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Fe)
Code of Business
Standards
CONTENTS
A letter from Nick Read, Group CEO
Introduction
About Post Office
Qur purpose
Qur intent for 2025
Qur ways of working
Be Aware
Why we have a code
Who must follow this code
How to make good decisions
When a breach occurs
Reporting concerns
Fair Treatment of Employees
Embrace diversity and inclusion
Prevention of Modern Slavery
Be kind and respectful
Creating a safe and healthy work environment
Protecting the environment
The use of social media
How we Conduct Business
Prevent bribery and corruption
Fraud and financial crime
Risk Management
Use of computers, internet, phones and email
Protecting Post Office Information
Personal data and privacy
Maintaining accurate business records
Financial Accuracy
Communicating with the public
Choose suppliers with integrity,
Avoiding conflicts of Interest
When do conflicts of interest occur?
Family members and close working relationships
Qutside board members
Political activity
The last letter
CODE OF BUSINESS STANDARDS
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A Letter from Nick Read
Welcome to the most important document we have at Post Office — our Code of Business Standards
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.
The Code of Business Standards (the Code) defines the expectations we have for how we act and
how we make decisions. It sets out our clear standards of conduct to ensure that we always make
the right choice. It’s a document which not only protects Post Office but each and every one of us.
Read and re-read our Code. It matters. Think about how it applies to your work. Consider how your
behaviours, actions and decisions may affect others.
The way that we conduct business has never been more important which is why I expect everyone at
Post Office to follow our Code, advocate for others to do the same, and feel empowered to speak up
if you need help or have questions.
Thank you for your commitment to ensure our customers and the communities we serve continue to
place their trust in us.
Sincerely
Nick Read
Group CEO
CODE OF BUSINESS STANDARDS. 3
Introduction
About Post Office
Post Office is the Uk’s largest retail network
and the largest financial services organisation
in the UK. We have provided services for more
than 370 years and currently supply a range
of essential products and services to
communities’ right across the UK
Our UK Government mandate is to provide at
least 11,500 Post Offices, some within certain
geographical, demographic and social criteria
that provide a unique operational challenge for
Post Office compared to other wholly
commercial retail or financial institutions. We
are often at the heart of the local communities.
Post Office directly manages around 1% of
the Network of branches which consumers
will generally recognise as the larger branches
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often situated in the centre of towns and cities
across the UK. The remainder of the branches
are managed on a franchise basis by
independent small retailers and shop owners
operating Post Office services within their
own store. Business owners may own more
than one shop operating Post Office services
and have a range of other non-connected
business interests. We also have Franchised
facilities within some larger high street
commercial partners, who like the smaller
independent retailers, provide their own
trained and friendly staff to provide our Post
Office services to consumers.
At Post Office we are committed to doing
business the right way.
CODE OF BUSINESS STANDARDS
Our purpose
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‘We're here in person, for the people who rely on us’
Our Intent for 2025
Our intent for 2025 is to be the operator of
a successful, sustainable, and sought-after
franchise and an organisation that
colleagues feel proud to work for. There are
seven strands to our future success:
1. Wewill prioritise strong, trusting and
rewarding relationships with all our
Postmasters
2. We will grow our network, making sure
we have the right branches in the right
locations nationwide.
3. We will innovate in Mails, working with
more carriers and delivering more of what
customers want and small businesses
need.
4. Wewill secure free, convenient and
reliable access to cash in every
community.
5. We will build commercial partnerships, to
launch new products and services in our
branches and online.
6. We will invest in new branch
technology for Postmasters and online for
their customers.
7. Wewill create value for our
shareholder with a successful, sustainable
and efficient business.
Beyond that, we intend to work with
Government on the various means by which
we could deliver on a long-term aspiration to
facilitate profit sharing with our Postmasters,
so Postmasters can share fairly in our success.
Our Ways of Working
We all want Post Office to be a great place to
work. A friendly, helpful environment, where
we work together collaboratively to achieve
the same aims.
Created by colleagues, for colleagues, our
Ways of Working reflect the kind of culture
you would like us to have and set out how we
need to work together to deliver our Purpose
and our Intent. Everyone has a part to play in
bringing them to life — by working in
partnership, as one team, we deliver amazing
results. We are Post Office.
We need to put the relationship with our
Postmasters and branches at the centre of
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what we do. This means getting the whole
business aligned behind our frontline to
ensure we deliver.
We can all help to make Post Office an
organisation that everyone is proud to work
for. By living our Ways of Working each and
every day, we can all learn from and inspire
one another, as we strive to do our best for
our Postmasters, our customers and each
other.
Each of our Ways of Working is supported by
six statements to bring to life exactly how we
will put them in to practice.
“We're here,
in person, for
the people who
rely on us”
Ways of Working
Working in partne
deliver
ver amazing results
CODE OF BUSINESS STANDARDS.
Our Ways of Working
We work in Partnership
Partnerships are at the heart of the way we
work; they allow us to achieve far more than
we could alone. In short, we are stronger
together. Each partner brings different
capabilities and resources, but it only works if
we accept each other as equals and the
partnership benefits both parties.
It’s always important to respect each other's
unique perspectives, but for partnerships to
work we need to find common ground and
shared goals. We also need to build trust by
being open about our aims, and to deal with
any problems together. Be aware that
partnerships evolve over time so it’s important
to regularly check that both parties are still
happy and that you still share the same
objectives.
