Our Code of Business Conduct - Tesco PLC
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Our Code of Business Conduct.
Our Code sets Contents
out our most Introduction 2 Trading fairly 30
important policies.
••A message from Dave Lewis, Group CEO ••Competition laws
••What is The Code of Business Conduct? ••Trade restrictions & sanctions
••Raising your concerns ••Ethical trading
It is designed to ••How can I speak up?
••The Code & our leadership skills
••Laws that protect suppliers
••Brands & intellectual property
keep us and our
Looking after our customers 12 Protecting our reputation 42
••Clear prices & marketing ••Fraud
••Food & product standards ••Bribery
business safe. ••Protecting customer & colleague data
Working together 20
••Gifts & entertainment
••Conflicts of interest
••Insider dealing & market abuse
••Health & safety ••Engaging in political activity
••Equal opportunity, inclusion & diversity ••Accurate accounting & money laundering
••Unacceptable behaviour ••Keeping our information secure
••Human rights ••Social media & external communications
Protector Line and other 62
useful contacts
Keeping the business safe 3
‘As colleagues, we
are responsible for
following the Code.
Wherever we work
and whatever our role.’
Our Code of Business Conduct is designed Our Code means more than just following the
to help and protect us as we go about our law and our policies. It’s about using our Values
work for Tesco. In a competitive, fast-moving and Leadership Skills to guide our conduct and
and increasingly regulated marketplace, it is decision-making so that we are always doing the
important that each of us understands the right thing at work and working in a fair, open
rules that we must follow and the conduct that and honest way.
is expected of us in order to do a great job for
If you ever have concerns about your own
customers and help Tesco to play a valuable
conduct or that of another person, you must
role in society.
speak up straight away and talk to someone
The Code describes our most important legal you trust, starting with your line manager.
obligations and the policies that must guide Alternatively, speak to your Personnel Manager
our conduct. As colleagues, we are responsible or the Legal team. Or, if you feel the need to
for following the Code. Wherever we work and raise your concern anonymously, you can call
whatever our role, the Code is there to help Protector Line in complete confidence.
keep us safe and protect the reputation of
I want everyone who works for Tesco to be
our business among customers, colleagues,
proud of our business and of our achievements
suppliers, shareholders and other stakeholders.
for customers and the communities of which
Whether we are new to Tesco or have worked
we are a part. Knowing our policies, applying
for our business for some time, it is important
good judgement, being honest and speaking
that we take time to understand how the Code
up are just some of the ways that we can
applies to us.
build pride in Tesco and help build a stronger
business for the future.
A message from
Dave Lewis,
Group CEO
Dave Lewis Group CEO
4 Code of Business Conduct Keeping the business safe 5
What is the Code of How we keep
Business Conduct? ourselves safe
Our Code of Business Conduct sets down To make sure we follow the law, we have 1. The law
our minimum expectations for all colleagues, developed policies and blueprints on each key
We must always follow the law. It sits at the heart of customer
wherever we are based and whichever Tesco risk issue. These provide us with a protective
trust in Tesco.
business we work for. It provides guidance on layer of training, guidance and support to
each key risk area that may arise in our role. ensure that we know how the rules apply to us.
There are 21 of these and for each issue the
Beyond the law and our policies, we must
2. Our policies & blueprints
Code tells us who to contact if we need help
always be guided by our Tesco Values. These provide a protective layer of procedures, training,
or more information.
Our Values can guide us when we make and support to ensure we don’t break the law.
Our Code brings together three elements difficult decisions. They ensure that we
which keep us safe. At the heart of our Code
is the simple principle that we always follow
“do the right thing”, often going further
than the letter of the law and our policies.
3. Our Values
the law. The trust of our customers depends These ensure that we always “do the right thing” for our customers,
on our reputation as a law-abiding business. colleagues, shareholders and communities – often going further
for them than just complying with the law and our policies.
Our Values How to use our Code
Our Values guide us when we have difficult As colleagues we: And if you are a people
manager, you also:
•• Make sure we are familiar with the Code and
decisions to make. By following our Values,
•• Understand the Code and be able
we can be sure to do the right thing.
know how to access it.
•• Follow the law and our policies and know how to communicate its key messages.
the Code applies to our role. •• Ensure all new starters are trained on
•• Always attend training on Code-related issues. the Code and understand it.
We treat
•• Use our Values to help us “do the right thing”. •• Act
No-one tries Every little responsibly if a team member tells you
people how help makes they think the Code has been breached.
harder for they want to •• Speak up if we think the Code or the law has •• Speak up if you think others are breaching
customers a big difference been breached in any way.
our policies or are not demonstrating the
be treated
•• Ask questions if we are ever unsure. Tesco Values.
