Our Business Standards - An employee's guide - myroyalmail

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Our Business
    Standards
    An employee’s guide

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1    2   3   4
July 2021

Contents                         Part 1
                                 Business behaviour                10
                                                                        Part 2
                                                                        Personal behaviour             34
                                 Health and safety                 12   Our expectations                36
Introduction                02   Service to our customers          13   Promoting diversity
                                 Commercial behaviour and               and inclusion                   37
What are Our
                                 following regulations             14   Religious and political beliefs 39
Business Standards?         03
                                 Handling inside information       16   Examples of appropriate and
Our values                  04
                                 Security, privacy and trust       18   inappropriate behaviour         40
Our expectations            06
                                 Dealing fairly with                    Managers’ duty of care          41
Your personal commitment    08
                                 suppliers and customers           20   Working with colleagues         42
Making the right decision   09
                                 Extraction of personal mail by         Personal behaviour
                                 Royal Mail Group employees        21   and appearance                  43
                                 Political donations                    Use of company funds
                                 and impartiality                  22   and property                    45
                                 Conflicts of interest             23   Using computers, phone and
                                 Bribery and corruption            24   email accounts and protecting
                                 Gifts, hospitality, sponsorship        our valuable information        46
                                 and donations                     25   Restrictions on photography
                                 Christmas and religious                and filming                     49
                                 festival gifts                    26   Modern slavery		                50
                                 Tax evasion                       27   Preventing and reporting crime 51
                                 Supporting our communities        29   Speak Up		                      52
                                 Our community support scheme      30   Getting help                    53
                                 Caring for the environment        32

                                                                                                             2
What are Our Business Standards?
Our Business Standards are the standards of behaviour we expect to see
in all of our people at Royal Mail Group. It’s about following the law, doing
the right thing and treating others with respect.
It’s important that we all understand         how others see the company. By applying
the behaviour that is expected of us and      good judgement, knowing and following
follow our company policies when at           our policies, being honest and speaking
work. This will help us do the best job       up when things don’t seem quite right,
we can for our customers, enhance our         we can all help to build the right culture.
already strong reputation and maintain
                                              If you ever have concerns about how
the important role that we play within the
                                              to act or respond in a situation or you
communities we serve.
                                              witness someone doing something that
Our Business Standards set out our            you think is not in line with Our Business
expectations of you, wherever you work        Standards, you must let us know straight
and in whatever job you do. Our Business      away. You can talk to your manager, or
Standards make sure we’re meeting our         contact one of our confidential helplines
legal obligations, keep us safe and protect   covering security, bullying and harassment
our reputation among our customers,           or speaking up.
suppliers and shareholders.
                                              By working together, we can continue to
We all make decisions every day that          grow trust at the doorstep, strengthen
affect our business, our customers and        our business and delight our customers
our colleagues. The individual actions we     whilst safeguarding the business and
take reflect on all of us and influence       each other.

                                                                                            3
Introduction

  Our values
 Our values reflect the principles, beliefs
 and aspirations that guide our behaviour
 and shape our culture.

                                              Be Positive
                                              We love to give it a go, aiming to make
                                              life better and brighter for our customers
                                              and each other. We trust each other to
                                              do the right thing and always say thank
                                              you for a job well done.

                                                                                           4
1

      GREAT
       JOB!

                                                                                  OPEN

Be Brilliant                                Be Part of It
We know our stuff, so we always deliver     It’s all about our team. We listen to each
great service. That’s because we do the     other and support each other, because
little things well, and we’re pretty good   after all, where would we be without each
at the big things too! We work hard to      other? We appreciate diversity because
find a better way – we never stop trying    getting thoughts and ideas from everyone
to improve.                                 makes us a stronger team.

                                                                                         5
Introduction

 Our expectations
 We’re all responsible for making                    We commit to:
 Royal Mail Group the best it can be.                •	 provide a safe, secure, healthy and
                                                          productive work environment;
 That means doing business fairly and honestly,
 giving our customers the best service we            • treat people fairly and with respect;
 possibly can and taking responsibility for the      •	 protect people from inappropriate or
 environment and local communities in which               bullying behaviour;
 we operate.                                         • support people to raise concerns; and
 To make sure we meet these responsibilities,        • operate within the law.
 we commit to looking after our people. In return,
 we expect our people to commit to always being
 the best they can be.

                                                                                                 6
As employees, we will:
• act honestly at all times;
• be productive during working hours;
• f ollow Our Business Standards and
   Royal Mail Group policies;
•u  se sound judgement and be personally
   accountable for our actions at work;
• show respect for each other; and
• operate within the law.

                                            7
Introduction

 Your personal commitment
 We expect our people to follow              If you discover our standards and company
 Our Business Standards.                     reputation are being put at risk by unethical
                                             or criminal behaviour, you should report
 We have a responsibility to ourselves and   the facts to a manager. If you don’t feel
 to each other to uphold the standards       comfortable speaking to your own
 defined in this booklet.                    manager you should speak to another
 Managers should make sure their teams       manager in your area. You can also contact
 understand and keep to these standards.     the Security Helpdesk or Speak Up helpline,
 We should all hold each other to account.   confidentially, if you feel you can’t talk to
 If you witness someone behaving in a way    anyone in your workplace
 that’s not consistent with Our Business     Ignoring inappropriate or illegal behaviour
 Standards, it’s your responsibility to      is wrong and will damage the reputation
 let us know.                                of our company and everyone who works
 Please be aware that breaking any of        for us.
 Our Business Standards may be dealt         We realise it’s not always easy to report
 with under the conduct policy and any       unethical or criminal behaviour but it’s
 finding of misconduct could result in       important to let us know if something’s
 action, up to and including dismissal.      wrong. If you’ve got any concerns, please
 Breaking specific business standards        see the ‘Getting help’ section at the back
 may result in criminal prosecution.         of this booklet.

