POL00412083 - Code of Business Standards - Post Office

Evidence on official site

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CONTENTS

Foreword by our chief executive
Our heritage and values

Introducing the Code

Observing the Code

Our brand

Customer excellence

Our people

Business behaviours

Personal behaviours

Valuing diversity and inclusion

Creating and maintaining a safe and healthy place of work
Health & wellbeing

Protecting the environment

Use of alcohol, tobacco and illegal drugs

Use of computers, internet, phones and email

Social media

Engaging with the media

Political activity

Conflicts of interest

Gifts and sponsorship

Hospitality and entertainment

Fraud and financial crime

Risk management

Modern slavery

Consequences of non-compliance for the code of business standards
Making proper decisions and seeking help

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Foreword by our chief executive

Dear Post Office Colleagues,

Post Office is unique - a commercial business delivering an important social purpose. We
believe in the importance of connecting communities and enhancing the powerful role they
play in all our lives. We stay true to this commitment by meeting customer needs through
carefully designed, high quality products, and maintaining an unrivalled local presence
across the UK

Generations of hard work and honest achievement have made Post Office a name that elicits
trust. This is due in no small part to an unwavering commitment to ethical behaviour and
doing the right things in the right way. This commitment and integrity is critical to achieving
great business performance

Our Code of Business Standards sets out our enduring commitment to ethical behaviour
and ensures our policies and processes are relevant and appropriate to today’s dynamic
operating and regulatory environment, Regardless of the challenges that arise in achieving
our ambitions, our commitment to how we do business is unwavering

\ expect everyone at Post Office to read this document carefully and to think about how
it applies to their work. Consider how your behaviours, actions and decisions may affect
others, including customers and colleagues.

The way that we conduct business has never been more important. Thank you for your
trust in Post Office, And, most importantly, thank you for your commitment to ensure our
customers and the communities we serve continue to place their trust in us

Paula Vennells

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Our heritage and values

Post Office has thrived at the heart of communities across the
UK for over 370 years.

We are one of the country’s most trusted brands and we take our commitment to provide
essential services very seriously. We are the UK's largest retail network and provide
unrivalled access to banking and financial services, with more branches than all the UK's
banks and building societies put together.

‘We are committed to doing business the right way. That means we act lawfully. It also means
that how we conduct ourselves is more than just a matter of policy and law: it’s a reflection
of our core values: Care, Challenge and Commit. By aligning our behaviours to our core
values, we help maintain the trust and support of our customers, shareholders, communities
and others with whom we work

“We are committed to doing business the right way.
That means we act lawfully. It also means that how
we conduct ourselves is more than just a matter of
policy and law.”

Introducing the Code
Our Code of Business Standards defines how we operate.

in developing the Code of Business Standards, we have drawn inspiration from our heritage
and values as well as the law, Itis intended to guide the way we behave and give us
standards to measure ourselves. It sets out what people can expect when working for and
with Post Office. It is designed to provide guidance and support in making decisions and
carrying out work in a way that is compatible with our values, policies and processes and the
law. As the legal and regulatory environments evolve, the Code will adapt to accommodate
such changes.

By consistently adhering to this Code we will continue to foster and strengthen a culture
that will help us to continue to be a business to be proud of - a Great place to work’ that is
‘Simpler to run’ and ‘Better for customers’

Observing the Code

Everyone employed by Post Office is required to NOTE

adhere to the Code; they are expected to operate in Please be aware that any

line with it and the corresponding G , breach of this Code may
be dealt with under our

Conduct Code, and that

gross misconduct could

result in your dismissal

As a Post Office colleague, you are required to:

Read and understand the Code of Business Standards and
work-related policies and incorporate them into your work
and behaviours

Complete all mandatory training on time

Report potential unlawful behaviour or breaches of the Code
or company policies

Cooperate fully with company investigations
Never victimise colleagues for ‘calling it out’
Ask questions when you're unsure

Aline managers have aces tothe My HR Help service which supports
managers with team management queries. Visit ww °.