6 Code of Business Conduct Keeping the business safe 7
Recognising concerns How can I speak up?
Ask yourself: Who should I speak to? About our Protector Line
••In everything we do, it’s important always to Protector Line allows you to raise your
1. Could that be dangerous? have an open and honest relationship with concerns regarding misconduct at work.
your line manager. If you do not feel able to speak to your manager
••This means that your line manager is the or your Personnel Manager, you can call
2. Should he have done that?
Protector Line to:
person you should speak to first – unless you
3. Should I tell someone
think they have breached the Code. ••Raise any concerns about something at work
••If you cannot speak to your line manager, you think might be unlawful, that breaches
about that?
the Code or is against company policy.
you can speak to your Personnel Manager,
4. Isn’t that against the law?
your local Legal Director or your local Loss ••Report anything you think is a danger to
Prevention & Security Director. colleagues, customers or the general public.
5. Is that right? ••Alternatively, you could escalate your ••Share any concerns you have that
concerns within your own business information about these things is being
function if your line manager has not deliberately concealed.
resolved your concern.
Protector Line is completely confidential and
••If you need to raise your concern in complete run by an independent company for Tesco.
confidence, you can contact your local You don’t have to give your name when you
Protector Line. call although if you do, the Protector Line will
be able to update you on the outcome of any
investigation and will also be able to contact
you for additional information if necessary.
As a business we support the UK Public
Interest Disclosure Act 1998 (and its foreign law
equivalents) which protects the confidentiality
of complaints. This means that as long as
you’re acting in good faith and your concerns
are genuine, you are legally protected from
victimisation and will not be at risk of any form
of retribution, including losing your job, as a
consequence of raising a concern – even if you
are mistaken.
8 Code of Business Conduct Keeping the business safe 9
The Code & our
leadership skills
Collaboration
Working together across the business
to achieve shared success. By working
collaboratively with our colleagues and
suppliers, we provide our customers with high
quality products that are sourced responsibly.
Empathy
Building strong relationships with customers
and colleagues. We work to build strong and
enduring relationships with all those we do
business with so that we get the very best from
our customers, suppliers and each other.
Responsiveness
Being agile in the way you think, make
decisions and handle change. We listen when
colleagues or suppliers raise their concerns
about breaches of the code and take action
right away.
Resilience
Knowing your own sources of energy and
keeping yourself fit for life. We understand
the Code and ensure we follow it, even if it is
‘Our Tesco Leadership Skills support
sometimes hard to do. We speak up if we think
the Code is being breached.
us in doing the right thing for our Innovation
Keeping your eyes open so you can lead the
customers, colleagues, shareholders
business for the future. We look for new ways
to ensure the code is understood and followed
by colleagues.
and communities.’
10 Code of Business Conduct Keeping the business safe 11
Our value “No one tries harder
for customers” is central to our
success and encourages us to
understand our customers and
deliver for them every day.
This section of the Code covers issues relating
to giving customers clear price messages and
protecting their data.
Clear prices & marketing 14
Food & product standards 16
Protecting customer 18
& colleague data
1.Looking
after our
customers Keeping the business safe 13
Clear prices & marketing Questions & answers
Why does it matter? What does it mean for me? QQ I am planning a Chilean wine promotion QQ What rules apply to web-based advertising?
••If you are involved in any marketing activity, and will be using a vineyard picture for the
Advertising and marketing are among AA The same as for any other advertising.
posters. We have a great shot in the photo
the most powerful ways we talk to our ensure that all messages are honest, Messages must be accurate, clear and must
library of an Argentinean vineyard that we’ve
customers. Customers tell us that clear accurate and fair. not be misleading.
never used. Can I use that in my campaign?
••Keep promotions and pricing simple: avoid
communications about our products and
QQ I’ve noticed that the price of some products
prices are important to them. Whether through AA No. Your images must accurately
complex price promotions and frequent has been increasing just before they go on
television advertising, Clubcard mailings, online reflect the product you are advertising.
price changes. promotion. Is this allowed?
messages or at the point of sale, our messages You would need to source a photograph
influence our customers’ decisions as to where, ••Ensure that all messages are responsible; of a Chilean vineyard that produces the AA In many markets there are strict rules which
how and why they choose to shop with us. no customer should ever be offended by wine you are promoting. have to be followed whenever products
our advertising. are sold on promotion. Your local Legal or
If we get our messages wrong, we upset QQ Our product is cheaper than the price our
•• Trading Law teams can advise you on how
customers and may attract the attention of When comparing our prices or products competitor is selling at. Can I include this in
these rules apply in your market.
the media. Advertising standards are regulated with those of competitors, always use my POS material?