1. We place those who work in Post
Office branches at the centre of
everything we do
2. We invest time and energy into
trusted and valued partnerships
3. We build lasting relationships with all
our partners
4. We respect and recognise each
other’s challenges
5. We enable our Postmasters and
DMBs to serve their communities
6. We are stronger together
We are one team
Every day we are faced with decisions to
make and we strive to achieve the right
outcome. Often two heads are better than one
and three would be better still
It’s important to remember that our
colleagues’ success is our success and vice
versa. Diversity of thought is important
because different ways of thinking drive
innovation and ensure that everyone feels
included. So, be open with your colleagues,
CODE OF BUSINESS STANDARDS.
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listen to them, and share your views. Working
as one team is powerful and is already
transforming our culture, but we need your
help to create an environment where everyone
feels empowered to speak up and share their
feelings, thoughts and ideas.
We collaborate and share freely
2. We listen to understand and then
respond
3. We celebrate success and say
thank you often
4. Weare helpful, friendly and
available
5. We trust and empower everyone to
make decisions
6. We act with integrity and are open
and honest
We deliver
Delivering effectively is the end result of
working well as one team, with our partners —
it's a collective effort around a shared goal.
In order to deliver, we need to be outcome
driven because this helps to clarify our
approach, making it simpler and quicker to
make decisions. Learning from our mistakes is
also crucial and makes it easier to deliver more
effectively next time.
Delivering well and consistently builds trust; it
will give us a reputation for being reliable and
for doing what we say we will do.
1. Weare reliable and always do what
we say we will do
2. Weare passionate about the service
we provide
3. We learn from our mistakes
4. We embrace change and find ways
to innovate and improve
5. We are outcome driven
6. We work to keep it simple and get
stuff done
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Our Ways of Working
Our Ways of Working are wrapped around and inclusion, encourage learning and
growing, and champion taking care and
our ‘We are Post Office’ colleague
commitments where we celebrate diversity supporting each other.
‘We work in partnership
Caring and support"
We deliver
We are one team
CODE OF BUSINESS STANDARDS.
Be Aware
Why we have a Code
As a purpose-led company, our ‘Ways of
Working’ are the foundation to our success
and essential to achieving our ‘Purpose’.
Post Office’s Code of Business Standards and
the policies that support, set out the standards
required from all our employees.
Sometimes, you might face a situation where
the right thing to do is not obvious. That is
where our Code of Business Standard can
help. It is always here as your guide to
preserving our reputation. While the Code
cannot answer every question, it can show
you where to go for guidance when the
answer is not clear
The code enables you to:
= Conduct yourself honestly and ethically.
* Upholds our ways of working and protect
our reputation.
= Understand what Post Office expects
from you.
* Make good decisions every day.
= Comply with the laws, regulations and
standards that apply to our Company.
* Understand where to go for assistance or
guidance if you have any questions.
Who must follow this Code?
It does not matter where you work or what
you do for the Company - you have
a responsibility to use good judgment and
follow our Code. That includes every
full-time or part-time employee at every level
of the Company.
As employees, each of us has as a
responsibility to:
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= Know and live the Code. Read it and
follow it, along with any other policies that
apply to your job.
- Complete relevant mandatory training
on time as required by the company.
* Think before you act. Use good judgment,
being honest and ethical in every action
you take, ensuring you demonstrate
respect for others.
«Follow the law. Understand and ensure
compliance with laws that apply to your
job and our company. If you are ever
unclear about a law or regulation speak to
your manager.
= Ask for help. When an answer is not
clear, ask for guidance before taking
action.
* Report concerns. Prevent harm to our
company and its reputation by reporting
your concerns of potential unlawful
behaviour or violations of the Code as well
as co-operating with Company
investigations.
* Never retaliate against anyone who raises
a concern in good faith about a possible
violation of the Code or who cooperates in
an investigation.
People managers and leaders have additional
responsibilities to serve as a positive role
model in every respect and to help our
employees review, understand and apply the
Code. The way our managers make decisions,
and handle concerns, different opinions, and
even bad news, will set the foundation for
trust with teams.
Take these simple steps to build a culture of
trust and integrity within your team.
= Lead by example and model the Code
and our ways of working.
* Talk about the Code. Ensure that all
colleagues, including new joiners:
- Have read the Code
- Have completed any mandatory
training
- Understand how to raise concerns
and/or report actual or suspected
breaches
* Be informed. Recognise that you may not
always find the answers that you need in
the Code, so know where to go for
answers when there are questions.
* Expect the best. Ensure your team knows
that for results to matter, they must be
achieved the right way.
«= Be responsive and create a “speak up”
culture. Create an environment that
fosters and enables ethical behaviour,
where employees are comfortable
speaking up without fear of retaliation.
Take seriously any concern raised by an
employee that compromises the Code and
determine if the issue should be escalated.
«Take action. Take corrective or preventive
action when someone violates the Code
How to make Good Decisions
Even with good judgement and the best
intentions, we may not always know
the most appropriate course of action to take.
Doing what is right is our goal. The Code,
along with our other company policies, is
designed to help us make the right decisions.
If the right thing to do is not clear, ask
yourself:
Am I being honest?
Is it consistent with our code?
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Does it follow our policies and
ways of working?
What would others think
of my actions?
Would I be comfortable if my
actions were made public?
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.
When a breach occurs
Compliance with the Code and our company
policies is not optional.