Our brand

Our brand experience, for employees, customers,
partners and stakeholders is shaped by our core values
of Care, Challenge and Commi

‘We make that happen by having a set of straightforward business behaviours
which inform the way we do things, and we use them as a guide to improve
‘our people processes including recruitment, learning and development, talent
and performance management. In short, it's how we do things to deliver our
brand commitment to customers

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Customer excellence
Our customers are at the heart of everything we do.

We all know what it feels like to experience good and poor customer service. We need to
ensure that we deliver great service for all customers, every time they interact with us. The
more we understand our customers and their expectations, and put ourselves in their shoes,
the easier it will be to provide consistently great service.
How do we demonstrate our commitment to customer excellence?

By listening to them and understanding their needs and expectations

By communicating respectfully, leaving out the jargon, providing them with the
best service and products that meet their needs

By always thinking about them and not the process

By keeping it simple and straightforward to reach us - in branch, online, mobile

Our people

With a diverse range of backgrounds, talents and perspectives,

Post Office is in a unique position to understand our customer needs.

At Post Office, we differentiate ourselves through the dedication of our people. Our rich
and diverse cultures and experiences help us make connections with our customers and
sustains the continued success of our brand. To maintain this, we treat each other with
respect, even when our differences may set us apart.

We aspire to provide a positive work environment. This means that regardless of our
differences, we can work without fear of discrimination, harassment or victimisation.
Employment decisions - whether they be related to hiring, promotions, transfers or

terminations ~ are based on merit, equity and fairness.

Business behaviours

Our behaviours are based on our core values of Care,
Challenge and Commit.

We care by always thinking customer

Care is the cornerstone of our business. It means valuing people and their
time and putting our customers first It means making it personal; listening and
understanding; being guided by our conscience and expertise; and keeping
‘our word. In short, it means doing right by people. This is what sets us apart.

We strive to make things ever better through honest challenge

Challenge conventions, challenge complexity, challenge competitors,
challenge on behalf of our customers, challenge each other, challenge
yourself. We've been passed the baton of this great institution. I's up to every
one of us to drive it forward and create change for a successful future.

We commit to decisive delivery

‘We don't ust work for Post Office, we are Post Office, and we're all
responsible for its commercial success. The road ahead is exciting, but not
‘easy. I each and every one of us invests all our energy, creativity and passion,
‘we can achieve amazing things. You can find out more about these behaviours
and what they mean, in Ov ft

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“We don't
just work for
Post Office,
we are

Post Office,
and were all
responsible for
its commercial
success.”

Code of Business Standards
NOTE

Ifyou havea concern
about bullying and
harassment, you can
speak to your line
manager or refer to
the Dignity at Work
Polley or managers can
contact My HR Help.
There is also the HELP
employee assistance
programme, which
you can find out more
about here.

Personal behaviours

We expect high standards of personal behaviour at work.

Behaviour which damages service to customers, or the reputation or efficiency
of Post Office, is unacceptable. This extends to poor attendance, lateness,
dishonesty, drunkenness, use of illegal substances, and violent or disorderly

behaviour or abusive language.

Maintaining our standards means we:
+ Conduct ourselves appropriately and professionally

Act as an ambassador for the company

Operate within the law
Do not bring Post Office into disrepute

Do not claim money for hours you did not work, ajourney you id not
make or an expense you did not incur

Do not use inside information about a company transaction for
personal profit

Post Office operates a zero tolerance to any form of
discrimination, including based on:
Race
Colour
Religion or faith
Age
Sexual orientation. gender, or gender identity expression
National origin, geographical or demographic background
Pregnancy or maternity
+ Any other classification protected by UK law

We should all demonstrat
Honesty and integrity

Efficiency and reliability
Punctuality and good attendance

‘A smart and clean appearance - and where uniform is provided by
Post Office, it should be worn as intended
A credible image to the public

We do not tolerate any form of bullying or harassment,
whether written, verbal, visual or physical, including:
+ Sexually suggestive statements or actions
Inappropriate or offensive comments or ‘jokes’
Inappropriate conduct or contact
Threats

Valuing diversity and inclusion
We want our people to reflect the diversity of the communities
in which we live and work, and the customers we serve.