in many of the markets in which we operate accurate comparison data – compare like QQ There’s an Express store next to my child’s
AA Yes you can. However, it’s really important
and if we are found to mislead customers, we with like and keep comparisons up to date. primary school and they have put a poster
that you collect accurate and current
••Ensure that your advertising matches your
may face penalties and lose customer trust. So up to advertise the launch of a new violent
data to support the claim you’re making.
everything we say about our products must be martial arts X-Box game. Surely, it’s wrong to
products - validate all images so you are Remember, to monitor the competitor’s
true - and, if we say we’re offering a great price, be advertising violence where lots of small
certain that they are genuine and relate to prices and update your point of sale
it must be just that. Getting our messages right children will see it?
the products being sold. advertising to reflect changes in the price
directly influences the trust that customers
••Make sure your advertising is appropriate
difference as they occur. AA We would never want to place advertising
place in us.
where it is likely to cause offence or where
and responsible – especially for alcohol.
it could be construed as being harmful to
••Never make untruthful marketing claims children. You should speak up and share
about any third party, such as a supplier your concern with your line manager,
or a competitor. Trading Law or Legal.
Where can I find
out more?
• UK Legal
— Customer team
14 Code of Business Conduct 15
Food & product standards Questions & answers
Why does it matter? What does it mean for me? QQ I am concerned that a supplier of processed QQ Where can I learn more about the processes
••Ensure that our suppliers meet our product meat products is using inferior quality meat we have to manage product quality, safety
Our customers expect us to only sell products
in Tesco products. What should I do? and legality?
made to the highest quality and they trust safety and quality standards and comply
us to ensure that all our products are safe with our policies about maintaining product AA You should raise your concerns immediately AA The Tesco Product Quality Rules are a
and comply with all applicable laws and safety, quality and legality. with your line manager and your local basic guide to the principles by which
••Report any instances or suspicions of fraud in
regulations. We are committed to ensuring the Trading Law or Loss Prevention teams our products are made. This is available
safety and quality of all our products from the who will investigate the issue. Even if the from the Group Quality team or your
our supply chain.
moment we take delivery until the time our concern turns out to be unfounded, it’s technical manager.
customers buy them. ••Protect our reputation and preserve the important that you speak up.
QQ I am developing a new work routine that will
confidence of our customers that our
We are committed to using our scale for good. QQ I’m looking to list a new supplier for a change the way we handle frozen food in
products are safe and sourced responsibly.
We have simplified our supply chain to help new own brand product. What standards store. Who should I contact?
build better relationships with our farmers and ••Know who we buy from and carefully evaluate are our suppliers required to meet for
AA You should contact your local Operational
suppliers and ensure that all the products we each and every product we sell so we can be product quality safety and legality before
Risk or Trading Law team at an early stage.
source are safe, legal and meet our exacting certain our products can be fully traced in they supply us?
They can advise you on how to devise the
quality standards. our supply chain.
AA We have clearly defined Tesco new routine so that it meets food safety
We have a well-established and comprehensive ••If you are a store or distribution colleague, manufacturing and sourcing standards best practice and legal compliance.
food safety management system within our ensure you complete all food safety and that set out the requirements we want
stores and distribution centres. Every day hygiene training and refresher training and our suppliers to work to when they
we monitor and check the quality and safety take action if you identify unsafe products make products for Tesco brands.
of our food to make sure our standards on sale. We visit the sites before manufacture
are maintained. Such checks include the to verify that these standards have been
temperature of our products, personal hygiene, met. Talk to your local Trading Law team
cleanliness of our stores and equipment, for more information.
protecting foods from contamination and
managing the rotation of our food products.
Where can I find
out more?
• Quality team
• Loss Prevention
& Security team
16 Code of Business Conduct Keeping the business safe 17
Protecting customer Questions & answers
and colleague data
Why does it matter? What does it mean for me? QQ What is customer data? QQ Can I access our Payroll system to create
••If you are collecting information about a list of birthdays in our team?
Data is at the heart of our business. We collect, AA Any data relating to our customers or
process and use data every time we make our customers, always be clear with their activities in Tesco. This could include AA No. You are not allowed to access Payroll
contact with our customers. For example, data those customers what you will do with names, addresses and contact details, data unless you are authorised to do so and
on shopping habits allows us to give customers that information. transaction data, invoices, mobile phone it relates to a work matter, such as making
••Never share customer or colleague data
great deals on the products they love to buy. records, mobile application data, banking changes to their salary or their personal
We also hold and use information about our data, Clubcard data and correspondence details such as their name and address. A
with other people or companies in any form
colleagues, so that we can contact them and customers have sent to Tesco. better solution would be to ask your team
unless the customer or colleague has given
ensure they are paid on time. to provide you with this information again.