                                                                                             8
Introduction

 Making the right decision
  Our Business Standards are at the heart                                      Questions to consider
  of everything we do while we’re at work.                                     If you are faced with a dilemma or you’re not sure
                                                                               what to do, ask yourself these questions:
  You’ll already do a lot of what’s covered in this
  booklet without even thinking about it, but that                             • Does it feel right?
  doesn’t mean you won’t sometimes face difficult                              • Is it legal?
  situations or dilemmas in your day-to-day activities.
                                                                               •	 Is it in line with Our Business Standards, values
  Some decisions are clear cut whereas others may                                   and company policies?
  be more open to interpretation. Use this booklet to                          •  Will it reflect negatively on me or Royal Mail Group?
  help you understand how to behave when faced with
                                                                               • Would I be happy to defend my decision in public?
  these difficult situations, or as a guide for where to
  find more information and help.                                              •	 Who else could be affected by this
                                                                                    (for example, colleagues or customers)?
  We haven’t covered every situation you might face
                                                                               •	 Would I be concerned if others knew I’d taken
  but we hope the examples and information will give
                                                                                    this course of action?
  you the tools you need to make the right choices.
  We trust you to use your good judgement to act in                            • Is there a better action I could take?
  line with Our Business Standards and to ask for
  help when you need it.

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  If you’re still not sure about the right thing to do, talk to your manager
  or report the matter using the Speak Up helpline, call 0800 090 3154
  or visit royalmail.gan-compliance.com/p/speakup

                                                                                                                                                            9
Part 1
Business behaviour

                     10
The behaviour that makes a difference to our customers
and how our business is run
Health and safety       				                                12
Service to our customers                                    13
Commercial behaviour and following regulations              14
Handling inside information 				                            16
Security, privacy and trust				                             18
Dealing fairly with suppliers and customers                 20
Extraction of personal mail by Royal Mail Group employees   21
Political donations and impartiality			                     22
Conflicts of interest					                                  23
Bribery and corruption 				                                 24
Gifts, hospitality, sponsorship and donations               25
Christmas and religious festival gifts			                   26
Tax evasion						                                           27
Supporting our communities				                              29
Our community support scheme 			                            30
Caring for the environment				                              32

                                                                 11
Part 1 – Business behaviour

 Health and safety
 ‘Everyone has a responsibility for their own safety,                                                  Never carry
 that of their colleagues and others’                                                                  out tasks
 You must:                                                                                             without
 • act in accordance with the responsibilities set out in the ‘Your SHE (safety,                      the proper
    health and environment) roles and responsibilities’ booklet appropriate to                         training
    your role in the organisation;
 • support a safe culture and behave responsibly, always taking account
    of your own safety and that of others;
 • report hazards and unsafe acts and conditions so we can deal with them;
 • intervene in a positive and polite manner where necessary to keep your
                                                                                         Example
    workplace safe, and respond to others who step in to help you in the same way;
 • make sure you have the proper training and necessary authority to carry out tasks;   A manager notices that
                                                                                         their team members
 • take part in health and safety briefings, work time listening and learning
                                                                                         aren’t pushing Yorks in the
    sessions (WTLL) and meetings, where required;
                                                                                         correct way. They believe
 • always follow the appropriate safety rules, standards and procedures,                this could be a risk to them
    and ask for an explanation if you’re not sure;                                       and to the people around
 • use and maintain all controls, procedures and protection provided                    them, so they discuss the
    for your safety and the safety of others;                                            safe systems of work for
 • report all incidents, near-misses and personal injuries to your                      Yorks and everyone agrees
    manager straight away;                                                               to follow these methods.
 • make sure your working hours are in line with the working time policy.

                                                                                                                        12
Part 1 – Business behaviour

 Service to our customers
 Our customers are important.
 We serve their needs by giving them:
 • consistent delivery of what we promise;
                                                                     Mistakes and
 • value-for-money services and products;
                                                                     service failures
 • timely, reliable and secure services nationwide;
                                                                     damage our
 •	 accurate and accessible information about our
      services and products;
                                                                     reputation, and
 • a helpful and polite service at all times; and
                                                                     lose customers
 • a prompt and appropriate solution if things go wrong.

 Everyone in the company has an important part to play in living
 up to these commitments. If we fail our customers, they’re likely
 to take their business elsewhere. That damages our business and
 our job security and it won’t go unnoticed.
 Our external regulator, Ofcom, can impose penalties if we fail
 to meet our obligations. There is also a consumer watchdog
 which takes an interest in the service we give to customers.

                                                                                        13
Part 1 – Business behaviour

 Commercial behaviour and following regulations
  The only right way to compete with other businesses is by making sure that our business
  methods are always ethical, professional and legal.
 Regulatory framework                                                 Competition law
 We operate under a regulatory regime, overseen by Ofcom              Like all other business, we must also
 (our regulator). This sets out our responsibilities as the           comply with competition law.
 Universal Service Provider and also the requirement that we
                                                                      Both Ofcom and the Competition and
 provide access to our network. We must not share information
                                                                      Markets Authority have competition
 gained as a result of providing wholesale services with other
                                                                      law powers and will take action against
 parts of our business, and we must not discriminate against
                                                                      companies who act in a way that damages
 wholesale customers and their mail.
                                                                      competition. For example, it’s illegal for
 Everyone in Royal Mail Group needs to play a part to make sure we    competitors to agree prices collectively
 meet our regulatory requirements. We should all do the following:    with each other. The golden rule is that
                                                                      we should decide our commercial policy
 • Be aware of and follow our Access Regulation and Competition
                                                                      independently from competitors and
    Law policies, processes and procedures.
                                                                      other businesses operating in the market.
 • Complete all mandatory training courses to the timescales given.   Discussing our business arrangements
 •U  nderstand and act on any supplementary guidance issued by       with competitors (and even suppliers)
   the business.                                                      runs the risk of breaking competition law.
 •K  now who to go to for help - you can contact Group Compliance    For more information, see our competition
   & Ethics (group.compliance@royalmail.com) or Group Legal           law and USPA5 policies and guidance
    (Regulation_And_Competition_Team@royalmail.onmicrosoft.com)

                                                                                                                   14
Did you know?
  Under competition law, if we are found to have significant market power, we will have extra responsibilities
  not to abuse that position of power by exploiting customers or unfairly excluding competitors.
  Failure to follow either the regulatory framework or competition law could have serious
  consequences (such as fines and damage to our reputation) and consequences for individuals
  (for example, action taken under the conduct policy or criminal charges for some offences).