We celebrate the diversity of our workforce and the communities we serve by embracing
diversity and inclusion and creating policies which actively promote working without fear
of discrimination.

Everyone working for Post Office has a responsibility to:

Promote a professional and positive work environment

Promote a culture of inclusivity where differences are accepted,
valued and celebrated

Inform their line manager of any instances of apparent discrimination or any
perceived problem in relation to employment

Comply with, and promote Post Office policy and procedures with regard to
diversity and inclusion. You can view our Valuing Diversity Poliey, hee

We actively support:

Flexible working practices, which you can read more about hers
Women in Leadership Programme to support and nurture female talent

Post Office Prism: a network of lesbian, gay, bisexual and transgender
(LGBT) colleagues and their allies, The group supports and celebrates the
Post Office LGBT community and provides advice and guidance to our
business on inclusivity and diversity

Disability Confident Group: a network of Post Office colleagues with
disabilities and colleagues who want to support them. The group provides
support and advice and helps the business do the very best it can for
employees with disabilities

Language:

‘The common language of business should be English (English or Welsh in Wales). However,
s0 long as it doesn't jeopardise the job or health and safety of colleagues or members of the
public and doesn't deliberately exclude people, colleagues should be able to communicate
in their own language, within reason,

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“We support
and encourage
our people

and unions to
get involved

in pursuing a
healthy and safe
way of living
and working.”

Creating and maintaining a safe and
healthy place of work

We strive to work as safely as possible.
Everybody has the right to work in a safe and healthy environment.

We will fulfil our promises without compromising the safety of
our customers, colleagues, suppliers, and all those affected by

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Health and wellbeing
We seek to enable colleagues to achieve a positive balance
between their work and their lives outside of work.

We take health and wellbeing seriously. That's why we work hard to promote a positive
wellbeing culture and provide a range of services to help all our people stay mentally and
physically healthy.

our activities

Pursuing this aim reflects the high value we place
on our employees, and all those touched by our

business activities:

We ensure that the
health and safety
responsibilities of our
employees, including
managers. are clearly
defined, allocated
and understood

We encourage and
help all managers and
employees to carry out
their responsibilities
through effective health
and safety management

We support and
encourage our people
and unions to get
involved in the health
and safety performance
of our business

We support and
encourage our people
and unions to get,
involved in pursuing a
healthy and safe way of
living and working

We monitor and review

systems, with safe
premises, equipment
and processes

how well we put our
health and safety
policies into practice
We improve our

employees’ capability

to manage and work

safely, through coaching

and training

We are all responsible for health and safety. It is an employer's duty
to protect the health, safety and welfare of their employees and other
people who might be affected by their business. A full copy of the
Health and Safety policy. and all associated policies, can be found on
the He f

What we offer:

for colleagues and
their families - to support our people
to stay fit and healthy

Monthly health and wellbei
campaigns, helping to raise
awareness of what we offer and how
our people can stay healthy

Health checks ~ a rolling programme
Using kiosks and mobile kit

programme for colleagues ~ partners
and managers can provide advice
and guidance on a variety of topics in
full confidence

OH Assist Managers Portal provides
advice and guidance for managing
health and wellbeing

for managers to request support for
their teams during challenging times

Training for colleagues to raise
awareness on specific issues relating
to health, safety and wellbeing

My HR provides expert advice and
guidance for all managers on any HR
related issue. Visit www.myHRhelp.
co.uk for more information

Code of Business Standards
Protecting the environment
Everyone has a part to play in reducing our environmental impact.