you permission to do so. QQ Can I send marketing e-mails to customers
••Make sure colleague and customer data is
Whether the data we hold belongs to our of our local Tesco Mobile business? QQ I’m working on a new marketing campaign
colleagues or our customers it must be in my business area. Can I contact
securely stored at all times and can only AA Normally, our privacy policies allow for
used carefully. We must always respect our customers who have already provided
be accessed by colleagues who have been customer data to be shared within the
customers’ and colleagues’ preferences for how their e-mail address?
trained on using data appropriately. Group for marketing purposes but you must
their data is used, including whether customers
••Never use colleague or customer data for check the exact local privacy policies to see AA We can only use our customers’ personal
want to receive marketing communications
if this is permitted. Even if it is, you must data for the reason it was provided.
from us. personal benefit.
always respect the marketing preferences Customers must have agreed to receive
So whenever we collect, process or use ••If you believe that any type of data might of the customers concerned and must marketing communications from us at the
data we must always follow our Customer have been misused, lost or be the subject ensure that any data is transferred securely. time of providing their details in order for
Data Principles: of an unauthorised disclosure, you must us to use that information to contact them.
inform your line manager immediately. We must also consider the customers’
Protected: We keep our customers’ data
marketing preferences: if they have opted
secure and make sure it doesn’t fall into the
out of marketing contact from us, then we
wrong hands.
must respect their choices
Appropriate: We only use customer data in
ways that customers consider appropriate
and responsible.
Open: We are clear with customers about
how we use personal data.
Choice: We provide customers with choices
over how we use their data.
Where can I find
Customer benefit: We make sure customers out more?
get as much benefit from their data as we do.
• Group Legal
Data Privacy team
18 Code of Business Conduct Keeping the business safe 19Our success depends on
our people. The Tesco Value
“Treat everyone how they like
to be treated” ensures that
we get the most from our
teams and helps colleagues
realise their ambitions.
This section of the Code covers
the key issues relating to people.
Health & safety 22
Equal opportunity, 24
inclusion & diversity
Unacceptable behaviour 26
Human rights 28
2.Working
together
Keeping the business safe 21Health & safety Questions & answers
Why does it matter? What does it mean for me? QQ I have just joined Tesco and colleagues have QQ Who are our Health & Safety specialists?
••Follow and understand safety instructions told me that safety training takes a while to
We are all responsible for making Tesco a safe AA Every business unit employs specialists in
complete and is just “common sense”.
place to work and shop. Everyone should and guidance and the Health and Safety Health & Safety who can deal with technical
Do I really need to do the training?
be able to do their job in a safe working policies and procedures that apply to questions and manage the process of risk
environment. Our customers rightly expect your role. AA Yes. All new colleagues must be familiar assessment. These colleagues all possess
••If you are a manager, you must set an
our stores to be safe so that they can enjoy with safety precautions necessary in safety qualifications and considerable
shopping with us. Each of the countries in which their workplace and know what to do in experience that together make them
example of safety leadership and create a
we operate has safety laws and regulations with an emergency. Not all workplaces are the competent in their own field. Their details
workplace where people follow your example
which we comply. Our own standards exceed same and we all have different levels of should be listed on the colleague or safety
of doing the right thing.
basic legal requirements to ensure that no-one experience. Our safety training makes sure notice board.
is exposed to injury or harm. ••Ensure risks are understood and have proper that we all work together to stay safe.
QQ How can I report a safety
plans to minimise potential harm from them.
Accidents and injuries can cause distress to QQ I’m worried about the safety of a new piece concern confidentially?
colleagues and customers, and in some cases ••Safety is everyone’s responsibility –if you see of equipment. What should I do?
AA In the first instance, talk to your line
can have very serious consequences. As well something that you think is unsafe or could
AA If no instructions or training have manager or Personnel Manager. The
as the personal impact that an injury can have cause an accident, take action to deal with it
been provided, it should not be used. Protector Line is also there for colleagues
on individuals and others’ lives, the disruption or tell someone immediately.
You should check with the provider who to report safety concerns. It can be used
••If you see a colleague working in a way that
to the business caused through absence
should have supplied a risk assessment completely confidentially and every
from work and costs from investigation,
could harm them or others, step in and and designed the right controls. If there report is investigated independently.
medical treatment and compensation can
remind them of the safe way to work. are instructions and you’re still concerned,
be substantial. Failure to deliver on our
••Never agree to do anything if you don’t have
contact your local Health and Safety
responsibilities could also lead to legal action
specialist – you’ll find their details on
being taken against us, damaging our reputation the appropriate knowledge or training to do
your local safety noticeboard.
and the trust our customers and colleagues it safely.
have in us.
Where can I find
out more?
