A message from our Director

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Our reputation with our community, customers, regulators and the general public is
essential to the long term success of P&P
To protect and enhance our reputation the achievement of consistently high standards of
integrity, honesty and personal commitment to act in accordance with our values is crucial.
Our company vision is focussed on our ‘We Care’ policy. To deliver this aspiration we must
set out and be committed to high ethical and operational standards in all that we do. Our
values are completely aligned to achieving this. This Code of Responsible Business Conduct
sets out the minimum personal and professional standards that we should adopt and
provides guidance to achieve these requirements. Management and Employees at all levels
in the organisation have contributed to the production of this Code. The content is based on
the knowledge and skills of our people and in particular draws on the real life experience of
dealing with complex and difficult issues. Consequently, it has real relevance to what we do
every day.
Our business very often sets stricter standards than those in the outside world and our
values depend on each of us taking the responsibility to do the right things in our daily
endeavours. We would encourage everyone in the business to take time to read the Code to
learn from the experiences of others and to avoid errors that harm the reputation of the
business and/or ourselves. In particular it is important to remember that Safety must be at
the heart of everything we do.
Please take the time to read this code and work with your colleagues to find ways of
continuously improving our practices

Our Code of Responsible Business Conduct

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This code is intended to guide us, as the people of P&P, through the decisions that we have
to make to do our jobs responsibly, safely and ethically. We all have a duty to know what is
required of us in conducting business in a professional manner. Knowing what is required of
us in our roles is our responsibility
Everyone is responsible, everyone is accountable
Everyone, including the Director of the company, senior management, line managers and
employees must comply with this code. It will help guide everyone through our
expectations, providing the information that we need to help to understand and comply
with our requirements and the law.
The Code also explains what we should do if we witness behaviours that do not align with
our requirements.
Supporting our mission
By acting responsibly in business we will support our Mission and help secure our future
success. Whatever our role, our behaviour and input in executing our strategy and raising
concerns in a responsible and lawful manner is the key to our success as an organisation.
Living our values
Integrity – we will do what is right
Safety – We will actively care for each other’s safety
Respect – We will value people as they are- their abilities, contributions, and participation of
all
Commitment – we will do what we say when we say we will do it
People- we will enable and encourage each individual to achieve their full potential
Learning – we will create a climate of continuous learning
Understanding responsible business conduct
Our Code is intended to enable compliance with company policies. The law and policy can
change so it is up to each of us to ensure that we have the latest information to hand and
that we use our common sense and sound judgement where things do not feel right. The
following simple checklist is intended to assist with decisions we need to make each and
every day: Ask yourself:

  • How would I feel if someone else was doing what I am doing or proposing?
  • Would I be concerned if my actions were being scrutinised?

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  • If the media published details on what I am doing would I be comfortable about explaining
    it?
  • How would I feel if my family and friends examined my actions?
  • Am I setting a good example to others?
  • Should I be consulting with colleagues with specialist knowledge or insight? Would they do
    what I am proposing?
  • Would my actions call my or the company’s integrity into question?
    Even the appearance of the conflict between your personal interest and the interest of the
    company or another stakeholder could have a negative impact on how we are viewed by the
    public and the company
    Enforcement and discipline
    The expectations and behaviours outlined in the Code, and contained in our existing Policies
    and Procedures, are key to the continued success of our business and our position in the
    local community. Where breaches occur, the relevant policies will be enforced. Non-
    compliance with our policies is always taken seriously by P&P
    All failures to meet the high standards that are required by our company policies, or the
    legal requirements within which we all operate, are always of concern.
    Any formally investigated and confirmed breach of policy or procedure does have the
    potential to result in disciplinary action against the employees. This could result in a range
    of sanctions, up to and including dismissal, or for non- employees of P&P it may result in
    permanent removal for the sites we operate our services.
    It continues to be a requirement that everyone should co-operate fully with any internal
    investigations being carried out in relation to suspected breaches of our Company Policy
    and Procedures or non-adherence with the Code of Responsible Business Conduct.
    Asking questions and getting help
    The right answer is sometimes hard to find as not everything is black and white.
    Sometimes grey areas and outside circumstances require us to look hard at the facts and
    make decisions that test the limits of our prior experiences. Always ask for input. Help is
    just a phone call away!
  • While you can start with any of the people listed here, we encourage you to first talk with
    your line manager. Whenever possible, you should discuss your question with your line
    manager. Try to work together to resolve your concern or decide if you need additional
    help.