You must do the following
• Never discuss confidential             • Keep to our ring-fencing obligations    Example
   information when in public.               when it comes to wholesale
                                             information and don’t discriminate      An employee has been told some
   If you are going to events on behalf                                              information about changes to
   of Royal Mail Group , remember            against wholesale customers
                                                                                     Royal Mail Group’s strategy. This
   that you represent the business        • Act fairly and in a non-                information is very positive and
• If you are going to a trade               discriminatory way in all dealings      exciting for Royal Mail Group and
   association, forum or event               with our customers and suppliers        the employee wants to share
   attended by competitors, make          • Never share any commercially            it with an ex-colleague who he
   sure that you have Group                  sensitive or confidential information   still sees regularly and who now
   Compliance & Ethics approval              outside of Royal Mail Group, or         works for a competitor of Royal
   and follow the appropriate steps          accept this kind of information         Mail Group.
   which you can find on the Group           from competitors
                                                                                     This information must not be
   Compliance & Ethics intranet site      • Never enter into discussions or         shared with the ex-colleague,
• Never reveal confidential                 make any form of arrangements           even in an informal setting. It
   information on social media.              with competitors without first          could be used by the competitor
   This could be pricing, strategy           getting legal advice                    to alter their own strategy and so
   or anything else which the public                                                 could breach competition law.
   do not already have access to

                                                                                                                          15
Part 1 – Business behaviour

 Handling inside information
 Inside information is any information that you know because you are an employee,
 which could affect the price of Royal Mail Group plc shares.
 You must:                                               Our obligations as a listed company
 • keep our information confidential and reveal         As a company listed on the London Stock Exchange,
    it only to employees who need to know it;            we have to keep to the obligations in the Financial
 •pass details of potential inside information         Conduct Authority’s Listing, Prospectus and Disclosure
    (for example, major business developments,           and Transparency Rules (listing rules), as well as the
    expected earnings or losses) to your manager or      Market Abuse Regulation. The listing rules say listed
    to the Company Secretary (cosec@royalmail.com)       companies must meet certain standards of governance
    as soon as possible;                                 and investor protection.
 • not communicate with the media, shareholders or      The listing rules say we must treat all our shareholders
    analysts unless you have been authorised to do so;   equally, which means we must do the following:
 • not deal or encourage anyone else to deal in         • announce to the markets, as soon as possible,
    Royal Mail Group plc shares if you have inside          any information about matters and developments
    information; and                                        relating to our companies that could affect the
 • keep to the relevant communications policy and          price of our shares. This information is known as
    share dealing policy and code, as appropriate.          inside information until it has been announced to
                                                            the markets
                                                         • make sure all inside information is properly
                                                            protected and employees with access to it don’t
                                                            abuse, and are not seen to abuse, their position.

                                                                                                                    16
Handling inside information                                Using inside information incorrectly
If you have access to inside information (or information   If you’re aware of inside information and try
which could become inside information), you must           to take improper advantage of it, you’re likely
keep it strictly confidential and treat it in line with    to be committing a criminal or civil offence.
our communications policy.                                 You could also face action under the conduct
                                                           policy. Taking improper advantage includes
If you become aware of inside information (or
                                                           revealing the information to someone who
information which could become inside information),
                                                           has no business knowing it. It could also involve
you should tell your manager or the Company
                                                           buying or selling Royal Mail Group plc shares
Secretary (cosec@royalmail.com) as soon as possible.
                                                           on the basis of the information or encouraging
In some cases, our Disclosure Committee will review
                                                           someone else to do so.
the information immediately to decide whether it is
inside information which should be announced.              For more information, see our communications and share
                                                           dealing policy and code
To avoid a situation where the markets become aware
of inside information that we have not yet formally
announced, you should only discuss confidential
information on a need-to-know basis. Only authorised
Royal Mail Group employees may communicate with
the media, shareholders and analysts.
If you’re considered to have, or you’re likely to have,
regular access to inside information (or information
which could become inside information), you’ll be told
by the Company Secretary and receive appropriate
information and training. You will also have to keep
to our share dealing policy and code and get clearance
before you can buy or sell Royal Mail Group plc shares.

                                                                                                                    17
Part 1 – Business behaviour

 Security, privacy and trust
 Millions of items are entrusted to us by our customers every day.
 We must gain and keep the absolute trust of our customers and others we come
 into contact with as a result of our business activities. The strength of the company
 rests on the honesty and integrity of each one of us.

 Maintaining our standards means:
 • handling with honesty all items, mail, data,          • accurately reporting business performance
    cash and valuables entrusted to us;                       measures, for example making sure there is
 • protecting company and customer property                  no interference or undue influence on quality
    and assets, making sure they are not stolen,              measurements;
    abused, damaged, or taken for personal use;           • making sure company premises and
 • making sure company funds and property,                   facilities are not abused for unauthorised
    including Royal Mail Group prepaid envelopes,             commercial transactions;
    are never used for personal use;                      • protecting confidential information you handle
 • reporting anyone who misuses company                      from compromise or unauthorised disclosure
    property or goods entrusted to us;                        and keeping to laws such as the UK General Data
                                                              Protection Regulation (GDPR) which require us to
 • using correct accounting in all financial
                                                              protect personal information; and
    transactions and claims and keeping to
    business-control procedures;                          •displaying Royal Mail Group photo ID at all times
                                                              when on our premises and being prepared to
                                                              politely challenge anyone on our premises who
                                                              is not wearing their identification.

                                                                                                                 18
Our obligation as a                         We must minimise the risk of loss, theft, damage or
regulated company                           interference with the mail by:
As a regulated postal operator we           • making sure all employees are aware of, and have access to,
have an obligation to protect the              the security standards and procedures needed to make sure
mail and make sure it is secure.               mail is secure;
                                            • individually and collectively keeping to those standards; and
Protecting the mail
                                            • reporting and recording any incidents of loss, theft, damage
Any loss or break in security undermines       or interference.
customer confidence in our ability to
protect the mail and may attract negative   Operational security standards
media attention.
                                            • Customers’ parcels and letters must not be left unattended
                                               or unsecure at any time
                                            • Everyone working for us must have an appropriate level
                                               of security awareness and training
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                                            • Unauthorised access to all our sites must be prevented.
                                            • Special Delivery, tracked and high-risk parcels and letters
                                               must be given appropriate protection
                                            • Managerial checks to protect all customers’ parcels and
                                               letters must be effectively used
                                            • All vehicles and equipment used to carry customers’
                                               parcels and letters must be given the appropriate
                                               level of security at all times

                                                                                                              19
Part 1 – Business behaviour

 Dealing fairly with suppliers and customers
  We aim to build trust and create positive relationships with our
  suppliers and customers through fair and consistent dealing.
  We do this by doing what we’ve said we’ll do, meeting agreed timescales and delivering
  our services in full. We expect employees involved in negotiating contracts to get the
  best value for the business and set an example of competence and honesty.