• Group People
Safety team
22 Code of Business Conduct Keeping the business safe 23Equal opportunity, Questions & answers
inclusion & diversity
Why does it matter? What does it mean for me? QQ I am a store manager and need to make a QQ A colleague is recruiting a new team
promotion decision between two colleagues. member. They have made a number of
We aim to employ people who reflect the We strive to create an environment of equality
Since one colleague is 50 and nearing remarks that I am concerned mean they may
diverse nature of society and we value the and inclusion where you feel your contribution
retirement age and the other only 30, should be discriminating against certain candidates.
contribution made by every colleague, is valued, you are treated well and you are
I promote the younger colleague since they What should I do?
irrespective of age, sex, disability, sexual encouraged to fulfil your potential.
may work for us for many more years?
orientation, race, colour, religion, ethnic AA You should always raise your concern in
We must all:
origin or political belief. At our stores, in our AA No. We only make employment decisions the manner you feel most comfortable
distribution centres and in our offices, we ••Demonstrate respect for our fellow based on job-related skills, achievements with, as we will not tolerate any form
make employment decisions solely on the colleagues, and others that we come into and performance. We never make decisions of discrimination. This could be in a
basis of job-related skills, achievements and contact with, whether they are customers, based on age or any other non-job related confidential manner through your line
performance, using clearly defined and suppliers or other parties, regardless of any characteristics. manager, your Personnel Manager or via
fair criteria. social or cultural differences. Protector Line.
QQ My personal circumstances have recently
We also try and make sure everyone can work ••Create an environment of openness and changed. Am I able to reduce my weekly
in a way that suits their circumstances – we collaboration so we can draw from the working hours?
support flexible working, offering part-time diversity, knowledge and experience of
AA We will always try and accommodate any
roles and encouraging job-sharing opportunities our colleagues.
change you would like to make to your work
••Voice our views and concerns through the
and shift swapping where this is possible.
arrangements, and in the first instance
relevant channels so that we can all work we ask you to discuss this with your line
together to make Tesco a great place to work. and Personnel Managers. They will want to
••Make the right employment decisions,
understand your request, the impact on
your job role, and talk through the options
for example recruiting new colleagues
for covering the work.
and reviewing those who already work in
your team, based on merit and business
considerations alone.
••Understand employment and equal
opportunities laws and local culture that may
have an impact on workplace decisions and
ways of working.
••Support initiatives to improve employment
Where can I find levels and skills where this is needed.
out more?
• People team
24 Code of Business Conduct Keeping the business safe 25Unacceptable behaviour Questions & answers
Why does it matter? What does it mean for me? QQ My line manager can be very intimidating and QQ I know a colleague has been having some
••Create a welcoming and inclusive work often abusive to the colleagues in our team. difficult times at home. Lately, they have
We are proud to work for a company that values
We know he is a perfectionist, but it makes been turning up to work very late and
everyone and treats them the right way. We do environment, and encourage those who you
our work unenjoyable and difficult. I worry sometimes appear intoxicated. They are still
not tolerate abuse or unacceptable behaviour work with to do so by treating everyone as
that if I speak up, he might become worse. getting their work done so I am not sure if I
in the workplace in any form, whether towards you would like to be treated.
What should I do? should say something. Should I speak up?
••Don’t engage in behaviour that would
our customers, other colleagues, suppliers or
anyone else. We all share in the responsibility AA Abusive or bullying behaviour is never AA Yes. For the good of your colleague
be considered by anyone in the team
for making sure that Tesco offers a safe and acceptable no matter who is doing it. Our you should always raise your concerns
as creating a hostile or intimidating
open environment for colleagues to work. culture is one of respect and inclusion if you believe that they are engaging in
work environment, including making
and any such actions should be reported behaviours that might be dangerous to
We should be sensitive to actions or behaviours inappropriate jokes or comments.
immediately via our confidential Protector themselves or others. This includes the
••Don’t spread malicious rumours or gossip
that may be acceptable in one culture but
Line. You will always be supported in raising use of drugs or alcohol. If you can’t
not in another. Some of these behaviours may
that might be considered derogatory, any legitimate concerns. talk to them directly, speak to your
even be illegal in other countries where we
defamatory, harassing, pornographic or Personnel Manager or line manager.
operate. Colleagues found to have engaged QQ A friend sent me an email with some rude
otherwise offensive.
in unacceptable behaviour can face serious jokes I think are very funny. Can I email them
consequences such as disciplinary action, ••Take responsibility for your performance to my team of colleagues?
including dismissal, and potentially legal action. by never using drugs or alcohol in the
AA No. We treat all colleagues with dignity
workplace. Such abuses are illegal, dangerous
and respect and what you consider funny
to yourself and others, and pose safety risks
might be considered abusive or offensive by
that will not be tolerated.
others. Always ask yourself whether
••Make sure that your conduct when you are your actions might be offensive, abusive
at off-site events is as it would be at work. or intimidating to others. This includes
Company-organised events include social viewing any inappropriate material while
events such as Christmas parties, team you are at work.
events and social outings.
