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, self-employed agents, suppliers and contractors, and the operating divisions within the Group.
These policies cover a wide of issues that are of relevance to the Group’s CR programme and focus on ensuring that Provident Financial Group and its operating businesses comply with all applicable legislation and regulatory requirements, and operate in a responsible and ethical manner, in line with its values and commitment to sound business practices. These include:
Health and Safety
This requires that Provident Financial Group and its operating businesses develop and implement a health and safety policy and manual which complies with health and safety legislation. It also states that they shall ensure that the health and safety policy and manual is reviewed annually and any changes approved by the boards of operating businesses.
Conducting Affairs with Integrity
This policy states that the trading activities of the Provident Financial Group and its operating businesses shall be conducted with honesty, integrity and in accordance with current law and regulations.
The Provident Financial Group and its operating businesses shall adopt a formal whistleblowing policy, which incorporates an external third party helpline facility. The Audit Committee of the Provident Financial plc Board shall have responsibility for reviewing the arrangements by which employees may, in confidence, raise concerns about possible improprieties in matters of financial reporting and other matters. And the Company Secretary and General Counsel will report annually to the Audit Committee on any concerns raised through the group’s whistleblowing framework.
Bribery and Corruption
This requires that employees, self-employed agents, 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 the Provident Financial Group and its operating businesses must design and implement a policy to ensure they do 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
The Provident Financial Group and its operating businesses are committed to supporting diversity and to creating an inclusive culture for its 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 requires that the recruitment, promotion and treatment of all employees by the Provident Financial Group and its operating businesses should be based on the individual’s relevant merits and abilities.
This policy includes the following requirements which apply to Provident Financial Group and its operating businesses:
- They must 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 it operates.
- They must 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.
- They must, where practicable, avoid or minimise the use of hazardous or toxic material or products, and prevent pollution from its operations and facilities.
- They must integrate environmental considerations into its processes to procure goods and services.
The Provident Financial Group and its operating businesses must evaluate the Anti-Money Laundering (AML) risks associated with their business activity and create policies and procedures commensurate with the risks. They 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 the procurement processes of the Provident Financial Group and its operating businesses 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 group Corporate Responsibility Manager for approval.