 When doing business for the company, you must:
 •h  ave the proper authority before you negotiate or     • set prices and conditions in line with
    sign contracts;                                           competition law, our regulatory
 • not negotiate with vendors or commit to third-party       requirements and approval processes;
    spending without procurement approval;                 • get timely advice from Group Legal if
 • keep to the relevant legal requirements,                  any non-standard form of contract is
    policies and standards, acting professionally             proposed and not making any decision
    during all customer interactions as the ‘face’ of         without their advice; and
    Royal Mail Group;                                      • pay suppliers for goods and services
 • avoid any business practice which might be                within the agreed timescales
    reasonably judged improper, including ‘cutting            and specification.
    corners’ by neglecting proper consultations or
    procedures which would result in us or a supplier      For more information on dealing fairly with suppliers
    having a negative impact on human rights;              see our Procurement Code on the intranet

                                                                                                                   20
Part 1 – Business behaviour

 Extraction of personal mail by
 Royal Mail Group Employees
  Employees working in the operational pipeline may come into contact
  with personal mail addressed to themselves.
  This is particularly true for our colleagues who work       Please note:
  in a delivery office that serves their home address, so     • only employees within Royal Mail Group can ask
  there may be circumstances where colleagues want to            to extract items of mail; for avoidance of doubt
  extract their own personal mail whilst at work.                employees in Parcelforce are not able to extract
                                                                 items and all requests will be refused;
  In such cases, the process below must                       • only mail items addressed to the individual
  be followed:                                                   employee may be extracted;
    1. A request to extract personal mail item(s)            • mail cannot be extracted for spouses, children,
       must be made to a manager.                                relatives, or neighbours, etc. (e.g. Mr Smith cannot
    2. The manager must check the item(s) is addressed          extract mail addressed to Mr and Mrs Smith); this
        solely to the employee at their home address.            must be delivered as addressed;
    3. If the manager agrees that the item can be            • the above does not prevent an employee on delivery
        extracted the manager must sign and date the             delivering to their own address, providing they reside
        item(s) to show the extraction has been authorised.      on their delivery route and they do not divert from
                                                                 route sequence to make their own delivery;
    4. All relevant tracking systems must be updated
        as appropriate.                                       • failure to follow this process may lead to action
                                                                 under the Conduct Policy.

                                                                                                                          21
Part 1 – Business behaviour

 Political donations and impartiality
 As a company, we must not make political donations of any kind.
 The interests of our company and our customers must not be
 compromised by any interest or activity in a political party.
 You are entitled to vote and take part in the political process, including
 representing a political party. This must be in your own time.

 You must:                                                 Follow these simple rules:
 • not offer company contributions, for example           • if you take part in the political process it must
    the free use of company premises, for any political       be in your own time using your own resources
    party or organisation which is linked with a           • political activity is not allowed at work.
    political party;                                          This includes active support of parties,
 • not sponsor or book events through any                    pressure groups or other causes
    political party or organisation which is               • you must not display badges, slogans
    linked with a political party;                            or notices advertising political parties or
 • make sure electoral material – which by law               causes while on duty or in uniform, or on
    we have to deliver – is treated correctly, with           our premises, notice boards or vehicles
    the same respect as other mail; and                    • you must not distribute or deliver unauthorised
 • remember company funds and resources must                 material while you are at work or in uniform,
    not be used to try to advance our interests by           or allow anyone else to use business services
    making payments to governments or officials.             free of charge for this purpose.

                                                                                                                  22
Part 1 – Business behaviour

 Conflicts of interest
 Carrying out your work with honesty and openness means you can avoid difficult situations.
 The essential principles
 • You must not do anything which conflicts with           • To avoid conflicts of interest or issues with
    your duty as an employee or agent of the company,          favouritism, if you are related (by blood, marriage
    or use your official position for any advantage            or partnership) or have a personal relationship with
 • You must not work for, receive payment from                someone, you cannot work in roles where supervision
    or advertise any organisation which is in                  may be affected. Report any possible situations
    competition with us, or which is involved in               like these to your manager or another manager
    activities which may damage our reputation,             • If you receive a fee from an outside source for
    including any personal sponsorship                         carrying out a service which forms part of your role,
 • You must declare any outside employment (which             or takes place in business time (for example, giving
    includes directorships or significant shareholdings).      an interview or lecture), you must report it to your
    These must not be contrary to our commercial               manager
    interests or damage our reputation
 • Your actions as an employee or agent must                 Example
    not be improperly influenced by any relationship          An employee’s son is about to transfer to the
    (for example, by blood, marriage, partnership             unit where the employee works as a late-shift
    or being a member of any social, religious or             manager. Even though the employee would not
    political association) or by any personal or              manage their son, they know they should tell
    financial consideration                                   their own line manager that their son is coming
                                                              to work at their unit.
  For more information see the conflicts
  of interest policy and guide

                                                                                                                       23
Part 1 – Business behaviour

 Bribery and corruption
 Corrupt acts expose our business and employees to the risk of prosecution, fines, exclusion
 from tendering for business and other penalties. We have a ‘zero tolerance’ policy on bribery.