Where can I find
out more?
• People team
26 Code of Business Conduct Keeping the business safe 27Human rights Questions & answers
Why does it matter? What does it mean for me? QQ I have heard through the media and friends QQ When we discover an abuse of human
••Help make Tesco a great place to work where that slavery issues may exist within the rights, do we automatically stop working
We are a global company and interact with
international supply chain. What are we with the supplier?
millions of people around the world every day. everyone is welcome and human rights are
doing to ensure there is no slavery in our
We have a responsibility to respect the human respected. This includes the freedom for all AA No. While we may suspend orders in the
supply chains?
rights of our colleagues, our customers, those colleagues to join a trade union. short-term, we should always use our
••Make yourself familiar with our Human Rights
who work throughout the supply chain and AA We do not tolerate any form of slavery or influence to help remedy the situation.
people in the communities of which we are part. forced labour. We have an extensive ethical Only as a last resort, for example where
framework and share it appropriately.
trade programme, including a team of full- a supplier refuses to co-operate or make
••Speak up if you are concerned that a
Any breach of a person’s human rights is wrong.
time labour standards specialists around improvements, would we ultimately
Through our Values “Using our scale for good”
colleague or supplier might be responsible the world who work with our suppliers terminate a relationship.
and “Treating everyone how they like to be
for an abuse of human rights. We will to improve conditions. We also work in
treated”, we work to ensure that our activities QQ We talk about stopping the abuse of
always take such allegations seriously partnership with others, including retailers
do not encourage abuses of human rights. We human rights, but what are we doing to
and investigate accordingly. and organisations such as the International
expect this of ourselves and other stakeholders promote them?
••Be a good neighbour wherever we operate. Labour Organisation and Ethical Trading
expect it of us too.
Initiative to address complex challenges. AA By using our scale for good we are
We recognise the role our colleagues play ••Build strong partnerships with trusted QQ I would like to join a trade union but it isn’t
addressing many global challenges which are
as part of civic society, and this means we suppliers and ensure that human rights and often closely aligned with specific human
the one that Tesco has recognised for the
also recognise their right to participate as labour standards are respected throughout rights as defined by the UN. For example:
purposes of pay negotiations. Can I join?
individuals in political activities and also the supply chain. the right to education, to be free from
collectively in the form of union membership. AA Yes, you are free to join a trade union of hunger and to enjoy the highest attainable
your choice. You are also free not to join a standard of physical and mental health.
We aim to work to the highest international
trade union at all.
standards. We were a founding member of
the Ethical Trading Initiative and also fully
support the UN’s Declaration of Human
Rights and the Core Conventions of the
International Labour Organisation.
Where can I find
out more?
• Responsible
Sourcing team
28 Code of Business Conduct Keeping the business safe 29Our values help us be first
for customers, without
compromising our strong
relationships with suppliers.
This section of the Code covers issues that are
critical to how we buy the products that are
sold in our stores.
Competition laws 32
Trade restrictions 34
& sanctions
Ethical trading 36
Laws that protect suppliers 38
Brands & intellectual 40
property
3.Trading
fairly
Keeping the business safe 31Competition laws Questions & answers
Why does it matter? Setting retail prices QQ I have been asked to attend a trade QQ Can I ask my supplier a question about a
••Always set retail prices independently. association meeting. Can I participate? competitor’s future prices?
Our customers expect us to compete fairly
••Always focus on cost prices during price
and independently in every market. Healthy AA Yes, these meetings are not in themselves AA No, we should not have advance warning of
competition brings lower prices, wider choice problematic, and may be pro-competitive. a competitor’s future prices. If a competitor
negotiations with suppliers. Suppliers can
and better products. We use our scale for good However, the normal competition rules or supplier ever gives you this information,
give us recommended prices but not fixed or
by competing hard with our competitors to offer apply - make sure you do not discuss, you must follow the Pushback Process and
minimum prices.
our customers the best shopping experience. disclose or exchange commercially sensitive inform your local Legal team. The Pushback
The Pushback process information with a competitor. Refer to Process is designed to ensure that you
Legislation exists in all of our markets to protect
••If contact with competitors or suppliers “Meetings with Competitors” guidelines. visibly disregard such information should
competition and there are significant penalties
you ever receive it and have an audit trail to
for companies and individuals that break the raises any concerns, you must follow the QQ Can I invite more than one supplier to
demonstrate that you have not made use of
law. Investigations are disruptive and costly for Pushback Process. It is not enough to simply a meeting?
this information.
the business and can damage the trust that ignore the information, even if it is obvious
AA From time to time, it may be sensible
customers place in us. that it was disclosed in error or is inaccurate.
to invite suppliers to a joint meeting,
What does it mean for me? Document creation for example, to brief suppliers on key
••Take care when writing about our business, changes to our business or to discuss best
Contact with competitors
practice in relation to supply chain issues.