Post Office promotes initiatives that save on the resources we use. We recognise that our business
activities and policies have an impact on the environment and we are committed to taking account of the
environmental and ethical effects of our policies in our planning and operations.

In standards of design and cleanliness, we recognise our responsibility to ensure that our premises are a
credit to the communities in which they are situated.

We aim to reduce our environmental impact through:
Reduction in the use of water
Efficient use of energy and a reduction in our CO: emissions
Reduction in waste to landfill and maximising recycling opportunities

The use of sustainable materials

Use of alcohol, tobacco and illegal drugs

Possession or use of alcohol or illegal drugs while on Post Office premises
or while conducting company business is prohibited.
The exception is that during business dinners and events, or in designated areas, we may provide and

drink alcohol in moderation, where permitted by law. Smoking (including vaping and e-cigarettes)is not
allowed on company premises.

“We recognise that our business activities and
policies have an impact on the environment,
and we are committed to taking account of the
environmental and ethical effects of our policies
in our planning and operations.”

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Use of computers, internet, phones and email
The security of our information and IT systems is critical.

Many colleagues will have access to Post Office systems, information and devices such as laptops and
mobile phones. It’s really important that anyone who accesses them knows how to keep them secure by
following the requirements in the Acc se policy. For example, these devices must not be left
unattended in public areas, screens must always be locked when not in use, and the use of privacy screens
should be adopted when working in public areas.

Failure to comply with the Acceptable Use policy can carry profound consequences for Post Office and
individvals. Breaches of the policy or the law may lead to disciplinary action up to and including dismissal

To help protect our systems and information, you should:

Classify information in line with our
classification standard, as set out in our

Don't become a victim: if you think an
offer is too good. it probably is!

meee Only use approved data storage areas,

Use complex passwords to such as onedrive, Don’ sign up for cloud
protect your access storage services such as Dropbox

Only open emails when you know who
they are from and don't click on unknown
links or open unexpected attachments

Don't store Post Office data directly onto
your personal devices

Don't use your Post Office email address
or password for accessing third party
services such as Linkedin. Use a different
password

Never click on links to go to a website
where you expect to log on - always go
to the website directly

Safeguard confidential information against
abuse or unauthorised disclosure, and
comply with laws protecting personal
data, See the Protecting Personal Data
policy for more information

If you become aware of any information security issue or incident you should always report it to the IT

Helpdesk on “pr email post

Further information can be found on the Infor
Acceptable Use policy can be found on the intranet

RO

.e team intranet site. The

Code of Business Standards
Social media
Digital and social media is a key part of modern life.

New digital technologies can help us engage actively with our customers. We can promote what we do
and draw on innovative ideas. However, with these benefits comes greater responsibility

As more colleagues can access the internet at work both on personal and official devices, itis important
that we maintain the highest levels of propriety at all times. We must always act in a way that does not
compromise the trust and confidence of our customers or the standards of behaviour expected of us.

Colleagues are free to use social and other digital media in their own time. Social media is a public forum
and the boundaries between professional and personal can become blurred ~ so it’s important that we
exercise particular care to ensure:

We must not disclose official information
relating to clients, partners or suppliers
without the prior authority of the business

Post Office brands or logos are not used or
altered without prior permission

Copyright and fair usage laws and
restrictions are respected and observed You must not appear to be endorsing
any product or service (including

Social media is not used to offend, harass
retweeting comments)

or bully people

The simple rule to remember is that the principles covering the use of social and other digital media in
both work, and in a personal capacity, are the same as those contained in this Code of Business Standards
and company policies that apply for any other activity.

Engaging with the media

Where a colleague is asked to make a comment about Post Office in a published form external to the
business, such as a newspaper, magazine, journal, radio, television or a website, they must direct the
request to our Press Office, They can be contacted or GRO I

Political activity

Colleagues have the right to participate as an individual in
political activities.

However, these activities are conducted as an individual and not as a representative of Post Office.
Post Office is a politically neutral organisation and our reputation must not be compromised by your
interest, affiliation or activities to a political party's pressure groups or other causes.