Whenever we become aware of a breach of
the Code, company Policy or the law, we will
act to address the problem and prevent future
occurrences. Depending on the circumstances,
corrective and preventive steps might include
training, counselling and disciplinary action up
to and including termination of employment. If
an act violates the law, it could result in fines
or criminal prosecution.
The Company has other policies and
processes governing performance, conduct
and behaviour. Policy breaches that are not
Code breaches will be handled under the
appropriate policy or procedure.
10
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WE DO
Reporting Concerns
To help us build the Post Office of the future
we are committed to doing things correctly
and we want you to always raise issues and
concerns with us. A healthy organisation is
one where people can speak up without fear
and, as a result, stop harm.
Noticing a problem and speaking up about it
helps us address issues quickly. This in turn
helps ensure that we can enhance Post
Office's processes and controls and support
our Postmasters and the communities that we
serve.
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,
report it.
Post Office encourages everyone to raise any
concerns that you have with your line
manager, but we recognise that sometimes
this may be difficult or inappropriate, and
therefore a number of different reporting
mechanisms are available to raise your
concern:
* A senior member of the People team, or
* Direct to the Whistleblowing Manager
(whistleblowing
* Contacting the ‘Speak Up‘ line, a
confidential reporting service which is run
by an independent company called
Convercent:
- Telephone Numbe }
- _ http://speakup.postoffice.co.uk/ which
is a secure on-line web portal
*\
\
Learn mor
Whistleblowing Policy
reporting
CODE OF BUSINESS STANDARDS.
NOT
Retaliate
No Retaliation «
It takes courage to speak up when
something’s not right. We understand that
you might be uncomfortable or anxious. That
is why we do not tolerate retaliation of any
kind, against anyone who shares a concern in
good faith or participates in any investigation
into that concern. Concerns raised honestly
even if they turn out to be unfounded is never
an excuse for any kind of retaliation.
We take serious action, typically disciplinary
action, against any individual who threatens or
retaliates against individuals who have raised
their concerns.
What is Retaliation?
We define retaliation as any action that would
likely deter someone from reporting a concern
or participating in investigation. Examples of
retaliation might include demotion, firing, a
reduced salary, job reassignment, threats,
harassment or any other action taken against
someone because they raised a concern,
participated in an investigation, or attempted
to deter someone from violating.
No False Accusations
As much as we encourage honest reporting,
we do not tolerate knowingly false reports.
Making a false accusation can divert
investigatory resources away from credible
good-faith concerns and damage morale.
Report what you have a reasonable, good-
faith belief be true, but never knowingly make
a false accusation, lie to investigators or refuse
to cooperate in an investigation, as these
actions may also violate our Code.
Speaking up
By asking ques
ions and
ncerns, you are
doing the right thing and helping 11
our Company stop or prevent
misconduct.
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Fair Treatment of Employees
In our People related processes, such as recruiting, developing, promoting and other employment
activities, we are committed to complying with the applicable employment and labour laws and
regulations. These include, wage & working time, privacy, immigration, compulsory child labour,
modern slavery, collective bargaining, anti-discrimination and similar employment rules.
Complying with the legal requirements is only part of the formula for cultivating a culture of respect in
our workplace — we are all responsible for assuring that everyone at Post Office is treated with
respect and given fair consideration.
Embrace Diversity and Inclusion
We are committed to building a diverse and
inclusive workplace in which everyone feels
like they belong and are empowered to bring
their authentic self to work
Embracing diversity and inclusion means we:
* Strive to promote fairness and equal
opportunities for employment and
promotion based on experience,
qualifications and skills.
* Are respectful of the differences between
people and their circumstances and do
not tolerate discrimination or harassment
on the basis of any legally protected
characteristics.
«= Encourage ideas, opinions, and ways of
thinking that may be different from our
own and prohibit exclusionary
behaviours, which may include, bullying
and workplace violence, discrimination
and isolating individuals and groups who
are different.
Learn more:
Equality, Diversity and Inclusion Poli
Q:1 want to make a promotion decision.
One colleague is 50 and
age and the other 30. Should I promote the
ice they may work for
us for many more years?
ring retirement
younger colleague
A: No, We only make employment
decisions based on job-related skills,
achievements and performanc
= Foster an inclusive and respectful
workplace by assessing our conscious
and unconscious biases, removing
barriers to inclusion, focusing on
systemic equity in our people processes
and company procedures for consistency
and fairness, being a supportive ally and
standing up for others.
* — Invest in the physical, mental and
emotional well-being of our employees
through ongoing education around
inclusion and diversity initiatives.
Post Office strives to build an inclusive
workplace where we celebrate diversity and
inclusion with all employees feel a sense of
belonging and valued for who they are and
the differences they bring. Post Office does
not tolerate discrimination based on the
grounds of race, ethnic or national origin,
disability, martial or civil partner status, sexual
orientation, pregnancy or maternity, age,
religion or belief, sex and gender
reassignment.
Be Kind and Respectful
We have a responsibility to create a .
respectful and inclusive workplace. It is
important that you feel valued and respected
and that you are treated fairly. .
You must:
= Familiarise yourself and comply with .
Equality, Diversity and Inclusion and
Dignity at Work policies.
= Understand employment and equal
opportunities laws and local culture that
may have an impact on workplace .
decisions and ways of working.
* Treat every colleague with respect,
regardless of role, position, employment
status or length of service.
= Consider the needs and perspectives of .
others and how our words and actions
might be received.
= Never threaten, act violently toward or
harass others.
