsibilities towards the environment seriously and aim to be sustainable in everything we do.
How to make good decisions
For most of us it’s easy to know what the right thing to do is, but sometimes we’re put in situations that we’ve never been in before, or asked to do things that are new; it’s at times like this where it’s not always obvious whether something is right or wrong.
In these instances we must all rely on our instincts and our support network in order to do the right thing. When we’re faced with a decision or situation where the ethics aren’t clear, there are a few questions that you can ask yourself to help you make the right decision:
If you are not sure, then
seek advice and guidance
from your managers.
We encourage everyone
to be open and to discuss
issues related to the Code
of Conduct. If in any
doubt, ask!
How the Code works
Why the Code is important
Our Code of Conduct provides the principles that we expect all of our people to follow when working for us. We expect everyone to be familiar with it and to apply it when acting on our behalf.
Along with the Code we also have supporting policies and guidelines to make sure that we fully understand how the principles can be applied in everyday working situations. In each section of the Code you’ll find references to the relevant policies and guidance. All policies can be found on the intranet.
Who does the Code apply to?
The Code of Conduct applies to all Pennon Group permanent and temporary employees regardless of the role you perform.
In addition we expect that all of our suppliers and contractors comply with equivalent principles to those set out here.
Breaches of the Code
If you’re found to be in breach of the Code then disciplinary action may be taken. This could be up to and including termination of your employment.
Should any proven breach of the code be criminal, we will support the appropriate authorities in their prosecutions of the individuals involved.
Will I receive training on the Code?
Yes, everyone is expected to complete regular Code of Conduct training. This will be provided as either an on-line training module, or as a face-to-face session.
Your commitment to the Code
As part of the training you will be asked to state that you’ve, read, understood and are committed to upholding the principles in the Code.
For further information on the training please contact the Head of Legal Compliance.
For further information about the
Code of Conduct please contact
If the answer to all of these is yes, then it is
likely you can proceed
If the answer to any of these is no,
then do not proceed
Is it legal?
Is it ethical?
Would I be comfortable explaining my actions to my
friends, family and colleagues?
Would I be comfortable if the decision appeared in public or the media?
No
No
No
No
No
Yes
Yes
Yes
Yes
YesIs it consistent with
this Code of Conduct?
Is it the right decision for the business? NoYes
2 3
How to raise questions and concerns
Upholding the law
We’re committed to doing the right thing and upholding the law. The law guides us and is our first point of reference when running our business. Ignorance of the law is no excuse, so whenever something isn’t clear you should always seek advice from our legal advisors. Specifically, legal advice should be sought immediately when any concerns arise with regard to fair competition, bribery and corruption, product safety or employment welfare rights.
Speak Up Confidential ReportingFreephone: 0800 297 0110 access code: 73693
Online: www.speak-up.info/pennon
Or text Pennon directly: 07788 916698
Speak Up procedure
If you become aware that a law may have been broken or that anyone could be breaking the principles of this Code of Conduct we want you to speak up. In the first instance you should consider speaking with your line manager or HR representative to report the issue. However, if you feel uncomfortable doing this then the ‘Speak Up’ service is available to raise issues confidentially.
Any issues raised through Speak Up are treated as confidential, whether you give your contact details or not. We treat each incident seriously and follow each of them up. The Speak Up policy provides further guidance on what to do if you have a serious concern.
A B
C D
design:one InTouch | SpeakUp logo identity © Design One 2011
Confidential Reporting
Confidential Reporting
Confidential Reporting
Confidential Reporting
Freephone: 0800 297 0110 access code: 73693Online: www.speak-up.info/pennonOr text Pennon directly: 07788 916698
4 5
This Code of Conduct sets out the principles that we as a company believe should guide our actions. It’s designed to support all of us in everyday decision making while we carry out our day-to-day business.
8 9Our Principles
Our workplace
Respect for each other: We treat each other with courtesy and without prejudice, valuing diversity and the strength it brings us. We help each other develop and grow.
Using company property: We protect company property and use it responsibly.
Safeguarding information: We treat personal, company and third-party information confidentially. We always carefully consider how we refer to work or business activities when using social media.
Our safety and the environment
Health and safety: We provide a safe, tidy and clean place to work where the health and wellbeing of our employees comes first.
The environment: We act responsibly towards the environment minimising our impact and working for a sustainable future.
Our communities: We respect the communities that we work in and endeavour to create a positive impact for the people who live in them.
