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ee)
Code of Business
Standards
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
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.
I 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.
‘GRO
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. It is 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’.
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Observing the Code
Everyone employed by Post Office is required to
adhere to the Code; they are expected to operate in
line with it and the corresponding Group Policies.
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
All line managers have access to the My HR Help service which supports
managers with team management queries. Visit www.myhrhelp.co.uk
Our brand
Our brand experience, for employees, customers,
partners and stakeholders is shaped by our core
values of Care, Challenge and Commit.
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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NOTE
Please be aware that
any breach of this
Code may be dealt
with under our
Conduct Code, and
that gross
misconduct could
result in your
dismissal.
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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
“We don’t just
CODE OF BUSINESS STANDARDS work for'Post
Offiroa we ore
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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. It'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 just 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. If 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 Our Post Office.
Personal behaviours
NOTE
If you have a concern
about bullying and
harassment, you can
speak to your ARE OF BUSINESS STANDARDS 9
manager or refer to
the Dignity at Work
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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, a journey you did 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 demonstrate:
Honesty and integrity
Efficiency and reliability
Punctuality and good attendance
Asmart 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:
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.
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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 Equality, Diversity and Inclusion Policy, here
We actively support:
Flexible working practices, which you can read more about here
‘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,
so 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.
Creating and maintaining a safe and
healthy place of work
“We support
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our people and
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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
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
systems, with safe
premises, equipment
and processes
We improve our
employees’ capability
to manage and work
safely, through coaching
and training.
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
how well we put our
health and safety
policies into practice
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 Health and Safety intranet site.
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
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wellbeing culture and provide a range of services to help all our people stay mentally and
physically healthy.
What we offer:
Lifestyle online for colleagues and
their families — to support our people
to stay fit and healthy
Monthly health and wellbeing
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
HELP employee assistance
programme for colleagues — partners
and managers can provide advice
and guidance on a variety of topics in
full confidence.
Protecting the environment
OH Assist Managers Portal provides
advice and guidance for managing
health and wellbeing
Occupational Health Referral Portal
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
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related issue. Visit www.myHRhelp.co.uk
for more information
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
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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 COzemissions
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
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 Acceptable Use policy. For example, these devices must
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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 individuals. 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 » Don't become a victim: if you think an
classification standard, as set out in our offer is too good, it probably is!
Information Classification Standard - Only use approved data storage areas,
Use complex passwords to such as one drive. Don’t sign up for cloud
protect your access storage services such as Dropbox
Only open emails when you know who » Never click on links to go to a website
they are from and don’t click on unknown where you expect to log on — always go.
links or open unexpected attachments to the website directly
Don’t store Post Office data directly onto « Safeguard confidential information against
your personal devices abuse or unauthorised disclosure, and
Don’t use your Post Office email address comply with laws protecting personal
or password for accessing third party data. See the Protecting Personal Data
services such as LinkedIn. Use a different policy for more information
password
y_information security issue or inci
lor email postofficeservicedesf GRO
Further information can be found on the Information Protection and Assurance team intranet site.
The Acceptable Use policy can be found on the intranet.
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, it is
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.
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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:
Post Office brands or logos are not used - We must not disclose official information
or altered without prior permission relating to clients, partners or suppliers
Copyright and fair usage laws and without the prior authority of the business
restrictions are respected and observed « You must not appear to be endorsing any
Social media is not used to offend, harass product or service (including retweeting
or bully people comments)
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 Pi Office. They can be contacted ot
pressoffice
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.
Conflicts of interest
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 as per the Conflict of Interests Policy,
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.
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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 interview 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
Gifts and sponsorship
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“You must not The giving and receiving of gifts must be reported and
approved, and ordinarily be below £100 per person on
accept any value. Items costing £20 or less, such as pens,
gift, payment calendars, diaries, notepads and paperweights do not
or inducement need to be reported and approved.
that might
influence (or
seek to
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actions as
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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 obtain prior approval from your line manager before accepting or
giving any gift over £20.
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
Record full details via the online form, found here
You must not accept cash or cash equivalent (e.g. 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 is in 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
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:
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You must obtain prior approval 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 — if over £200 it must also be
approved by your GE member.
You must record full details of all 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 Anti-Bribery and 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
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.
We aim to protect our customers, - We promote high ethical standards and
maintain value for our shareholders and have a zero tolerance for circumvention
assist society in combating crime by our fraud and financial crime policies
preventing criminals from benefiting from + Our colleagues are supported by
their activities and proceeds mandatory training to develop their
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of
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understanding of financial crime risks Politically Exposed Persons and Anti-
including Anti-Money Laundering, Bribery and Corruption regulation
Counter Terrorist Financing, Sanctions,
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 Anti-Money
Laundering and Counter Terrorist Financing policy or the Financial Crime_policy.
These policies can be found on the Policies page of the intranet.
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.
Modern slavery
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 commercial gain.
Post Office is committed to acting ensuring that modern slavery is not taking
ethically and with integrity in all our place anywhere in our own business or in
business dealings and relationships and to any of our supply chains
implementing and enforcing the systems - The prevention, detection and
and controls set out in our Modern reporting of modern slavery in any
Slavery Statement with the aim of part of our business or supply chains
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is the responsibility of all Post Office Slavery statement can be found on our
employees at all levels, as well as of website here.
its directors and officers. Our Modern.
If you witness any signs of modern slavery withi or supply chains, you should
raise your concerns via our Speak Up line on
Consequences of non-compliance for the
code of business standards
Compliance to Post Office Code and policies is not optional.
It is 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
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 with good judgement and the best intentions, we may not always know
the most appropriate course of action to take. The Code, along with our other
company policies, is designed to help us make proper decisions.
If you are faced with a dilemma, after reviewing the relevant parts of the Code,
ask yourself a few questions to help make the right decision:
Am I adhering to the Code, other policies and procedures?
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?
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How would my decision impact on Post Office reputation?
If you are still unsure as to the right thing to do, you should talk with your
manager and discuss your questions and concerns.
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
being put at risk by unethical or even criminal behaviour, you must immediately,
and without investigating, report it.
If you feel you can’t talk to your own manager and we
confidentially, please contact the Speak Up line on
information can be found in the Whistleblowing Policy availabie’on the Policies
page of the intranet. You can also email whistleblowing¢
DOCUMENT CONTROL RECORD
SUMMARY
GE Policy Sponsor I Policy Owner Policy Implementer I Policy Approver
Employee Relations Head of Employee
and Policy Director Relations
Lee Kelly Janene Mellor
Group HR Director
Group HR Director
Mohinder Kang
Mohinder Kang
Document Review Policy — effective
Version Policy location
Period date
1 24 Months 08/01/2018 UK
REVISION HISTORY
Version I Date I Changes Approved by
Removed reference to B&H policy and
2 01/10/18 included Dignity at Work Janene Mellor
Minor amends to Gifts and Sponsorship .
3 17/12/18 and Hospitality and Entertainment Sally Smith
4 08/04/19 Updated hyperlinks Janene Mellor
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DOCUMENT DISTRIBUTION STATUS
I Mark x as
Mark x as ne :
Sparopeate Document Sensiti apotentict
Internal x Non-sensitive x
External Sensitive
QUALITY STATEMENT
Quality Control Next Review Date
This document is periodically re
years from the last effective date.
This policy has been reviewed against the latest Post Office
policy standards and legislative requirements.
wed, and at least every 2
Jan 2020
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