Learn more:
Equalit
Dignity at Work Policy
Diversity and Inclusion Polic
Q:A friend
with some rude jokes
think are funny.
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Not insult, bully, disparage, shame or
mock others and be vigilant for signs that
others are being harassed or bullied.
Not retaliate against others—everyone
should foster a culture in which anyone
can comfortably raise a concern without
fear of retaliation.
Speak up through the relevant channels
about anything that may violate Post
Office Diversity and Inclusion policies so
that we can all work together to make
Post Office a great place to work.
Make sure that your conduct when you
are at off-site events is as it would be at
work. Company-organised events include
social events such as Christmas parties,
team events and social outings.
Complete unconscious bias training if
you are to be involved in recruitment
activity.
it me an email
which I
in I email
them to my work colleagues?
A: No. Wet
with dignity and re:
zat all colleagues
and
what you consider funny might
be considered offens
by
others. Always ask yourself
whether your actions might be
offensive, abusive or
intimidating to other
13
Prevention of 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 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 any
of our supply chains.
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.
Learn more:
Modern Slavery Statement
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You must:
« Familiarise yourself with our Post Office
Modern Slavery statement which can be
found on our website here
* Complete the mandatory Modern Slavery
and Human Trafficking training on time
If you have any concerns about the issues
raised in the statement or if you think you
have identified signs of modem slavery within
our business or supply chains, please contact
the below:
* Direct to the Whistleblowing Manager
(whistleblowing¢....... GRO. or
* Contacting the 'Speak Up' line, a
confidential reporting service which is run
by an independent company called
Convercent:
- Telephone Numbe:
- _ http//speakup.postoffice.co.uk/ which
is a secure on-line web portal, or,
«The Government's Modern Slavery
Helpline ort.
Q: I heard a POL supplier
created a work experienc
program that allows minors
under the age of 16 to work
unlimited hours per week
without pay. Should I be
concerned?
A: Yes. The program you
describe violates child labour
laws and also raises suspicion
of human traffickir
modern slavery. You should
eport this con
Creating a Safe and Healthy Work Environment
Whether working in an office, commuting to
work, at home, in depots or branches or out in
the field nothing is more important than you
staying safe and healthy. We care about your
wellbeing; we want to create conditions in
which you are free from harm and free to do
your best work.
We comply with all applicable legislation and
regulations and aim to continuously improve
health and safety performance.
Everyone at Post Office have a role to play.
We all have a duty to ensure a healthy and
safe work environment and work safely
You must:
+ Familiarise yourself and comply with
health and safety policies, risk
assessments, method statements (safe
system of work), standards, procedures,
Learn more:
Health and Safety Policy
Alcohol & Drugs Policy
Physical Security Policy
Health & Wellbeing Policy
Safety, Environment and Wellbeing Team Site
Protecting the Environment
At Post Office we comply fully with all
relevant environmental law and promote
initiatives that save on the resources that we
use
We are committed to taking account of the
environmental and ethical effects of our
policies in our planning and operations.
We can all play an important part in
supporting good environmental practice by
not wasting resources, such as fuel, energy
and paper.
CODE OF BUSINESS STANDARDS.
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laws and regulations relevant to your
work.
Familiarise and comply with all policies
related to physical security.
Work and behave safely, so that we do
not endanger ourselves or others.
Make sure you know what to do if an
emergency occurs at your place of
work/on the road or at a location you are
visiting
Support one another, be aware of and
utilise the business wellbeing and mental
health support resources.
Promptly report any actual or near miss
accident or injury, illness, unsafe or
unhealthy condition so that steps can be
taken to correct, prevent of control these
conditions immediately.
Complete mandatory Health and Safety
training.
Not work under the influence of illegal
drugs, alcohol or any other substance that
could compromise safety or performance.
We should take every
opportunity to recycle or
reuse waste products and
minimise waste to landfill
15
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Q: A co-worker posted an
offensive, sexual comment
about me on their personal
re they
social media pag
The use of Social Media eliowed (0 dota,
A: No. Employee use of online
media must comply with
While it is recognised that all employees are entitled to privacy in their
personal life, Post Office is committed to maintaining confidentiality and
safety whilst also maintaining the reputation of Post Office by exhibiting
acceptable behaviour at all times.
company policies, includin
Dignity at Work polici
Social media is a collective term for websites and applications which focus on communication,
community-based input, interaction, content-sharing and collaboration (this includes sites such as
Twitter, Facebook, Linkedin as well as YouTube, Flickr, Instagram, Snapchat, TikTok and other image
and video sharing sites (not exhaustive)).
Personal use: Post Office understands that you may wish to use your own devices such as mobile
phones, to access social media websites while you are at work, but you should limit your use so not
to interfere with your working day and should be limited to your allocated break times
While using social media in a personal capacity and not acting on behalf of Post Office it should still
be recognised that your actions can damage the Post Office’s reputation. All communications you
make in a personal capacity must not:
Make statements which cause, or may
cause, harm to our reputation or otherwise
be prejudicial to our interests.
Use data obtained in the course of your
employment in anyway which breaches
provisions of the Data Protection Act
2018
Make disparaging or defamatory
statements about the company, your
colleagues, customers, postmasters or
suppliers
Make comments that could be considered
to be bullying, harassment or
discriminatory against an individual.