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  • call head office on 02037050064 or email [email protected]
    Our expectations for leaders and managers
    Whilst this Code sets out our expectations of everyone, we place a higher expectation on
    those who lead and manage to set and demonstrate high standards and to provide help and
    support to others in the workplace. We expect those who supervise others to set high
    standards in promoting our values and thereby enabling compliance with this Code. This
    includes:
  • Living and communicating our Code.
  • Helping those being supervised to understand their responsibilities under the Code.
  • Protecting the health and welfare of everyone.
  • Communicating clear expectations.
  • Behaving ethically and with integrity in everything that you do.
  • Monitoring compliance with and enforcing the Code consistently.
  • Cultivating learning and questioning environment.
  • Enabling individuals to do the right thing
    How to use this guide
    Throughout this guide you will see a number of ‘talking points’ included. These are aimed at
    highlighting situations that you may be faced with or need to think about.
    Safety
    Safety is a corporate value for P&P and is the priority for everything that we do. We share a
    responsibility to continuously improve our safety performance. We will set demanding
    standards for safety, the vigorous application of our safety principles and fundamentals is
    key to delivering these standards. Our safety principles we believe:
  • All events or incidents leading to injury, and occupational illnesses are preventable.
  • Safety is everyone’s personal responsibility and it is delivered through personal ownership
    and action.
  • Managers are accountable for leading by example, clearly setting direction and demanding
    the highest standards.
  • Excellence in safety requires working together with our employees, contractors, suppliers
    and customers.

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  • Good safety is good business, and continuous improvement is essential to our success.
    Our safety fundamentals
    We will:
  • Not compromise on our standards and expectations, holding everyone accountable for
    safe and environmentally responsible behaviour.
  • Communicate, celebrate and share success, show pride in our successful safety
    performance and act on learning.
  • Be firm in our beliefs, seek to understand alternative views, but stand our ground when
    necessary to agree optimum solutions.
  • Earn and maintain the respect and trust of people who work with us, the public and other
    stakeholders.
    Environment
    Together we work hard to minimise the environmental impact of our operations across all
    areas of on-site activity. We engage with our clients and suppliers and seek the widest
    possible approval of how we manage our environmental responsibilities, including the
    application of our Integrated Waste Strategy. It is our goal to continually improve global
    environmental performance by:
  • Eliminating accidents and incidents.
  • Minimising waste and the use of natural resources.
  • Ensuring that all wastes are managed safely and with care for the environment.
  • Sharing and using best practice.
  • Meeting or exceeding current standards of environment, health and safety performance.
    Health
    The health and safety of employees and everybody that works with us is vitally important.
    We will take a proactive stance to continuously improve our health and safety performance
    across the business. We aim to maintain a fit and healthy workforce by:
  • Eliminating ill-health at work.
  • Encouraging our employees to have a balanced lifestyle and maintaining a healthy
    work/life balance.
  • Identifying and maintaining acceptable conditions for our workforce.

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•Learning lessons from events, implementing corrective actions and seeking out and using
good practice.
Quality
Our customers demand high standards from us and we strive to enhance their satisfaction
through continuous improvement, operational excellence and delivery of high quality
products and services.
Talking point:

  1. I have only been with P&P a short time but I have worked in a similar industry. The safety
    rules at P&P seem to be tougher than where I have worked before. Surely if I know what I
    am doing and I know it is safe then I do not need to follow all the guidance for P&P?
    You must follow all P&P Safety processes. Sellafield Ltd is proud of its safety culture and
    record. We strive to be world class and to achieve this we need to focus on safety in all that
    we do. However, if you believe that there are ways of improving systems or processes then
    speak with your supervisor or manager. There is always scope to learn and continuous
    improvement is critical to achieving our goals.
  2. When at work I know I have a duty to promote safe working and to challenge
    inappropriate/unsafe behaviours. However I am concerned that if I make comments to my
    colleagues this could come across as interfering or even worse as harassing them. What is
    the right thing to do?
    The way you challenge behaviours is important. Do so in a constructive, sensitive and
    helpful way and we expect your colleagues to respond in kind. Peer observation is a great
    way to improve safety culture and awareness. Challenging unsafe behaviours will prevent
    accidents and can even save lives. Where serious safety breaches are observed we have a
    duty to report these for the benefit of all.
  3. I work in a controlled area and I am pregnant. I want to tell someone at work as I am a
    little worried about the possible health effects of not saying anything, even though I have
    only just found out about the pregnancy; however I do not want anyone else to know just
    yet. What should I do?
    It is in the interests of you and your unborn child to inform the company as soon as possible
    so that we can take the appropriate measures to control you’re working conditions. You can
    contact Human Resources in confidence and they will provide further advice and support.

Use of Information Technology

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Everyone should be very careful when using IT systems including creating email, voicemail,
instant or text messages. Disciplined use of IT is required to prevent disclosure, loss, theft,
damage, careless or unauthorised use of physical assets and information.

  • All information and data inputted onto company systems becomes company property.
  • Engage only in limited personal use of company systems and only if that use is not
    contrary to the P&P’s guidelines within the company hand book
  • Do not violate copyright or trademark rights, using unlicensed software, making
    unauthorised copies, or making defamatory or discriminatory statements while using P&P’s
    information systems and technology.
  • Internet usage must be reasonable and in line with company guidelines. The use of
    gambling sites is strictly prohibited.
  • Company systems must not be used to download or otherwise view sexually explicit or
    otherwise offensive content. This is strictly prohibited.
    Talking point:
  1. I have an account with a social networking site and I use it to keep in touch with my
    friends and colleagues. While I am at work I regularly check my account and update it with
    details of what I am doing or what is going on in the business.
    You must not use company IT systems or company time for social networking and you must
    not use social networking sites to post unauthorised details of the company or its activities
    online. You may not think that what you are saying is sensitive but it could be, or could be
    misunderstood, leading to inadvertent damage to the company reputation. Be aware that
    email from a company account may be construed as the official position of the company.
  2. I have agreed with HR that I can operate a small business in my own time that is nothing
    to do with the company. In order to do this I sometimes need to access the internet; make
    calls or send emails during office hours. Can I use company IT systems to do this?
    Although you may have permission to operate your business in your own time, this does
    not entitle you to use company resources, even outside working hours, to support your
    business.
  3. Sometimes, whilst at work, I will use the internet to browse the web. This is mostly in my
    lunch break and my manager does not object. Am I doing anything wrong?
    So long as your manager has approved it; your use is reasonable and does not interfere with
    your work, and you do not access inappropriate websites then this is acceptable.
    Avoid conflict of interest

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Conflicts of interest can occur in a wide range of common business situations.
You need to think carefully about your actions and assess whether a potential conflict
exists. If you are concerned that your actions could be viewed as creating a conflict
between your personal interests and the company then, you should check with a member of
management or Human Resources. Outside employment you may not, without company
consent, work as an employee, consultant or in any other capacity, with any other business
or organisation (including volunteer activities). Use of company resources You may not,
without company consent, use the name, logo, proprietary information, office space,
facilities, staff, vehicles, telephones, computers, supplies or any other resources or
equipment operated by P&P in connection with outside employment, business activities or
for personal gain.
Financial interests
You may not, without company consent, either directly or through an immediate family
member, have a financial interest in any other business, organisation or activity that may be
affected by your actions and decisions whilst working at P&P.
Personal relationships at work
Your close personal relationships should never improperly influence your decisions at work.
You should not be working in a position where you could influence the salary or
performance review decisions about a family member or a romantic partner. Also, if you
have a close personal relationship with another person, you should not be able to assign,
review, approve or somehow affect the work of that person. If your circumstances change
and you find yourself in a position where you gain a close personal relationship with another
person then you must notify Human Resources and/or your line manager immediately. You
should never informally share company information with relatives or friends who work in
the supply chain or with our customer.
Prohibited payments
All payments must be made in accordance with the Financial Director. You may not take or
approve any action that will require payment from corporate funds if such expenditure is
not authorised or reimbursable under company processes.
Talking point:

  1. I have recently started a new relationship with an individual within my department who
    reports to me. They are very competent and deserving of a promotion. Am I okay to
    promote them?
    There is potential for a perceived conflict of interest. This does not mean the individual
    should not be promoted but the decision ought to be made by an independent manager.