••Always act independently. Never agree with our customers, suppliers or competitors.
However, these meetings can be sensitive
Remember that most internal documents,
competitors to reduce competition between because they often involve suppliers who
including e-mails, text messages, committee
us. You cannot agree to fix prices or agree are competitors. Refer to “Joint Supplier
papers and property reports can be viewed
where we will or will not operate. Meetings” guidelines and ensure that no
by regulators during an investigation.
••You must not ask for, receive or share
inappropriate activity takes place during
the meetings.
confidential, commercially sensitive
information with competitors. You can use
information in the public domain to help
make decisions.
Contact with suppliers
••You must not request or receive confidential,
commercially sensitive information about a
competitor from a supplier.
••Keep our suppliers’ confidential information
Where can I find
out more?
confidential and do not share it with
their competitors. • Group Legal
Competition
••You can ask suppliers for information in the Law team
public domain to help us make decisions.
32 Code of Business Conduct Keeping the business safe 33Trade restrictions & sanctions Questions & answers
Why does it matter? What does it mean for me? QQ I am a buyer looking for new markets to QQ I would like to set up a wholesale deal to sell
source from. I found a great supplier I want to Tesco products in a new country for the first
From time to time, governments impose As a colleague working in a global business,
start using. Does it matter that the owner of time. As long as the business looks good do I
restrictions on buying from, or travelling to, if you are involved with buying, shipping or
the company is in a sanctioned country if his need to consider anything else?
certain countries. We may also be banned selling of goods or services internationally,
business is not?
from trading with certain named individuals. be careful to: AA Yes. You should discuss with Corporate
••Not buy from, or travel to, countries subject
We must always be aware of these restrictions AA Yes. Sanctions laws are often very broad Affairs and Legal whether there are any
when doing business around the world. and include more than just the country at specific trade restrictions, sanctions or
to sanctions or travel conditions.
In today’s globalised world, not only issue but all nationals or individuals of the other reasons why we should not sell to
governments, but also our customers expect ••Not work with individuals or companies that country under sanction. Always know who that country. Legal will also support you to
us to be aware of sanctions or restrictions appear on UN or other sanctions watchlists. you are doing business with and seek advice conduct due diligence on the customer, so
••Seek legal advice if you are unclear whether
when doing business with certain countries, from your Director before acting. that you know enough about them before
companies or individuals. beginning a trading relationship with them.
any restrictions or sanctions apply to
If we break trade restrictions, this could your activities.
••Speak up if you believe anyone is breaching
damage the trust customers have in our
brand and may also result in serious penalties
trade restrictions: all suspected violations
for both the business and colleagues.
must be reported to your local Legal Director
or anonymously to Protector Line.
Where can I find
out more?
• Group Legal Business
Integrity team
34 Code of Business Conduct Keeping the business safe 35Ethical trading Questions & answers
Why does it matter? What does it mean for me? QQ My supplier has been found to be paying QQ Child labour has been found at my supplier’s
••Carefully consider which suppliers you their workers below the legal minimum site. What should I do?
Our customers expect that we will only work
wage. What should I do?
with suppliers who share our Values and treat place business with – price should not AA You should bring this to the attention of
their people the right way, so we must ensure be the only factor: quality, reliability AA Place all orders and deliveries on your local Ethical Trading team right away,
that suppliers of products and services respect and ethical responsibility are important hold and call the supplier to discuss. even if children are legally entitled to work
local labour laws. Since these vary around the considerations too. Workers’ employment terms should be in that country. The ETI Base Code places
••If you work with suppliers in your role,
world, we use the Ethical Trading Initiative (“ETI”) updated immediately and back-payment strict requirements on all young workers.
Base Code as a mechanism to promote better for all underpaid workers agreed and In order to ensure that the issues are
ensure they are aware of the ETI Base
and more consistent global standards. paid as quickly as possible under the resolved on a permanent basis, the team
Code and its requirements. Ensure that
supervision of independent witnesses. will address the issue directly with the
In developing countries, trade with Tesco is agreed improvements are completed on
Contact the Ethical Trading team for supplier’s management team. In the short-
particularly important in helping people live a timely basis.
guidance and support. term, you should avoid placing orders with
••When talking to or visiting suppliers,
better lives – a clear opportunity for Tesco
the supplier until you are advised that the
to use our scale for good. Decent working QQ I am visiting a site and have discovered that
be aware of the conditions they work issue has been resolved.
conditions are important to people everywhere, the fire exits are locked. What should I do?
under and the challenges they face.
even in developed countries. QQ Do ethical trading requirements apply only to
In other words, show empathy. AA You should escalate your concern
goods that we sell in store?