Respond yourself to negative posts about
Post Office. You may come across
negative or disparaging posts about the
Company or see third parties trying to
spark negative conversations. Avoid the
temptation to respond yourself and
instead let those who are certified
internally know and respond if required,
by reporting to socialt”
Use at work: You are allowed to access social media sites from any Post Office devices in
connection with work related activities, such as posting about our services, upcoming events or
publicising Post Office. You are reminded that they must comply with the below:
Post Office brands or logos are not used
or altered without prior permission from
(GRO I
Do not create any social media accounts
whether for your, Product Category, Area,
Region, Department, Depot without
seeking permission from
soci
CODE OF BUSINESS STANDARDS.
Copyright and fair usage laws and
restrictions are respected and observed.
You must not disclose any intellectual
property, confidential or commercially
sensitive information relating to the
company.
As above don't respond to negative post
about Post Off If, reporting these
16
How we Conduct Business
Prevent Bribery and Corruption
At Post Office, we are committed to a policy of
zero tolerance of bribery and corruption,
recognising that bribery is contrary to
fundamental values of integrity, transparency
and accountability and undermines the Group's
effectiveness. We conduct business using
ethical practices only.
We strictly prohibit bribes, fraudulent conduct,
kickbacks, illegal payments and any other offer
of items of value that may inappropriately
influence or secure an improper advantage
In the drive to be successful in our business,
there may be instances where you are asked
to give or accept a bribe. Do not do it. The
consequences of violating bribery laws can be
severe — for you and for the Company.
Learn to spot a bribe. Bribes come in many
forms, and they are not always obvious. A gift,
the promise of a job, the offer of a trip, a
charitable contribution, all could be considered
bribes, if offered in exchange for any decision
or favourable treatment.
Gifts and Hospitality are part of everyday
commercial life. If you are offered gifts or
hospitality, as a test of appropriateness, you
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should always consider how the acceptance of
the gift or hospitality would be viewed by
others or could be portrayed by the media -
would others see it as appropriate and
proportionate?
We responsibly invest in our business
relationships but never offer or accept gifts,
hospitality of entertainment or anything else of
value to improperly influence people. An
overly generous gift can pressure the recipient
to return the favour or feel indebted to the
giver — with decisions that benefit the giver
and create a conflict of interest or perception
of a conflict of interest.
You must:
* Apply this code in good faith to ensure
gifts and hospitality are never considered
to be excessive, confer improper
advantage or create an actual or perceived
conflict of interest
+ Familiarise and observe monetary limits
that Post Office has set separately for
gifts and hospitality.
* Ensure all gifts and hospitality are
reported and approved, prior to the offer
or acceptance
Prevent Bribery and Corruption
Gifts
The giving and receiving of gifts should
ordinarily be below £100 per person in value.
Items costing £20 or less, such as pens,
calendars, diaries, notepads and paperweights
do not need to be reported and approved.
You must:
* Not accept cash or cash equivalent (e.g.
Gift Cards)
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.
You must:
= Ensure the hospitality is 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:
* Familiarise yourself with and follow the
Anti-bribery and Corruption policy and
procedures.
= Always make clear, internally and when
dealing with third parties, that Post Office
has a zero tolerance approach to bribery
Learn more:
Anti-bribery and Corruption Policy
CODE OF BUSINESS STANDARDS
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and corruption and will not (directly or
indirectly) offer, pay, seek or accept a
payment, gift or favour to improperly
influence a business outcome.
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
Always obtain approval for any gifts or
hospitality offered or received.
Not offer or accept any gifts or hospitality
if the third party or Post Office is currently
or about to tender for a contract for
services involving the other party.
Immediately notify your manager if they
become aware of any suggested or actual
payment or other transaction which has
the potential to be in breach of the Anti-
Bribery and Corruption Policy.
Complete mandatory Anti-Bribery and
Corruption training.
Ask yourself these questions
Is the gift prohibited?
Could it be interpreted as a bribe?
Is it in line with our (or their_ gift policy?
Could it influence a business decision?
How would it be perceived if it were
publicly disclosed?
If any of these questions raise doubts, you
should speak to your line manager
18
Fraud and Financial Crime
At Post Office we are committed to conducting
business in a way that prevents the use of our
product, services and business transactions by
those who might abuse them, so we comply
with anti-money laundering, financial crime
and anti-terrorism laws
Money laundering is the process criminals use
to conceal, disguise, and dispose of money and
assets obtained from criminal activity,
changing them into clean money or assets that
have no obvious link to their criminal origins -
such as terrorism, drug dealing, tax evasion,
human trafficking and fraud.
You may be committing an offence, and be
prosecuted if you carry out a transaction
where you know, or suspect, that the funds
are intended for use in support of money
laundering or terrorism, regardless of whether
the funds were the proceeds of criminal
activity or lawfully derived.
Learn more:
Anti-Money Laundering and Counter Terrorist Financing Polic
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Full details are available in the Anti-Money
Laundering and Counter Terrorist Financing
policy or the Financial Crime policy.
You must:
= Familiarise yourself with and follow Anti-
Money Laundering and Financial Crime
policies.
= Understand and follow procedures and
internal controls that are designed to
prevent individuals in money laundering
and engaging in other illegal activities
"Be proactive when it comes to spotting
financial transactions that might signal a
problem and report your concern (to
Grapevine on Jif you see
or suspect an activity of transaction that is
outside of normal processes.
* Complete mandatory Anti-Money
Laundering and Counter Terrorist
Financing training on time.