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You should also discuss with HR whether it is appropriate to continue to act as line manager
for this individual.

  1. My husband holds a position with a supplier where he will gain a bonus from his
    employer in relation to additional business being awarded to them by P&P. Although I have
    no say in who we order from, the department does use the product. Do I need to tell
    anyone?
    Although you may feel that you are not directly influencing the business that could be
    awarded to the supplier, if your husband secures his bonus based on increased sales then it
    could be said you have a direct financial interest. P&P is unlikely to object to your husband
    supplying to our sites in these circumstances but if you declare your interest you can be
    confident that the company is aware of, and consents to, this in the event that any
    questions are ever asked. It is also important for the company and your manager to know
    so there is no possibility you could fall within a position where you make, recommend, or in
    any way influence the decision whether to award work to your spouses’ employer.
    Drugs and alcohol at work
    We all need to be alert and fit for work if we are to deliver the demanding standards of
    performance and safety which P&P requires. The use of alcohol or any other drugs,
    including prescription medicines, must not impair our ability to work safely and make sound
    judgements. Attending work when unfit due to drugs or alcohol can have serious
    consequences for us, our colleagues or our community so we must take care to ensure that
    any consumption, even outside working hours, does not affect our ability to do our jobs
    competently and safely. This means all employees and suppliers must comply with and
    enforce a strict policy on the misuse of alcohol and drugs. Some medicines contain alcohol
    or can impair our ability to do our jobs. You should carefully check the advice leaflets
    provided by the manufacturers of their products. If you are still in doubt seek guidance and
    approval from the Human Resources department prior to use or before reporting for work
    having taken them. You must not bring illegal drugs or alcoholic beverages onto any of the
    Company’s sites. P&P will not tolerate the possession or use of prohibited substances,
    which includes the possession or consumption of alcoholic beverages and illegal drugs in the
    workplace and will conduct searches of company premises if we have reason to believe that
    such substances are present on the premises. Any substances found as a result of a search
    will be confiscated and disciplinary action will be considered.
    Talking point:
  2. Sometimes my colleagues and I go out for a meal at lunchtimes to celebrate a special
    occasion or to socialise. Is it okay to have a pint of beer or a glass of wine with lunch?
    You should not drink alcohol if you are returning to work. You should bear in mind that
    random and for cause testing is carried out on our sites.

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  1. Sometimes I travel with work either for training or meetings off site. On occasion we stay
    overnight. When I do I often drink alcohol in the evenings either with my meal or at the bar.
    Is this acceptable?
    Moderate alcohol taken with a meal is reasonable. If you are travelling with work you are
    expected to behave appropriately at all times. Excessive drinking during the evening whilst
    representing the company on a residential training course, conference or business dinners is
    not acceptable behaviour.
  2. I often go out into my local town at weekends and I have seen some of the people I work
    with on the site also in town. Although I am not sure I think that they may be using drugs. I
    am worried because although they do not seem to be under the influence when on site they
    do work with appliances and chemicals, Should I say anything?
    Yes you should, this is a genuine concern and should be reported. You can do this in
    confidence if you wish to Human Resources. It is better to raise your concern even if you
    are incorrect as the abuse of drugs can have serious consequences both to the individuals
    concerned and others on and off the site.
    Keeping personal information safe
    P&P keeps certain personal records for every employee including HR and medical
    information. These records must be kept strictly confidential and P&P is committed to
    ensuring this. Personal information will only be disclosed for legitimate, need-to-know,
    business purposes or as required by law. If we have access to any information that may be
    of a sensitive or confidential nature, we must treat the information as our own and
    safeguard its confidentiality.
    Personal security
    We all need to feel that P&P sites are safe and secure places to work. To prevent losses,
    secure personal and company valuables at all times. Do not leave bags or equipment
    unattended in an unsecured location. Always place valuables out of sight. You should also
    take special care when travelling offsite. Violent behaviour and or any sort of offensive
    weapons even if related to sports activities, are prohibited on our premises.
    Security and safeguards on our sites
    Sellafield Ltd is committed to the physical security of its sites; we all have a duty to:
  • Manage security issues responsibly
  • Protect the sensitive information contained in documents and the knowledge that we
    hold.