Our partners
Customers: Our customers are at the heart of our business, we seek to provide excellent service, to keep our customers safe and to offer value for money.
Suppliers and contractors: We’re transparent in all our dealings with suppliers and contractors, respecting their interests and asking for their commitment to equivalent standards and practices.
Regulators: We work constructively with our regulators to ensure that the interests of our customers are upheld and that the industries we work in serve our communities effectively.
Shareholders: We strive to create value for our shareholders and provide accurate, transparent and timely information so that they can make informed decisions.
Our business conduct
Bribery and corruption: We don’t tolerate bribery or corruption in any form. We do not offer, give or accept bribes or incentive payments, either directly or indirectly.
Gifts and hospitality: We build strong partnerships with our customers, clients and suppliers; giving or accepting gifts and hospitality only if they can be shown to be of modest value and in no way influence our decisions.
Conflicts of interest: We declare and manage any potential conflict of interest that could prevent us from making objective decisions.
Integrity of business records: We record all business transactions accurately and with integrity. We’re committed to preventing any type of fraud or financial crime.
Competition: We welcome fair competition in our markets and comply with all relevant laws and regulations.
Meaning:
We implement robust health and safety management systems, adopting best practices and engaging in continuous performance improvement
We all take responsibility for our health and safety and the health and safety of others
We only undertake work that we are trained, competent and authorised to do
We report any unsafe conditions or breaches of health and safety rules and procedures
We stop work at any time if health or safety is being compromised
We ensure we understand the risks associated with our work and we take the necessary precautions for the health and safety of all
We are required to act responsibly at all times and we do not tolerate the possession, distribution or use of drugs or alcohol in the workplace
We secure our sites to ensure safety is not compromised
A: Our Code requires that we understand the risks associated with our work and take the necessary precautions. Working on equipment that has not been isolated and without a risk assessment presents a health and safety risk. You should raise the issue with your supervisor, who should access other options to make the repair safely. If you’re uncomfortable speaking directly to your supervisor you should speak with either your HR representative or the health and safety representative for the facility.
Q: We’ve had an equipment breakdown in one of our facilities and my supervisor has asked me to undertake a quick repair and not to worry about isolating the equipment or completing a risk assessment. I know I shouldn’t do this, but I feel pressured to do as I’m asked.
Health and safetyPrinciple: We provide a safe place to work where the health and wellbeing of our employees comes first.
Our safety and the environment
Meaning:
We measure our environmental impact with respect to energy, water and natural resources and set targets to continually reduce the resources we need to run our business
We manage our resources and the disposal of our waste responsibly. We control our emissions and help others to do the same
We actively reduce vehicle emissions from our cars, vans and lorries
We work with customers and consumers to encourage the proper disposal of dangerous and hazardous waste such as Lithium-ion batteries, ash and clinical waste
We comply with environmental regulations and report our performance openly
We encourage all employees, contractors and suppliers to support our efforts to work sustainably and to protect the environment
Q: I’ve noticed oil and other materials being washed down an open drain by one of my colleagues. Should I say anything?
The environmentPrinciple: We act responsibly towards the environment minimising our impact and working for a sustainable future.
A: We act responsibly towards the environment and dispose of our waste correctly. Hazardous materials disposed of down drains may cause pollution to the natural environment, including water courses. You should speak with your colleague about the potential consequences of their actions and remedy the situation. If you’re uncomfortable speaking directly, you should report it to your manager or health and safety representative.
Our safety and the environment
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A: It’s not always easy to respond to community members in the right way, but as a company we need to listen to all complaints seriously. You’re right to be polite, but you should log the complaint even if it has been logged previously and if needed, take action where you can.
Q: A member of the local community keeps complaining about the noise from our site, should I just be polite and ignore them?
Our communitiesPrinciple: We respect the communities that we work in and endeavour to create a positive impact for the people who live in them.
Meaning:
We listen to what the people living in our communities tell us and respond to their concerns
We consider the impact we have on the local communities where we work and take steps to minimise any disruption or inconvenience
We encourage and support our people to make a contribution to local communities through our charity partners and volunteering activities
We support local initiatives to improve public facilities, such as our beach cleaning activities and butterfly meadows
Our safety and the environment
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Meaning:
We’re inclusive towards our people, promoting equal opportunities and treating everyone with respect and courtesy
We don’t tolerate any form of bullying, harassment or discrimination
We recruit and promote on merit, using a transparent performance review process and provide everyone with the same development opportunities
We value our colleagues’ opinions, listen to what they have to say and seek feedback from them to develop as individuals and improve how we work
We respect Human Rights throughout our operations and will not tolerate modern slavery in our own organisation or supply chains. We report openly on these issues as required by law
We respect the rights to freedom of association
We support and encourage our people in achieving the right balance between their work and personal life
A: It’s important that you feel comfortable and respected in the workplace. Raise the issue with your manager and discuss why the jokes make you feel uncomfortable. If you’re not completely satisfied with the response and action taken, you should escalate the issue to your HR representative.