Any activity you
Financial Crime and Supply Chain Compliant Team Site
suspect could be
Financial Crime Policy
Fit and Proper Policy
CODE OF BUSINESS STANDARDS.
linked to money
laundering needs to
be reported straight
away.
Risk Management
Risk management is fundamental to how Post
Office is directed, managed and controlled at
all levels. Risk must be embedded in all Post
Office activities and is key to effective decision
making.
All material risks must be identified, measured,
monitored, managed and reported on a
continuous basis.
Our Risk management processes must also
align and integrate with the delivery of our
Learn more:
Risk Policy
CODE OF BUSINESS STANDARDS.
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strategy and in such a way that supports an
enterprise wide approach;
Risk management must follow a consistent,
transparent and auditable methodology and
proactively recognise external factors,
opportunities, and uncertainties.
Managers must be accountable for identifying,
assessing, owning and managing their risks as
well as the maintenance of the associated
internal controls.
Risk must be identified,
measured, monitored,
managed and reported.
20
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Don't open emails from
unknown sources and
never click on links or
open attachments you
are unfamiliar with or
Use of Computers, Internet, Phones and Emails which seem suspi:
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 important that
anyone who accesses them knows how to keep them secure by following the requirements in the
Cyber and Information Security policy. Failure to comply with the Cyber and Information Security
policy can carry profound consequences for you and Post Office. Breaches of the policy may lead to
disciplinary action up to and including dismissal
To help protect our systems and information, you should:
Ensure Post office equipment is used
appropriately and protected from damage,
loss and theft.
Immediately report to the IT Service Desk
the loss or theft of any Post Office
equipment.
Use a password or pin to lock unattended
Post office equipment. Use complex
passwords to protect your access.
Ensure any removable Post Office IT
equipment is secured when left in the
You must not:
Try to disable, defeat or circumvent Post
Office security controls, including but not
limited to firewalls, browser configuration,
privileged access, anti-virus and the
deletion of system logs
Use Post Office systems or equipment to
intentionally access, store, send, post or
publish material that is:
- Pornographic, sexually explicit,
indecent or obscene, or
- Promotes violence, hatred, terrorism
or intolerance.
Run or engage in any form of private
business using Post Office IT equipment
office overnight, is locked away or put out
of sight when left unattended at home, in
a hotel or in a vehicle. When travelling,
keep the equipment with you at all times.
Follow the appropriate IT request process
to install any software applications on
your Post office equipment.
Only use approved data storage areas,
such as one drive. Don't sign up for cloud
storage services such as Dropbox
Open emails when you don’t know who
they are from and click on unknown links
and attachments in emails
Use your Post Office password for non-
Post Office IT Systems
Use your Post Office email address for
non-business-related websites or online
activity
Share your Post Office access
passwords/pins with anyone else,
including work colleagues
Access Post Office Systems or Information
after leaving Post Office employment
If you become aware of any information security issues or incidents you should always report it
through the Service Desk primarily through Service NOW or alternatively you can contact them on
Learn More:
Cyber and Information Security Polic
CODE OF BUSINESS STANDARDS.
21
Protecting Post Office Information
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Information is one of Post Office’s most valuable business assets: Post Office is committed to
safeguarding and protecting our information and any other information entrusted to us.
Disclosing (or “leaking”) confidential information outside of Post Office or to those who do not
need it for legitimate business purposes can have dire consequences on Post Office business,
damaging our reputation and breaching the trust of others.
Information within Post Office is held in many different formats, including on paper, electronically in
documents or in IT applications & systems. Our requirements to protect information apply to all
formats.
Post Office has Information Classification standards which define how information within Post office
should be classified, handled and protected.
When handling Post Office’s information, you must:
* Familiarise yourself with all information
handling policies and complete any
mandatory training on time.
= Complete mandatory information security
training on time.
» Understand the nature and classification
of the information, as defined in the
Information Classification Standards;
understand and adhere to the handling
requirements detailed in the Cyber and
Information Security Policy; and take
personal responsibility for the proper use,
circulation, retention, protection and
disposal of Post Office’s information
= Not disclose confidential information to a
third party unless there is an approved
purpose.
* Not share confidential information
internally beyond those who need it for
their job.
Learn more:
Cyber and Information Security Standards
Cyber and Information Security Polic
Cyber Information Classification Standard
Cyber Security Team Site
CODE OF BUSINESS STANDARDS
Take care not to disclose information in
public places, including taking all
necessary steps to protect information in
documents and on IT devices away from
the workplace.
Not forward emails containing non-public
Post Office information to personal email
accounts
Not store or synchronising Post office
information onto personal devices
Not take any Post Office confidential
information with you if you leave the
company. Any work carried out during
employment will remain the intellectual
property of Post Office.
Immediately report events which could
impact the security of Post Office
information by following the information
security reporting procedures.
22
Personal Data and Privacy
When customers, postmaster or third parties
do business with us, they entrust us with
personal data. Our employees do the same
when they join the company. We take our
responsibility and obligations seriously to
collect, use and process any personal data
only for legitimate business purposes and
protect it from possible loss, misuse or
disclosure.
Keeping personal data secure is critical to our
people, our business and our reputation. We
recognise this responsibility and follow the
laws requiring us to protect personal data that
can identify an individual or which relates to
an identifiable individual
Many employees work with personal data as
part of their jobs. If you are one of them, guard
this data well by following the Company
policies regarding the access, transfer and use
of this data.
You must:
+ Familiarise yourself with and follow
company policies regarding the access,
transfer and use of personal data.