  What is bribery?                                       You must:
  Bribery is promising, offering, giving, asking         • never promise, offer or give a bribe;
  for or accepting any advantage to encourage or         • never ask for or accept a bribe;
  reward behaviour that is improper (in other
                                                         • report any bribe or suspected bribe as
  words, it is illegal, dishonest or involves breaking
                                                            soon as possible to your manager, and
  a duty). This can be either directly or through
                                                            to Group Compliance & Ethics or the
  someone else. Even if the recipient turns down
                                                            confidential Speak Up helpline; and
  a bribe or it doesn’t have the intended effect,
  it is still a bribe and is illegal.                    • remember that you won’t suffer any negative
                                                            consequences for refusing to give or receive bribes.
  Advantages may be financial or non-financial and
  could be anything which is, or might be, valuable
  to the person being offered the bribe or someone         Example
  connected to them (like a relative or friend).
                                                           An employee has been offered money to
  An advantage may be money, loans, donations
                                                           make sure a customer’s mail is delivered first
  (including charitable donations), an award of
                                                           in the morning. They know accepting this offer
  business, job offers, preferential treatment,
                                                           means breaking our policy and potentially
  a holiday or gifts and hospitality.
                                                           breaking the law. The employee does the right
 For more information see our prevention of bribery,       thing – they refuse the offer and report it to
 corruption and the facilitation of tax evasion policy
                                                           their manager.

                                                                                                                   24
Part 1 – Business behaviour

 Gifts, hospitality, sponsorship and donations
 Offering or accepting gifts, hospitality, sponsorship or donations to
 encourage or reward improper behaviour may be considered a bribe.
 Our guidance set out what we normally consider reasonable and
 appropriate gifts, hospitality, sponsorship and donations (GHSD).

 You must:                                                                  For more information see our prevention
                                                                            of bribery, corruption and the facilitation of
 •	 not ask for a gift from any individual or organisation we deal with;   tax evasion policy and our gifts, hospitality,
                                                                            sponsorship and donations guidance
 • not offer or accept any GHSD to influence a decision
     or to conceal a bribe;
 • not offer or accept any gift of cash, or cash equivalents                 Example
     such as shares, gift cards or vouchers (this does not include            An employee is in a tendering
     Christmastips from customers to front-line employees);                   process to set up a new supplier
 • not accept or offer any GHSD (other than simple                           for employee uniforms. During the
     refreshments provided at a meeting), if you’re involved                  tender process the supplier offers
     in tendering or negotiations of a contract or bid for work,              the Royal Mail Group employee
     during the period of the tender, bid or negotiation;                     hospitality tickets to a concert.
 • register all GHSD above £50 on the gifts and hospitality                  The employee refuses the tickets
     register and anything, regardless of value, offered to or                and reports the offer using the
     received from a public official; and                                     gifts and hospitality register to
 • tell Group Compliance & Ethics immediately if you (or your                confirm that he has declined the
     partner or relative) are offered any GHSD (including tips) and           tickets, protecting both himself
     the person giving it suggests they expect something in return.           and our business.

                                                                                                                             25
Part 1 – Business behaviour

 Christmas and religious festival gifts
 We do an important job, especially at Christmas.
 Colleagues deserve the recognition they get from the public.
 We see the giving of Christmas tips and gifts for other religious
 festivals as a matter between customers and individual employees.

 Remember
 You must not accept a tip if there is any suggestion it
 is meant to encourage you to do something inappropriate.
 You shouldn’t accept a tip if it’s meant to encourage you to reveal
 official information or information about another customer, to break
 any company rule or provide preferential treatment. Accepting or asking
 for a tip in these circumstances would be considered breaking the law.
  For more information see our prevention of bribery,
  corruption and the facilitation of tax evasion policy and
  our gifts, hospitality, sponsorship and donations guidance

                                                                           26
Part 1 – Business behaviour

  Tax evasion
  Tax evasion is a criminal offence. If you help someone evade
  tax, you could be prosecuted and Royal Mail Group could also
  be held liable and subject to unlimited fines, causing significant
  reputational and financial damage to our business.
  We all have a part to play in minimising the risks of tax evasion.
                                                                       Example
  What is tax evasion?
                                                                       An employee working in
  Tax evasion is fraudulently evading or cheating a tax authority
                                                                       Accounts Payable turns a blind
  out of tax and is a criminal offence.
                                                                       eye to a supplier issuing a wrong
  If you deliberately and dishonestly help someone (e.g. a customer)   invoice, so they don’t have to pay
  evade tax (anywhere in the world), Royal Mail Group can be           any VAT to HMRC. Royal Mail
  held criminally liable, unless we can show we have reasonable        Group could be held liable if we
  procedures in place to prevent our employees and representatives     cannot evidence that we have
  from doing this.                                                     procedures in place to prevent
  Even turning a blind eye when you know tax evasion is going on       this from happening.
  could still count as helping someone commit tax evasion.
  For more information see our prevention of bribery,
  corruption and the facilitation of tax evasion policy

                                                                                                            27
What is VAT fraud?                                          You must:
VAT fraud is a type of tax evasion. It can occur anywhere   • follow Royal Mail Group policies and procedures
along a supply chain; not just by the person or business       at all times;
Royal Mail Group is immediately doing business with.        • never assist a customer, supplier or anyone else
It could involve our suppliers or our customers. Royal         to evade tax;
Mail Group must have procedures in place to detect
                                                            • never turn a blind eye to what you might think might
fraud in our supply chains. For example, checking a VAT
                                                               be tax evasion;
number and bank account details provided by a supplier
are genuine and requiring our contractors to have           • consider if a deal appears “too good to be true”,
appropriate checks in place with their own suppliers.          taking into account things like pricing, communication,
                                                               experience and history; and
What are the consequences?                                  • report any knowledge or suspicion to Group Compliance
• You could be prosecuted and so could Royal Mail Group       & Ethics or through the confidential Speak Up helpline at
• In certain circumstances, a Royal Mail Group director       royalmail.gan-compliance.com/p/speakup
   or manager could also get a penalty if they should
   have known that RMG was connected with a VAT fraud
• For employees, action could be taken under the
  conduct policy

  Example
  A colleague in the Sales team is trying to win business from a new customer who imports goods from
  the EU. The colleague advises the importer to under-declare the value of goods being imported to help
  reduce the customs and excise duties due, in return for securing their business. Royal Mail Group could
  be liable for the actions of this colleague, as they have deliberately helped the importer avoid tax.

                                                                                                                     28
Part 1 – Business behaviour

 Supporting our communities
  We are a valued and trusted
  part of our communities.
  Delivering economic and social benefits to the
  communities we serve is one of the key objectives
  of our corporate responsibility strategy. We use
  our core business competencies, people and
  brand to benefit good causes.