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  • Be careful about where documents or electronic devices e.g. approved USB sticks, phones
    are left.
  • Avoid conversations about work in public.
  • Always wear and display our company pass while on site. This must be removed when you
    are no longer on site.
  • Always lock your computer when away from your desk for any length of time – you have
    access to data which others should not have access to.
  • Manage documents in accordance.
  • Promote an effective security culture.
  • Follow company and local security arrangements in respect of keys, workplace (egg.
    desks, filing cabinets) security.
    Talking point:
  1. I have been contacted by a trade journal who informed me that they like to send
    promotional material to senior managers in the business. They told me that if I provided
    some names, addresses and job descriptions to them they would reimburse me for my time
    and that this could be a few hundred pounds. Can I take the money even if I donate it to a
    local charity?
    You must never provide personal details or even role descriptions if you are not authorised
    to do so and certainly not in return for personal gain. Report this caller immediately to HR

Fraud or theft from the company
We all have a responsibility to detect and prevent fraud or theft from the company.
Whether there are concerns about our colleagues or our suppliers, we must act to prevent
corrupt and unlawful practices. Examples of theft or fraud are diverse but should all be
taken seriously. They include:

  • Taking of company equipment (tools, stationery, software) for personal use or resale.
  • Falsifying accounts or records to divert funds for personal use or to achieve personal gain.
  • Assisting suppliers to divert goods intended for our sites.
  • Having personal work done or making personal purchases on the company account.
    It is also critically important that you:

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  • Do not allow or facilitate the creation of undisclosed or unrecorded funds for any purpose.
    Never place any company funds in any personal or non-corporate account.
    Never attempt to influence, coerce, mislead or interfere with the auditing of company
    financial systems or processes
    Immediately report concerns or violations regarding accounting to head office.
    Talking point:
  1. I am in a management role and as part of my duties I am required to sign off the expenses
    and timesheets of my team. I believe some of the hours and amounts claimed are excessive
    but I did not really know how to resolve these so just approved everything. Nobody has
    ever questioned me about it though
    If you have any suspicions that this type of activity is taking place then you must not
    approve the records and you should seek for the advice. It is your duty to report any such
    activity you believe may be fraudulent so that an appropriate investigation can be
    undertaken.
  2. From time to time I take work home with me and sometimes I will take some stationary
    items with me, I have pens, pads of paper, files and other items. Can I get into trouble for
    this?
    Taking stationery items home with you in moderation is acceptable where it is supporting
    you in carrying out your work. However, it is important not to abuse this trust and to act
    with honesty and integrity at all times in relation to all company property. Any taking for
    purely personal reasons is unacceptable.
  3. I work at a site and I recently noticed that a number of items are being ordered where
    there is not a high demand for them to be used on site. More of these items are being
    ordered but it is not clear where they are going but the costs are being charged to P&P
    You have a duty to report fraud, other criminal behaviour and violations of the code that
    you reasonable suspect. This example suggests just such a reasonable suspicion. We value
    your honesty and integrity and encourage you to contact head office.
    Managing information and accounts
    Always prepare business documents and records honestly and accurately. Documents and
    records should be retained in a way that allows efficient retrieval whenever necessary. .
    You should:
  • Never make a false or misleading entry in a company report or record.