* Complete mandatory Data Protection
training on time.
Learn more:
Protecting Personal Data Policy
CODE OF BUSINESS STANDARDS
data.protectio:
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= Only collect data that is adequate and
relevant and use it solely for the purpose
for which it is collected.
« Be transparent with individuals in relation
to how their personal data is used in
alignment with Post Office privacy
notices.
= Keep personal data up to date correcting
inaccurate data when requested and
respecting individual legal rights.
= Keep personal data confidential and
secure.
= Act responsibly and ethically, always
considering the risk to individuals in using
their personal data and take steps to
mitigate such risk.
When collecting, using or storing personal
data, employees must not:
= Retain personal data for longer than
necessary to achieve the business
objective or meet minimum legal
requirements
* Collect and use personal data for
purposes that are not reasonably
expected by our consumers, postmaster,
third parties and employees
You can contact
if you have any
questions on concerns in
regards to the access,
transfer or use of personal
data.
23
Maintaining Accurate Business Records
At Post Office we generate a large volume of
business records each day. You are
responsible for ensuring that the records in
your custody or control are maintained,
retained and
destroyed in compliance with all legal and
regulatory record keeping requirements. To
manage
your business records properly, you should:
= Comply with our records management
policies and retention schedules for all
business
records, paper or electronic.
* Keep records only as long as necessary for
a legitimate business purpose or legally
required.
Learn more:
Document Retention and Disposal Polic
Financial Accuracy
At Post Office we are committed to accurate
reporting in our company’s books and records.
You are expected to be accountable for the
accuracy and honesty of the business records,
contracts and agreements that you handle in
the normal course of business. You should
never falsify, omit, misstate, alter or conceal
any information, or otherwise misrepresent
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= — Follow the retention periods specified in
the Records Retention Schedule, if
applicable, or as required by law.
* If you receive a Legal Hold notice, follow
all retention instructions on the notice
regardless of the retention schedule or
applicable law.
Destruction of documents subject to a Legal
Hold notice, even inadvertently, could expose
our company and you to civil and criminal
liability. You should consult the legal team
if you have specific questions about
documents referred to in a Legal Hold notice.
the facts on a company record or encourage or
allow anyone else to do so. All of your
transactions, no matter what the amount,
must be properly authorised, executed and
recorded. If you notice an inaccuracy in a
company record, or a failure to follow our
internal control processes, speak up and
report it immediately.
CODE OF BUSINESS STANDARDS.
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Communication with the Public and Journalists
Post Office is committed to providing accurate, clear, complete and consistent information to the
public. You may not speak at public events or to journalists without prior authorisation.
No Post Office employee is permitted to agree to an interview or external speaking engagement
(business or personal) in which the company will be discussed or referenced, or publish any video or
written content related to Post Office without the support and approval of a member of the
Communications team.
Where a journalist wishes to speak with someone from Post Office, this request should be put to our
Press Office who will decide whether it is appropriate to provide a comment to the journalist. Should
you be asked directly 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, you must always
direct the request to our Press Office. They can be contacted or}
pressoffic!
CODE OF BUSINESS STANDARDS. 25
Choose Suppliers with Integrity
As a publicly funded organisation, we are
committed to ensuring that we deliver value
for money through our trusted and valued
partnerships with suppliers. We are subject to
the Public Contract Regulations ("PCR") 2015,
which mandate the processes we must to
follow, from the initial supplier selection
through to sourcing competitions and contract
award. These processes are designed to:
* Stimulate market competition for public
contracts
* Deliver value for money and innovation
* Ensure equal treatment and transparency
with all suppliers
* Ensure contracts are awarded fairly
We must ensure that our commercial activity
is compliant with the legislation and
demonstrates our commitment to best
practice.
Maintaining our reputation for ethical business
integrity is absolutely vital and we must also
ensure that we partner with suitable suppliers
who will align with our ways of working.
If you work with suppliers, you must:
= Complete the Procurement online Training
module.
Learn more:
Procurement Policy
Purchasing Process
Contract Execution Policy
Supplier Code of Conduct
CODE OF BUSINESS STANDARDS.
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= Consult with the Procurement team for
advice, and to ensure that processes are
followed.
« Familiarise yourself with the Procurement
Policy, Purchasing Process and the
associated procedures on our Hub page.
« — Ensure there is no commitment or
contractual engagement with Suppliers
until they are onboarded correctly, which
includes accepting the Supplier Code of
Conduct and other guidance documents.
Once a Supplier has been selected and a
contract is in place, you must:
* — Ensure that Purchasing process is
followed to ensure that orders are raised
and managed so that we are only paying
for the goods or services that we have
received
= Ensure that contracts are managed
effectively in line with our policies and
controls.
«= Notify your Line Manager and the
Procurement team if they know of or
suspect that third party suppliers are not
meeting requirements or if they are
performing contrary to the agreed
contractual terms
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Avoiding Conflicts of Interest
When do Conflicts of Interest Occur
Conflicts of interest can arise when our personal ae
relationships or financial interests overlap with our job CONSIDER THIS
responsibilities. If we don’t navigate potential conflicts
When someone says...
of interest carefully, these situations can impact the
decisions we make, erode trust within teams, and
harm the Company's reputation. ‘Could you put in a good word for
me?”