 Our Community Investment strategy:
 Our Community Investment strategy has
 three priorities:
 • t o leverage our national scale;
 • use our local presence; and
 • unlock potential through education.

                                                      29
Part 1 – Business behaviour

 Our community support scheme
 Every Royal Mail Group colleague can apply once a year
 for up to £200 in matched giving from Royal Mail Group
 for money raised for any registered UK charity or registered
 good cause under the Community Support Scheme.
 We also offer volunteering and fundraising grants.
 Find out more at myroyalmail.com/community

    We report our Community Investment work
    each year in our CR report.
    Please visit: www.royalmailgroup.com/en/
    responsibility/policies-and-reports for the
    latest report.

                                                                30
Did you know?
• Our 2017-2021 Charity of the Year partnership with Action
   for Children raised an incredible £2 million. All funds
   raised were used to deliver the Blues programme; a
   school based programme supporting young people aged
   13-19 years old who are suffering from, or who are at risk
   of depression and other mental health problems. The
   programme has been delivered to over 5,000 young people
   across the UK
• We work closely with the charity, Missing People, using our
   presence in local communities to support the search for
   vulnerable, high-risk missing people. We send location-
   specific alerts through our network of handheld PDAs,
   office TV screens and MyRoyalMail.com
• For more than 30 years, Royal Mail Group has supported the
   Disasters Emergency Committee (DEC) with a dedicated PO
   Box. DEC appeals are launched in response to overwhelming
   humanitarian crises

                                                                 31
Part 1 – Business behaviour

 Caring for the environment
 We recognise the impact of a changing
 environment on our business, our people,
 neighbours, customers and suppliers.
 We believe the responsible management
 of natural resources is an essential part
 of the way we manage our business.
 We are committed to:
 • protecting the environment;
 • identifying and managing environmental risks;
 • preventing or minimising any possible effect our business
    might have on the natural or built environments and the
    communities living in those environments;
 • finding operational efficiencies that can reduce our
    use of natural resources; and
 • looking for environmental performance improvements
    that support new business opportunities.
 Together these commitments help us to manage our
 impact on the environment, whilst adapting our business
 to meet the challenges of a changing world.

                                                                32
We can all take simple steps to manage our effect
on the environment both at work and at home.

Responsible consumption                                      • Separate waste using the correct waste bins
• Turn off lights when not in use                            • Don’t drop rubber bands while on delivery.
• Don’t interfere with the building temperature settings       Collect and reuse them
• Turn off electronic devices and equipment after use       • Collect and reuse york card labels
• Use the most energy-efficient mode settings on your       • Print only when necessary, on both sides of a page
   electronic devices and equipment, for example, use        • Use hand driers instead of paper towels
   the hibernation feature on computers and laptops          • Instead of using disposable cups to buy drinks from
•M  ake sure bay doors and curtains are shut when              the canteen, use your own cup or mug
   not in use                                                • Use water bottles instead of disposable cups
• Turn off vehicle engines when not in use                  • Avoid using disposable cutlery, plates and bowls
• Don’t over-accelerate or break harshly
                                                             Save water
• Drive efficiently, using the correct gears
                                                             •	 Turn off taps after use
• Keep tyres at the correct pressure
                                                             • Report any leaks to your line manager as soon
• Use public transport as much as possible and reduce
                                                                 as possible
   the use of private cars and flights for business travel
• Share car journeys with colleagues where possible
   for business trips and to work                              For any questions on our work relating to
                                                               the environment or community please email
• Cut down on business travel: use conference calls,
                                                               the Corporate Responsibility team:
   virtual meetings and work from home where possible          corporateresponsibility@royalmail.com.
•O  nly purchase/use what is needed and reuse items
   where possible

                                                                                                                      33
Part 2
Personal behaviour

                     34
How we work together with our colleagues

Our expectations 					                                36
Promoting diversity and inclusion 			                 37
Religious and political beliefs 				                  39
Examples of appropriate and inappropriate behaviour   40
Managers’ duty of care 					                          41
Working with colleagues 				                          42
Personal behaviour and appearance 			                 43
Using company funds and property 			                  45
Using computers, phone and email and protecting
our valuable information 				                         46
Restrictions on photography and filming 			           49
Modern Slavery 				                       		          50
Preventing and reporting crime 				                   51
Speak Up		                				                        52
Getting help						                                    53

                                                           35
Part 2 – Personal behaviour

     Our expectations
      In Royal Mail Group we work together to create a positive working environment for everyone.
     We do this by treating each other politely and with respect,   What does this mean for managers?
     by making sure we don’t take part in inappropriate             We expect our managers to set a good example at all
     behaviour, and by keeping to our values at all times.          times and demonstrate how to live by Our Business
     When it comes to the behaviour of others – customers,          Standards and company values.
     colleagues, suppliers or anyone else we might meet             As well as our expectations of employees,
     at work – we don’t put up with abusive, aggressive or          all managers must:
     discriminatory behaviour.
                                                                    • remember they are Royal Mail Group managers and
     This section of Our Business Standards sets out the               represent the business, both in and out of work;
     behaviour we expect you to display while you’re at work.
                                                                    • lead by example;
     We should all behave appropriately and remember we are         • support, encourage and take action to challenge
     representing Royal Mail Group whenever we’re at work.             any failure to meet standards; and
     You must:                                                      • operate within the law.
     • not act in an intimidating, threatening, derogatory
        or discriminatory way;
     • not behave violently or be abusive to others;
     • not take part in criminal activity; and
     • not do or say anything that might harm our business,
2      3our colleagues
                4        or others we come into contact with.

                                                                                                                          36
Part 2 – Personal behaviour

  Promoting diversity and inclusion
 Diversity and inclusion is about treating each other with respect and consideration, and
 valuing the differences and contributions of all. It is about creating a positive culture
 where each of us feels comfortable bringing our ‘whole self’ to work. Royal Mail Group is
 committed to creating a work environment that is free from discrimination, victimisation,
 bullying and harassment, where all individuals are treated with dignity and respect.