No matter what your own political beliefs are, you must not act or behave at work in a way that is
determined by party political considerations, or use Post Office resources for party political purposes, or
allow your personal political views to determine any advice you give or your actions.

Conflicts of interest

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We ensure that information received during our business
dealings is not used inappropriately for corporate or personal
gain, or any other purpose except that for which it is given.

If you feel that you might have a potential conflict of interest, inform your line manager and
seek their advice if you are unsure. Be open and frank about any outside activity or business
you are involved in which may conflict with Post Office or your duties as an employee.

The essential principles are:

You must not do anything which
conflicts with your duty as an
employee or agent of the company,
or use your official position for
private advantage

You must declare any outside
employment, directorship or material
shareholding, and these must not be
contrary to the company’s commercial
interest or bring it into disrepute

Your actions as an employee or agent
at work must not be improperly
influenced by any relationship (e.g
with relatives, friends, marriage.
partners or membership of any social,
religious or political association) or by
any personal or financial consideration

No one should exploit their personal
or family relationship with any
colleague for any gain including to
themselves or others

If you receive a fee from an outside
source for performing a service which
forms part of your official duties

or takes place in business time, e.g
giving an inter view or lecture, you
must report it to your manager. You
will normally be expected to pay the
money to Post Office or to a charity
connected with it

IF the service arises from your work but
is not directly connected with it and is
given in your own time, you must still
report it to your manager

Code of Business Standards
“You must not
accept any gift,
payment or
inducement that
might influence
(or seek to
influence) your
actions as a
Post Office
employee.”

Gifts and sponsorship

In general, the giving and receiving of gifts is not
permitted except for low value promotional items,
such as pens, calendars, diaries, notepads and
paperweights.

You can find out more by reading the Anti-Bribery and

Corruption policy. This can be found on the Policies page of
the intranet

You must not accept any gift, payment or inducement that
might influence (or seek to influence) your action as a Post,
Office employee. If any such offer is made to you, you must
report this via the online form, found hore

You must not accept cash or cash equivalent (eg, Gift Cards)

Equally, you must not offer any bribe or inducement to
anyone else

You must not ask for or accept sporting or charitable
sponsorship from an organisation that has (or is seeking) a
contract to supply the company, or isin competition with
it. You must declare to your manager any plan to accept
sponsorship and ask if there is any conflict

If an employee, consultant or third party working with the group
acts outside of this procedure, they will be subject to disciplinary
action up to and including dismissal for gross misconduct/termination
of contract.

Hospitality and entertainment

Hospitality may only be given and accepted where it has a clear
and demonstrable link with a legitimate business purpose, e.g. an
organised event or a meal at which business is to be discussed.

In relation to offers of hospitality, numbers on both sides should be limited to those whose
presence is necessary to progress the business in hand.

Maintaining our standards means the giving and receiving of hospitality and
entertainment is subject to the following rules:

You must obtain prior permission from your line manager before accepting or
giving hospitality

The hospitality must be reasonable (not lavish or extravagant), proportionate to its
purpose and must ordinarily be below £200 per person in value

You must report details ofall hospitality offered or accepted via the online form
found here

You should be aware of the risk that accepting any hospitality and entertainment could
compromise your performance of official business, or might reasonably appear to have
improperly influenced a business decision.

Use sound judgement and exercise restraint. If you are still unsure about the standards

required of you, consult your manager or view the y and Anti-Corruption
policy; this can be found on the Policies page of the intranet.

if an employee, consultant or third party working with the group acts outside of this
procedure, they will be subject to disciplinary action up to and including dismissal for gross
misconduct/termination of contract.

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Fraud and financial crime

Modern slavery

We seek to comply fully with relevant legislation.

We take protecting our customers and their information extremely seriously. We invest significantly in
activities to detect, deter and prevent all aspects of financial crime, either committed on Post Office, or
where Post Office might be used unknowingly to facilitate such action.