In business, the line between personal and
professional interests can become easily blurred
Separating the two can be challenging, especially
when personal relationships, outside employment or
investments are involved. We are all expected to act
in the best interest of the company. This means we
must never allow our personal interests to influence
“No one needs to know — you can do
the work in your free time”
“My Nephew has a company”
Be Aware these can be warning
signs of possible conflict.
our actions on behalf of the company. Every decision
we make while on the job must be objective and with
the company’s business interests in mind.
You must:
* Actin the best interests of Post Office. You must not do anything which conflicts with your duty
as an employee of the company or use your official position for private advantage.
* Avoid situations where a personal relationship or financial interest in another company might
influence decisions you make in your job.
* Understand that a conflict can exist even if you are convinced that your decisions will not be
affected by an outside relationship.
* When a conflict of interest arises, ensure these are disclosed, and advice and approval is gained.
* Before taking on outside work, ensure that the work does not harm Post Office's business
interests.
* Not exploit your personal or family relationship with any colleague for any gain including to
yourself or others.
CODE OF BUSINESS STANDARDS 27
Family Member and Close Working
Relationships
Relationships with family members and close
personal friends can influence our decisions. It
is important to be careful about company
business decisions that involve close personal
relationships.
To prevent conflicts of interest employees
should:
* — Avoid taking part in the hiring or
promotion of family members
* — Avoid holding a position with access to or
influence over performance appraisals,
salary information or other confidential
information related to a family member.
These situations should also be avoided in
connection with another employee of a
prospective employee with whom one has a
close personal relationship outside the
Company.
Outside Board Members
Serving on outsides boards can present
conflicts of interest and should be disclosed
and discussed with your manager. Before
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accepting memberships on any board, it is
important to understand one's legal
responsibilities and avoid affiliations that carry
potential for distraction and conflict of interest.
Political Activity
We respect the right of employees to engage
in political activity to support political groups.
Employees can only offer support and
contributions to political activities in a personal
capacity.
Post Office is a politically neutral company and
our reputation must not be compromised by
your interest, affiliation or activities to a
political party's pressure groups or other
causes
Employee's must:
= Ensure any contributions towards and
support for, political parties are clearly
personal and give no impressions of being
connected to Post Office.
» Ensure any personal political support or
contributions do not affect your
performance or objectivity at work.
= Not improperly use company resources or
time for personal party-political purposes
THINK IT THROUGH
= Will this activity or relationship influence, or appear to influence, my ability to make sound
and unbiased business decisions or otherwise interfere with my ability to do my job?
= Will I personally gain something or will a family member benefit from my involvement in this
activity based on my status as an employee of Post office?
= Will I be using Company assets for personal gain?
= Will my participation cause me to put my interests ahead of what's best for the Company?
= Will public disclosure of the activity damage the reputation of Post Office?
If you answered “yes” to any of the above questions or ifyou feel that you might have a potential
conflict of interest, inform your line manager and seek their advice if you are unsure.
Learn More:
Conflicts of Interest Policy
CODE OF BUSINESS STANDARDS
28
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The Last Letter
Thank you for your commitment to Post Office and our Code of Business
Standards.
Be inspired and work each day in a way that inspires others
Follow not only our Code, our policies and the laws and regulations that apply to your work, but also
your conscience. When something does not feel right or puts our Company, our people or those we
serve at risk, report your concerns. When you do, you preserve our good name and reputation.
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Document Control Record
GE Policy Sponsor I
Group Chief People
Officer
Angela Williams
Version I
1
Version I Date
2 01/10/18
3 17/12/18
4 08/04/19
5 13/11/19
6 07/01/20
7 25/06/2020
8 02/11/20
Summary
Policy Owner
licy Implementer
Employee Relations Senior Employee
and Policy Director Relations Manager
Lee Kelly Janene Mellor
Document Review
Period
12 months 08/01/2018
Policy — effective date
Revision History
Changes
Removed reference to B&H policy and
included Dignity at Work
Minor amends to Gifts and Sponsorship and
Hospitality and Entertainment
Updated hyperlinks
Updated hyperlinks throughout
Updated CEO sign off (pg 4)
Updated 9 protected characteristics (pg 9)
Added reference to the Transgender Equality
Policy (pg 10)
Added reference to menopause, family
friendly and sick pay provisions as well as
link to information on mental health first
aider (pg 12)
Updated ‘GE Policy Sponsor’ and ‘Policy
Approver' contact
Update language to ensure consistent with
dignity at work policy (pg9)
Included reference to the POEM and return
to work network (pg 10)
Added hyperlinks to network forums on
Peoplehub (pg10)
Updated policy hyperlinks
Added link to gifts & hospitality reporting
tool (pg 17 & 18)
Updated speakup contact details (pg 20 &
21)
Updated policy hyperlinks
CODE OF BUSINESS STANDARDS
Policy Approver
Group Chief People
Officer
Angela Williams
Policy location
UK
Approved by
Janene Mellor
Sally Smith
Janene Mellor
Janene Mellor
Janene Mellor
Janene Mellor
Janene Mellor
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Replaces Code of Business Standards Post Office GE and
8 oui2/2021 effective 08/01/2018 in its entirety. Board
Document Distribution Status
Mark x as Mark x as
Document Sens
Internal x Non-sensitive x
External Sensitive
Quality Statement
Quality Control
Review Date
This document is periodically reviewed, and at least every 12 months from
the last effective date.
Jan 2023
This policy has been reviewed against the latest Post Office policy
standards and legislative requirements.
CODE OF BUSINESS STANDARDS 31
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