 This means:
 •	 we should always be open, respectful, polite          • we should work together to create an inclusive
     with each other and keep to our company’s values          working environment for all
     at all times                                           • everyone has the right to a family life. We should
 • we must not discriminate for any reason or                 respect each other and not discriminate against
     characteristics such as: race, colour, ethnic or          those with family commitments outside work.
     national origin, nationality, disability, marital or   You must:
     civil partner status, sexual orientation, pregnancy
     or maternity, age, religion or belief (including       • follow the principles of our equality and
     political opinion in Northern Ireland), sex or            fairness policy;
     gender reassignment                                    • not discriminate or encourage others to
 • we should encourage a workplace that promotes              discriminate; and
     equal opportunities for everyone, providing            • not use inappropriate behaviour or intimidate
     opportunities based on a person’s performance,            other employees, customers or suppliers
     skills and development needs in a fair and open way       for any reason.

                                                                                                                    37
Everyone is expected to take personal responsibility for putting these principles
into practice and setting an example in the workplace.
We will investigate formal complaints and any employee who is found to have committed an act
of discrimination or harassment will face formal action (up to and including dismissal) under the
conduct policy.

Our policies prevent you from:                          What to do if you have a genuine concern?
• taking action against someone who reports            If you feel you have a concern at work, we want you to
   a concern in good faith; or                          bring it to our attention. It’s in everyone’s interest for
• deliberately making false or fictitious complaints   people to raise genuine concerns about their treatment
   without action being taken against you.              or the treatment of others at work. Ideally, you should
                                                        first raise your concern with your manager.
Both could lead to formal action (up to and
including dismissal) under the conduct policy.          If the concern is about bullying and harassment,
                                                        see the stop bullying and harassment policy or
                                                        call the bullying and harassment helpline on
                                                        0800 5874 777 for support and advice.
                                                        If you have a concern about wrongdoing, misconduct
                                                        or unethical behaviour that isn’t appropriate to
                                                        raise through your manager, an independent
                                                        manager or other helplines or processes, you
                                                        can raise this concern via the Speak Up helpline
                                                        at royalmail.gan-compliance.com/p/speakup
              1      2      3       4

                                                                                                                     38
Part 2 – Personal behaviour

 Religious and political beliefs
 We have a duty to deliver a consistent                  Your manager will work with you to manage any
 standard of service to all our customers, no            issues as a result of personal views or beliefs
                                                         and will consider any changes that can be made
 matter what our own views or beliefs may be.
                                                         where appropriate.
 During your day-today activities at work you might      We aim to strike a balance between the needs of our
 come across people who hold different religious         people and the commercial needs of our business.
 or political views to your own, or you might be asked   However, due to the nature of our work, it will not
 to handle items that conflict with your personal        always be possible to meet every request.
 beliefs. For example, you may be asked to deliver
 food products, alcohol, or other postal items that      Be aware we have a legal obligation to deliver
 conflict with your personal views.                      electoral material, so political conflicts are
                                                         unlikely to be resolved.
 We all have a responsibility to deliver great service
 to our customers and meet the requirements of our
 job. We need to be tolerant of the views of others
 and make sure our personal beliefs and opinions
 don’t cause offence.
 If your personal beliefs or opinions prevent you
 from being able to fulfil your role you should raise
 this with your manager.

                                                                                                               39
Part 2 – Personal behaviour

 Examples of appropriate and
 inappropriate behaviour
 Acceptable behaviour
 • Talking to employees about their performance
 • Providing constructive feedback
 • Asking an employee to carry out a task in the workplace
 • Providing a constructive opinion when asked
 • Taking appropriate action in line with the conduct,
    attendance, performance management or supporting
    performance improvement policies

 Unacceptable behaviour
 • Suggestive remarks or gestures
 • Displaying pictures with sexual or racial undertones
 • Demeaning or ridiculing someone
 • Jokes and banter of a derogatory nature
 • Unwelcome touching
 • Any sexual advances
 • Using social media (e.g. public or Royal Mail
    Group’s approved Facebook Workplace)
    to display any of the above behaviours

                                                              40
Part 2 – Personal behaviour

 Manager’s duty of care
  If you are a manager, your behaviour should never conflict with Our Business Standards.
  You should lead by example and demonstrate how to display Our Business Standards and
  company values at all times.
  Managers must:
  • show initiative and commitment – leading by example to encourage     Example
     others to do the same;                                               A manager often offers overtime
  • manage and support employees appropriately, treating others          to one of their team members
     as you’d like to be treated;                                         ahead of everyone else. This is
  • develop a team culture that encourages integrity and speaking up      showing favouritism to that
  • evaluate the performance of your team fairly;                        person and not treating all
                                                                          employees fairly and equally. By
  • protect the interests of the company by considering commercial       doing this, the manager isn’t living
     implications and other risks in your decision-making;                up to the standards of behaviour
  • put the interests of the company as a whole above those of any       we expect or demonstrating the
     specific part of the business;                                       company values at work.
  • use company funds as though they were your own, avoiding
     costs that don’t add value to our core business activities or      See our Leading with
     benefit our customers;                                             Integrity manager guide
                                                                        for more support
  • behave responsibly and lawfully, avoiding exposing yourself
     or the company to legal liability; and
  • take all reasonable measures to record and protect essential
     information and maintain business continuity.

                                                                                                                 41
Part 2 – Personal behaviour

 Working with colleagues
 We expect our people to behave in line with Our Business Standards and company values
 at all times. This means treating each other politely and with respect.
 You must:                                                              Remember:
 • always be open, honest and polite towards colleagues;               Protecting our colleagues and our
 • not abuse or offend others by the things you say or write,          reputation is important, which is why
    including in emails and on social media. Always be mindful that     we launched our confidential helpline
    writing or posting on social media can be even more hurtful and     – Speak Up.
    offensive than if you say it in person because social media has a   If you have concerns about issues like
    much wider audience and stays online for a long time;               misconduct or malpractice you can raise
 • not behave in any way that suggests prejudice or favouritism;       them through Speak Up without risk of
                                                                        reprisal. You can access Speak Up online
 • not take part in, encourage or condone bullying, intimidation,
                                                                        royalmail.gan-compliance.com/p/speakup
    harassment, unlawful discrimination or abuse of any kind to
                                                                        or over the phone (0800 090 3154).
    anyone, whether a colleague, customer, supplier or member
    of the public;
 • challenge any instances of this behaviour and show
    it is not acceptable in our organisation;
 • not exploit colleagues for loans, private work or favours
    of any kind; and
 • not retaliate against any colleague who reports wrongdoing.