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  • Never tamper with, manipulate, alter, remove or destroy original records before the end
    of the applicable retention period.
  • Never knowingly alter, destroy, or conceal any record or document, or attempt to do so,
    in order to impair the record’s integrity or availability for use in an official proceeding.
  • Never sell, transfer or dispose of company assets without proper documentation and
    authorisation.
  • Always consider the value of documents before destroying them. We maintain company
    accounts with the highest degree of accuracy and integrity protecting trade secrets,
    intellectual property and confidential information. We must protect all confidential
    information including processes, software and methodologies developed by the company or
    entrusted to the company by others. Information not generally available to the public is
    confidential. All such confidential information must be safeguarded.
    We promote equal opportunity and diversity
    P&P are committed to making all employment decisions based only on merit to ensure we
    have the best people working alongside us. When involved in selection, promotion or
    transfer we must ensure employment decisions are not based upon personal attributes such
    as race, colour, gender, religion, national origin, disability, age, sexual orientation, gender
    identity or marital status.
    We demand a workplace that is free of any form of harassment or bullying
    Everyone has a right to be treated with dignity and respect. We will not tolerate
    harassment or bullying in any aspect of company business. Unacceptable behaviours
    include: making derogatory or obscene remarks, jokes or innuendo; unwelcome sexual
    attention; humiliating or ridiculing someone or being offensive, abusive or insulting.
    Training and development
    We recognise that an ongoing programme of training is the cornerstone of a sustainable
    business. We should all ensure that we have considered our development goals and those
    we achieve and support others in achieving our full potential. We should remember to
    utilise all elements of the training process, which is designed to help address these issues
    including equal opportunities, special needs and harassment
    We prohibit slavery and human trafficking
    We prohibit the use of modern slavery and human trafficking in our operations and Supply
    Chain. We are committed to implementing systems and controls aimed at ensuring that
    modern slavery and human trafficking are not taking place anywhere within our
    organization or in any of our supply chains.

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Talking point:

  1. I work at a site and have recently noticed that when I come into the work area people
    start talking amongst themselves and they do not speak to me. I am sure they are saying
    things about me. I do not know why but when I ask people they just say that I am being too
    sensitive and should not worry about it. I feel as if I am being left out. When they go to
    lunch they do not invite me and occasionally I have heard some comments about people
    who are no fun. I think they mean me.
    Even though nothing has been said directly to you if this indirect behaviour is causing you to
    feel intimidated it ought to be resolved. You should report this to your line manager options
    that you might consider for further help and support could include contacting your Business
    Development Manager or speaking in confidence to Human Resources if you feel that the
    matter has still not been resolved, speak to your manager to make it clear that behaviour of
    this type, if it amounts to bullying or harassment, will not be tolerated and must stop.
  2. Whilst at work I have witnessed a supervisor making remarks about the sexual
    orientation of another member of the team, sometimes directly to them. I think that this is
    being said lightly, but it sometimes seems to me that there is a more concerning undertone.
    Should I do something?
    Responsible behaviour does mean checking on the welfare of others and unlawful
    discrimination will not be tolerated. You could ask your team member whether they are
    uncomfortable with the remarks. Other options that you might consider for further help
    and support could include Human Resources
    Bribes or illegal payments
    We strive to deliver our business objectives fairly and honestly. We never give or accept
    bribes, illegal payment or other improper means to influence
    In the case of suspected fraud, bribery or corruption this should always be reported to Head
    Office
    Improper means can include gifts or entertainment, including to third parties, not just cash
    payments so extreme caution is required in the conduct of all business dealings.
    Employees involved in procurement have a special responsibility to adhere to principles of
    fair competition in the purchase of products and services by selecting suppliers based
    exclusively on normal commercial considerations such as quality, cost, availability, service
    and reputation and not on the receipt of special favours. We will not act on information we
    receive about companies with whom we do business
    We must comply with anti-corruption laws including the UK Bribery Act and the EU
    Directive on Anti-Bribery. These laws prohibit improper payments to any government

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official, political party or candidate to obtain or retain business to facilitate an action, or
other improper advantage.
P&P will not tolerate bribes or illegal payments, the company will ensure that it has in place
adequate procedures to prevent bribery and other corrupt practices.
P&p is not seeking to influence decision making in return for payments, merely to explain
the issues and challenges we face. Providing we act in accordance with our Code and the
law then such visits are perfectly acceptable. You should consult with the legal services or
HR for determination of acceptability
Gifts and entertainment
Gifts with a nominal value and appropriate entertainment can help build business
relationships. However, whether given or received, gifts and entertainment should never
improperly influence any business decisions and should never be accepted where they
could, or could be seen to influence a, business decision e.g. during a procurement process.
Gifts or entertainment must only ever be accepted where doing so would support the
business interests of P&P and will not damage the reputation of the company, its owners or
customers.
Gift and entertainment guidelines:

  • You may accept or give inexpensive gifts of a promotional nature e.g. diaries, pens,
    calendars etc. or gifts with a nominal value e.g. chocolates or flowers
  • It is not permissible to accept or provide any other gifts above a nominal value. All such
    gifts, whether given or received, must be declared to the company through the Human
    Resources
  • Meals or drinks received in the normal course of business are acceptable provided that
    they are reasonable providing there is a genuine business benefit and no conflict of interest.
  • Gifts of cash or cash equivalents (such as gift certificates, loans, shares etc.) are expressly
    prohibited under all circumstances.
  • Immediate family members may not give a gift, nor accept a gift connected with your
    work.
  • Understand and respect the gifts and entertainment policies of our business partners,
    suppliers and vendors and do not create situations that may violate those policies.
  • No gifts or entertainment must ever be given to government employees or elected
    officials without prior approval.

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Managerial approval, together with details of the gift/event/entertainment offered or
taken, must be communicated to Regional Operations Director for review
Talking Point

  1. I have been invited to a dinner by one of our suppliers. The dinner is in London and they
    have offered to pay for the meal, my travel expenses and an overnight stay. I do a lot of
    work with the supplier and I believe that spending some time with them at a social occasion
    will enhance our working relationship and promote effective partnering. I believe that the
    event will add value and I propose to attend.
    Attendance at this event is not acceptable on these terms. P&P will determine what events
    are in our interests for employees to attend. Normally you will be requested to attend by
    P&P if it is in our interests. Any other invitations and an estimate of costs should be lodged
    with regional operations director for a decision
    Political Contributions
    P&P does not lobby or make political contributions and no contributions should be made in
    its name. We recognise that employees may engage in political activity in their own time,
    but company time, assets and facilities may not be used for employee political activity.
    Social and environmental responsibility
    P&P shall wherever possible promote sustainable development and the responsible use of
    resources including encouraging the supply chain to participate in socio-economic
    development and targeting improvements to programme delivery particularly where local
    benefits are derived from the supply chain. We shall actively encourage responsible
    citizenship and we are encouraged to volunteer our time to legitimate community,
    educational, charitable, civic or other non- profit organisations, however this work must not
    interfere with our job responsibilities, conflict with the company’s interest, or reflect
    negatively upon the company’s reputation.
    Labour standards in our supply chains
    P&P is committed to engaging with our suppliers to address the risk of modern slavery in
    our operations and Supply Chain. P&P requires its suppliers to adhere to the labour
    standards and to require the same standards of their own sub-contractors, suppliers and
    business partners.
    Reporting Concerns
    If you know of or suspect an unsafe or unethical practice; a breach of the law; a breach of
    our Code or our policies you are responsible for reporting it immediately. Your report should
    be made in “good faith” meaning that you are providing all the information you have and
    that you believe it is true. Your reporting obligation also applies to situations involving non-

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employees, such as the supply chain, agents, vendors, independent contractors and
wherever else you may have a concern that impacts the company.
Generally, the first place to raise concerns should be with management; however we
recognise that you may not feel comfortable discussing concerns, particularly serious
concerns with your direct line manager so if the disclosure is extremely serious or in any
way involves your management you can report it directly to our head office.
‘How do I report concerns (‘Whistleblowing’)’
Please bear in mind that different concerns you may have may be best dealt with by
specialists and should you be aware of, or be made aware of, suspected fraud, bribery or
corruption this should immediately be reported to Human Resources.

  • Failure to report breaches is never appropriate and is itself a breach of our Code. Also, any
    delay in reporting could substantially increase the risk of safety, legal and/or financial
    exposure.
  • You can make reports anonymously. Maintaining anonymity may limit our ability to
    investigate an incident.
    In all cases, reports will be treated as confidentially as possible. P&P will not tolerate
    victimisation or retaliation against anyone for reporting in good faith, breaches of the law,
    company policy or our Code. Any acts of retaliation or victimisation against employees
    raising good faith concerns will be subject to disciplinary action. If you believe that you have
    experienced any form of retaliation as a result of raising a good faith concern, you should
    report it to a Manager or Human Resources.