Modern slavery is a crime and a violation of fundamental human rights.
It takes various forms, such as slavery, servitude, forced and compulsory
labour and human trafficking, all of which have in common the
deprivation of a person's liberty in order to exploit them for personal or

We aim to protect our customers,
maintain value for our shareholders and
assist society in combating crime by
preventing criminals from benefiting from
their activities and proceeds

‘We promote high ethical standards and
have a zero tolerance for circumvention of
our fraud and financial crime policies

‘Our colleagues are supported by
mandatory training to develop their
understanding of financial crime risks
including Anti-Money Laundering,
Counter Terrorist Financing, Sanctions,
Politically Exposed Persons and Anti-
Bribery and Corruption regulation

commercial gain.

+ Post Office is committed to acting
‘ethically and with integrity in all our
business dealings and relationships and to
implementing and enforcing the systems
and controls set out in our Modern
Slavery Statement with the aim of
ensuring that modern slavery is not taking
place anywhere in our own business or in

The prevention, detection and
reporting of modern slavery in any
part of our business or supply chains

is the responsibility of all Post Office
‘employees at all levels, a well as of
its directors and officers. Our Modern
Slavery statement can be found on our
website, he

‘We operate systems and controls designed to ensure that our products and services are not abused for
the purposes of laundering the proceeds of crime. Full details are available in the A

Terrorist Financing policy or the Fina Overarching policy. These policies can be
found on the Policies page of the intranet.

Money Laundering

Risk management
Effective risk management is integral to the management of our business

(Our risk management processes and practices are intended to help you make better informed decisions,
increase the likelihood of meeting our strategic objectives, achieve customer excellence and safeguard
our business interests. Effective risk management is demonstrated by how we behave - considering risk in
everything we do - from decision-making, to operational management. We encourage people to consider
and assess risks, manage them and be transparent throughout.

any of our supply chains

If you witness any signs of modern slavery within ous business or supply chains, you should
raise your concerns via our Speak Up linen, GRO__I

Consequences of non-compliance for the
code of business standards
Compliance to Post Office Code and policies is not optional.

Itis everyone's responsibility to follow our Code of Business Standards and the various related policies,

Failure to comply with company policies and the law can carry profound consequences for
Post Office and potentially for you

+ Where non-compliance with the Code, company policies or the law has been identified in
accordance with established company investigatory procedures, we will take swift and decisive
action against an offending party. up to and including, the termination of individual and or third
party contracts as appropriate

Post Office does not tolerate any form of retaliation against colleagues or third parties who have
made reports, in good faith, of threatened, ongoing, past or suspected breaches of this Code of
Business Standards

This Code will be subject to review annually and/or to implement and reflect changes in the law,
Best Practice or Post Office policies.

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Making proper decisions and seeking help

At Post Office, we set ourselves exacting standards. All
our stakeholders, and others with whom we work, have
an expectation that they will be treated professionally.

Even

h good judgement and the best intentions, we may not always know
° ig with our other
1ed to help us make proper decision:

the most se of action to take. The Code, alo

company policies, i

propr

dilemma, after reviewing the relevant parts of the Code,
questions to help make the right decision’

if you are faced w
ask yourself a few

Am ocedures?

hering to the Code, other policies and

‘Am I being honest?

What would others think of my actions?
How might my decision affect others?

Would I feel comfortable if my actions were reported in the media?

How would my decision impact on Post Office reputation?

to the right thing to do. you should talk with your

if you are still
manager and discus
We all share a responsibility to report concerns of actual or potential breaches of
the Code of Business Standards, company policies and the law.

if you witness or otherwise learn about the company's standards and reputation
by unethical or even criminal behaviour, you must immediately,
t investigating, report it

feel you can't talk to your own manager and
confidentially, please contact the Speak Up line o:

information can be found in the

nt to speak to someone

page of the intranet. You can also email

Code of Business Standards

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