                                                                                                               42
Part 2 – Personal behaviour

 Personal behaviour and appearance
  We expect high standards of personal behaviour at work from everyone.
  We should all demonstrate:
  • efficiency and reliability;
  • honesty;
  • punctuality and good attendance
  • a smart and clean appearance; and
  • integrity and confidentiality when handling
     customer and colleague data.
  Behaviour
  Behaviour which damages service to customers, our
  reputation or efficiency is unacceptable. This includes
  lateness; poor attendance; dishonesty, drunkenness;
  using illegal substances; misusing psychoactive
  substances (legal highs); violent or disorderly
  behaviour; and abusive language.
  Gambling is not allowed at work or on our premises.
  Employee clubs must keep to company rules.
  Possessing, selling and using alcohol and illegal
  drugs at work are not allowed, nor is the misuse
  of psychoactive substances.

                                                                          43
Appearance
Any nonpermanent marks (temporary tattoos, henna tattoos
and so on), badges, ribbons,jewellery, tattoos or ornaments
(including items used in body piercing) that are offensive,
indecent, a health-and-safety risk, or otherwise incompatible
with the standards in this booklet should not be displayed on
duty, or on company premises or property.
After reading this booklet, if you’re still not sure about the
standards you should be following, speak to your manager
or refer to the HR pages of the intranet.

                                                                 44
Part 2 – Personal behaviour

 Use of company funds and property
 We expect you to protect our property and assets.
 Don’t use our assets for your personal benefit                    Example
 or the benefit of anyone other than the company.                  An employee claims expenses for
 Make economic use of resources, avoiding waste                    their travel when they have to drive
 and extravagance.                                                 to other offices. They often add a
                                                                   few extra miles onto their claim
 You must:                                                         so they can claim more money.
                                                                   This is fraud, for which action will
 • not claim money from the company for hours you did             be taken under the conduct policy.
    not work;                                                      The employee may be prosecuted.
 • not claim money for a journey you did not make;
 • not claim an expense you did not legitimately have           For more information, see our business
    to pay; or                                                   travel and expenses policy
 • not use inside information about a company transaction
    for personal profit.
 All the above are unacceptable and may be treated as gross
 misconduct, which could result in your dismissal. If theft or
 fraud is involved, we may prosecute.

                                                                                                          45
Part 2 – Personal behaviour

 Using computers, phones and email accounts
 and protecting our valuable information
  Royal Mail Group goes to great lengths to protect colleague, customer and company
  information. As an employee you handle vast amounts of valuable Royal Mail Group
  information on a daily basis via our network, systems, devices and through information
  held electronically or on paper. Our best defence in protecting this information is our
  employees. It is everyone’s responsibility to ensure this information is protected
  in line with Royal Mail Group’s Acceptable Use Policy.

         YOU are our best defence against
         information loss and cybercrime.

  Information security and data protection requires
  a proactive approach to recognising and reporting
  lost, stolen and at-risk information. We all need stay
  vigilant for suspected or realised security incidents
  and data breaches, and notify the IT Helpdesk
  immediately on 0345 608 2555 when this happens.
  The quicker you report, the quicker Royal Mail
  Group can respond to protect your colleagues,
  our customers and our business.

                                                                                            46
Our Acceptable Use Policy helps employees               You must:
understand their individual responsibilities for        • protect information and handle confidential and
handling information and using the systems and             strictly confidential information in line with our
devices provided by Royal Mail Group . To support          policies, and not send it to anyone or anywhere not
this, Think Secure – Royal Mail Group’s internal           authorised to receive or view it
information security awareness programme –
provides further support and guidance on handling       • protect your IT equipment and not leave it
information securely from creation to disposal,            unattended, unlocked, or insecure at any time
staying safe online, using internal and public social   • use strong, unique and secret passwords to access
media responsibly, creating strong passwords,             Royal Mail Group systems and technology, and
cybercrime awareness, and reporting information           you must not share your own logon details and
security risks and incidents.                             passwords or use someone else’s
You are responsible for the information and             • log into Royal Mail Group accounts and systems
equipment in your possession and you must be               through secure and private networks
sure to protect them and keep to our policies at        • only download approved software from Royal Mail
all times. You must not use our systems to do              Group Technology and not download or modify our
anything which is unlawful, or which breaks any            software unless you have authorisation to do so
of Our Business Standards.
                                                        • comply with Our Business Standards and not access,
                                                           store, send or post anything indecent, pornographic,
                                                           abusive or threatening to others.

                                                                                                                  47
Social media
Never share Royal Mail Group business, colleague or        • Be responsible and social media savvy - only post,
                                                               publish or upload approved Royal Mail Group content
customer information on public facing social media,
                                                               to external sites, and do not upload or post anything
including photos. You can use Royal Mail Group’s
                                                               online on behalf of Royal Mail Group, unless it’s part
Workplace by Facebook to discuss internal
                                                               of your job. If information becomes available that
matters and exchange ideas.                                    shouldn’t be in the public domain, our reputation and
• Always be respectful of colleagues and customers            customer trust can be quickly damaged.
  when writing or posting online. You must not abuse       • Report incidents immediately - if you spot anything
  or offend others by the things you say on our internal      strange or suspicious, report it to the IT Helpdesk
  channels (for example, on emails or Workplace) or on        on 0345 608 2555 e.g. you lose any equipment, think
  external social media. Always be mindful that writing       your password or PIN may have been compromised,
  or posting on social media can be even more hurtful         notice unusual computer or mobile device behaviour,
  and offensive than if you say it in person because          receive requests for information from suspicious
  social media has a much wider audience and it stays         emails, instant messages, texts or phone calls.
  online for a long time. Remember, once you have
  posted something online, you may not be able to          For more information, see our Social media guide
  remove it.
                                                              For advice or guidance on information
                                                              security and data protection reach out to the
                                                              Think Secure team.
                                                              Email: ThinkSecure@RoyalMail.com
                                                              Call the IT Helpdesk: 0345 608 2555

                                                                                                                        48
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