Provident Financial Group’s approach to CR is underpinned by a range of corporate policies which set the codes of conduct, controls, processes and requirements for all employees, Customer Experience Managers, suppliers and contractors, and the operating divisions within the group.
These policies cover a wide range of issues that are relevant to our CR programme and focus on ensuring that we comply with all applicable legislation and regulatory requirements, and operate in a responsible and ethical manner, in line with our values and commitment to sound business practices. These include:
Health and Safety
This requires that we develop and implement a health and safety policy and manual which complies with health and safety legislation. It also states that we shall ensure that the health and safety policy and manual is reviewed annually and any changes approved by the boards of our operating businesses.
Conducting Affairs with Integrity
This policy states that our trading activities shall be conducted with honesty, integrity and in accordance with current laws and regulations.
We have a formal whistleblowing policy, which incorporates an external third party helpline facility. The Audit Committee of the Provident Financial plc Board has responsibility for reviewing the arrangements by which employees may, in confidence, raise concerns about possible improprieties in matters of financial reporting and other matters. The Company Secretary and General Counsel report annually to the Audit Committee on any concerns raised through the whistleblowing framework.
Bribery and Corruption
This requires that employees, contractors and directors must not directly or indirectly either offer, promise or give a bribe (active bribery) or request, agree to receive or accept a bribe (passive bribery). It also states that it is not acceptable to threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy or to otherwise engage in any other activity that might lead to a breach of this policy.
No Political Donations
This policy states that we will not make any political donations or incur political expenditure including offering or accepting a gift to or from government officials, representatives, politicians or political parties.
Equality, Diversity and Inclusion
We are committed to supporting diversity and to creating an inclusive culture for our employees and other stakeholders, including customers, suppliers and contractors. This means understanding the potential that all people bring to the workplace and recognising their differences regardless of: age, disability, gender, gender reassignment, marital and civil partnership status, pregnancy and maternity, race, religion or belief or absence of religion or belief, or sexual orientation. It also states that all fundamental human rights should be respected and, in the conduct of the group’s business, should be guided by the provisions of the United Nations Universal Declaration of Human Rights (UNUDHR) and the International Labour Organization (ILO) core standards.
This policy requires us to:
- Comply with, and where possible, exceed the requirements of all relevant environmental legislation, regulations and/or approved codes of practice in each country in which we operate.
- Have an ongoing continuous improvement programme which aims to reduce the group’s consumption of resources (eg energy, fuel, paper and water) and increase the efficiency of the use of these resources. This will include establishing objectives and targets to measure environmental performance and to subsequently evaluate, on at least a bi-annual basis, whether such objectives and targets have been met and how further improvements in environmental performance could be achieved.
- Where practicable, avoid or minimise the use of hazardous or toxic material or products, and prevent pollution from our operations and facilities.
- Integrate environmental considerations into our processes to procure goods and services.
We evaluate the Anti-Money Laundering (AML) risks associated with our business activities and create policies and procedures commensurate with the risks. We must also:
- Appoint a responsible person as the Money Laundering Reporting Officer (MLRO) who will create, update and ensure compliance with policies and procedures.
- Train all relevant employees in respect of AML, with refresher training carried out and documented annually.
- Request a report from their MLRO annually which sets out the procedures in place and reports on compliance with these procedures, highlighting any areas of concern.
This requires that our procurement processes must involve due consideration of the corporate responsibility practices of the supplier to ensure that there are no conflicts with group culture, relevant policies and the group’s core values. The group’s corporate responsibility assessment questionnaire should be used to support procurement decisions and areas of non-compliance should be referred to the Corporate Responsibility team for approval.