Q: A colleague keeps making jokes that everyone else laughs at, but they make me feel uncomfortable, what should I do?
Respect for each other Principle: We treat each other with respect and without prejudice, valuing diversity and the strength it brings us. We help each other develop and grow.
Our workplace
Meaning:
We protect the company’s property and ensure that intellectual property is kept securely
We use company assets appropriately and do not use them to access, copy and store or transmit any information or data considered to be offensive, obscene or inappropriate
We ensure that any personal use of company assets is within approved limits
A: Company tools are designed to be used for company activities and not for personal use. You may not remove them from company facilities without prior approval from your manager. In addition it is important that they are stored securely in line with health and safety and security requirements.
Q: I sometimes take my company tools home with me for my home improvements during the weekend. Is this okay?
Using company property Principle: We protect company property and use it responsibly.
Our workplace
16 17
Meaning:
We ensure that all commercial data is kept securely in accordance with our data protection policies
We protect personal data in accordance with the law and maintain the confidentiality of our customers’ and suppliers’ information
We ensure that third-party information requests and enquiries, including from the press and media, are channelled through the appropriate teams
We use social media responsibly, uphold the principles of this Code and ensure that personal views and comments are made independently from the company
A: The document is confidential and so should be treated as such. As the data is personal, you should try and avoid looking at it. You should inform your manager of what’s happened and pass them the document or dispose of it in a confidential way. Any information that you’ve seen by accident must be kept strictly confidential and not be shared with anyone else.
Q: I found a print out of our department salary information left on the printer, what should I do?
Safeguarding information Principle: We treat personal, company and third-party data confidentially.
Our workplace
18 19
Meaning:
We do not offer, promise, give or receive anything to improperly influence someone in order to obtain business
We do not make or accept facilitation payments or 'kickbacks' of any kind
There is no need for a bribe to be successful to be viewed as corrupt
We train our employees to ensure they can identify and respond to corrupt behaviour
We only engage in sponsorship and charitable giving if it can be shown that the organisation will not gain any unfair advantage from doing so
We all have an obligation to report breaches, or suspected breaches
A: If you have to ask the question it probably doesn’t feel right to you, so you should seek further advice. Although £20 is a small amount, paying it to jump the queue is termed a facilitation payment and is illegal. If this is common practice amongst your colleagues you can notify your manager, or if you would rather report it anonymously you can use Speak Up.
Q: I’ve been told that if there are any delays I should bung the guy on the gate £20 and expense it, is this really okay?
Bribery and corruptionPrinciple: We don’t tolerate bribery or corruption in any form. We do not offer, promise, give or accept bribes either directly or indirectly.
Our business conduct
Meaning:
We don’t give or accept any form of gift or hospitality during sales or tender processes
We make sure that any gift or hospitality given or accepted is within the limits of the gift and hospitality policy
We seek the appropriate approvals before giving or receiving any gifts or hospitality and keep records in line with the gifts and hospitality policy
Q: Last year I received approval to accept a bottle of wine from a customer. I don’t think we need to go through the process of obtaining approval again this year, if I just do something similar to what was approved last year. Is that okay?
Gifts and hospitality Principle: We build strong partnerships with our clients and suppliers, giving or accepting gifts and hospitality only if they can be shown to be of modest value and in no way influence our decisions.
A: Even if a gift was approved last year, you do need to seek approval to receive something similar again this year. The rules around gifts and hospitality may have changed and the situation with the customer may have changed as well (e.g. upcoming tender), which could mean that receiving a bottle of wine could be seen as inappropriate.
Our business conduct
20 21
Meaning:
We avoid situations where our personal knowledge or connections place us in a position that could compromise or influence our decisions
We declare all conflicts or potential conflicts
We don’t engage in insider trading, directly or indirectly, by using non-public information to gain from buying or selling shares or related financial products
A: You should let HR and the interview owner know immediately that you may have a conflict of interest. Even if finding a replacement is difficult at short notice it is important that the conflict is declared.
Q: I have been asked to sit in on a recruitment interview at short notice and the candidate is my cousin’s wife. What should I do?
Conflicts of interestPrinciple: We declare and manage any potential conflict of interest that could prevent us from making objective decisions.
Our business conduct
Meaning:
We maintain accurate records of all our business dealings
We maintain appropriate financial controls and are committed to the detection and prevention of fraud and money laundering
Where we suspect that irregularities exist in financial transactions we report them to a manager
We submit accurate and honest information in our expense reports, time sheets and other business administration records
Q: My colleague often returns late from lunch but charges this time as time worked on a project. He said that it is okay as he frequently works extra hours that do not get charged. Is this acceptable?
Integrity of business records Principle: We record all business transactions accurately and with integrity. We’re committed to preventing any type of fraud or financial crime.
A: It is imperative that all time sheets give a true and accurate reflection of the time spent working on that project. You should raise the matter confidentially with the appropriate manager so that they can decide how best to handle the situation. If you do not feel comfortable raising it in this way and would like to do it anonymously then you can use Speak Up.
Our business conduct
22 23
Meaning:
We will comply and implement regulations designed to encourage competition in our markets
We will not discuss pricing, bids, market segmentation or other commercially sensitive information with our competitors
We will follow the company’s guidelines about interacting with competitors and obtaining and handling competitor information
We will not enter into agreements with competitors that put us or them at an unfair advantage
We will report any suspicions of anti-competitive behaviour to our legal team
A: Our industries and markets are competitive and it’s wrong to collude with competitors to artificially impact pricing. Your colleague may not have been acting with any wrong intention, but regardless of this they should not discuss confidential pricing information with a competitor. You should report what you have heard to your manager or legal representative. Remember, if you prefer to remain anonymous you can use Speak Up.
Q: I overheard a colleague discussing bid pricing with a competitor, what should I do?
CompetitionPrinciple: We are committed to competing fairly in our markets and seek to comply with all relevant laws and regulations.
Our business conduct
24 25
Meaning:
We design our services and products to meet our customers’ needs
We listen to our customers and respond promptly and openly to any concerns raised
We listen to our customers and strive to continuously improve our products and services based on their feedback
Our customers are at the heart of what we do
A: Our customers are at the heart of our business and we want to make sure they get the best possible service. No one likes admitting to a mistake, but it would be wrong to overcharge a customer when we know that we’ve made a mistake. You should get advice from your manager on how best to handle the situation, no one will penalise you for admitting to a mistake and taking appropriate action to sort it out.
Q: I accidentally overcharged my customer but they didn’t notice, can I just keep quiet?
Customers Principle: Our customers are at the heart of our business, we seek to provide excellent service, to keep our customers safe and to offer value for money.
Our partners
Meaning:
We use transparent processes to select our suppliers and contractors and respect the terms of our contracts with them
We expect all our suppliers and contractors to uphold equivalent standards to those set out in this Code of Conduct and ask them to do so
We ensure that suppliers and contractors working on our sites understand and apply our health, safety, community and sustainability policies
We encourage suppliers, contractors and organisations in our wider supply chain to protect human rights and promote good working conditions
We seek to procure fairly traded products where available
A: Inducement in any form, including future benefits to the supplier, could compromise your ability to act objectively and in the best interests of the company and therefore must be avoided.
Q: I am working on a project with tight budgetary constraints. To complete the project within the targeted costs, I want to ask our supplier to provide me with an exceptional discount on this project order on the understanding that I will ‘make it up to him’ in future orders, is this okay?
Suppliers and contractorsPrinciple: We’re transparent in all our dealings with suppliers and contractors, respecting their interests and asking for their commitment to equivalent standards and practices.
Our partners
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Meaning:
We work actively with our regulators to ensure that we understand their requirements and meet their expectations
We listen to our regulators and make changes where needed
We report as required to our regulators, meeting the timescales and requirements set out A: We want to report to the regulator
in an open and transparent manner. You should clarify exactly what it is the regulator wants and report the true statistics.
Q: The regulator has asked for our customer complaint statistics, the period wanted is unclear, can I give them the best ones?
Regulators Principle: We work constructively with our regulators to ensure that the interests of our customers are upheld and that the industries we work in serve our communities effectively.
Our partners
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Peninsula House, Rydon Lane Exeter, Devon EX2 7HR Tel: 01392 446677 www.pennon-group.co.uk This brochure is printed on
100% recycled paper stock.
When you have finished with this brochure please recycle it.