••Be alert to potential problems such as
We also need to be careful that our own immediately to your local Ethical Trading
business practices do not become the team who will take action directly with the AA No. We expect all suppliers, including those
unsafe working conditions, abusive
cause of labour standards issues. Developing supplier, including additional auditing of the who provide goods not for resale and
behaviour, underage or illegal workers:
long-term relationships with suppliers we supplier’s sites if required. You should raise services, such as construction companies,
raise any concerns you might have with
know and trust gives them the confidence your concern while on site and insist that labour agencies and logistics firms to meet
the Ethical Trading team.
to invest in improvements so we can achieve the fire door is unblocked. our ethical trading requirements.
more together. ••Always stick to commitments you have
made. Last minute changes, or not providing
information on time, can lead to suppliers
feeling obliged to cut corners to meet our
deadlines. This can have a negative impact on
working conditions and product quality.
Where can I find
out more?
• Responsible
Sourcing team
36 Code of Business Conduct Keeping the business safe 37Laws that protect suppliers Questions & answers
Why does it matter? What does it mean for me? QQ Can I ask a supplier to fund a promotion? QQ I buy soft fruit for sale in Poland and the
••Understand and follow the laws and codes of Czech Republic and my supplier claims
Treating suppliers fairly is key to our success. AA In most markets this is permitted but there
they have the right to speak to my “Dispute
Developing long-term, reliable and sustainable practice in your market which are designed are limitations on how much they can
Resolution Officer”. Is this correct?
relationships with our supply base is essential to protect suppliers. contribute and suppliers must never be
••Keep to the commitments that you make
to providing predictability for suppliers and forced to participate in a promotion. AA Yes, Tesco is a signatory to the EU Supply
delivering the very best for our customers. Many Chain Initiative which is a mandatory code
to suppliers - do not make retrospective QQ I work in General Merchandise. In my market,
countries have introduced legislation to regulate of practice governing fairness in the supply
changes to supply agreements. the Retail Code applies only to groceries.
the supply relationships between supermarkets chain. Your supplier is entitled to speak to
••Record all agreements with your suppliers Should I follow the Code as well?
and their suppliers and all of our suppliers are our Dispute Resolution contact - normally
able to raise issues in complete confidence in writing. AA Retail codes normally represent the way the Legal Director.
••Give reasonable notice of any proposed
using our Supplier Protector Line. that we want to engage with suppliers across
QQ My competitors are selling products more
our whole supply base. You should follow
In the UK, the Groceries Supply Code of changes to supply arrangements and cheaply than us. What can I do to redress
these principles as best practice whenever
Practice (GSCOP) imposes an important set provide an opportunity for suppliers to have the balance?
you are working with our suppliers.
of legal rules that governs the relationship decisions reviewed.
Contact Legal with specific questions. AA You should always negotiate with
••Always work collaboratively with suppliers
between Tesco and its grocery suppliers. The
suppliers to get the best deal you can
most important of these is that we deal fairly QQ What is the de-listing process under GSCOP?
and always listen to feedback they give you. for customers. You can discuss whether
with our suppliers at all times. Similar legislation
••Be guided by the Tesco Values and Leadership AA GSCOP requires that you must always the supplier’s cost price is acceptable
exists in many other markets around the Group.
have a genuine commercial reason to end but take care not to place suppliers under
Investigations into breaches can be costly and Skills when making decisions about suppliers
a relationship. You must provide written duress when negotiating with them and
••If a supplier complains, acknowledge and
time-consuming. Significant fines may result
notice to the supplier and explain how avoid making retrospective changes to
and customer trust maybe damaged.
resolve it quickly, with help from your local they can have the decision reviewed by existing supply agreements.
Legal team if necessary. a senior buyer or escalated to the Code
••Be thoughtful and empathetic
Compliance Officer.
when communicating with suppliers:
written communications can easily
be misinterpreted.
Where can I find
out more?
• UK Legal
Product team
38 Code of Business Conduct Keeping the business safe 39Brands & intellectual property Questions & answers
Why does it matter? What does it mean for me? QQ I’m designing a new T-shirt range for girls. QQ I would like to start selling branded goods
••Always seek to create or source original How do I ensure I’m not infringing anyone bought and imported from outside my local
At Tesco, we have a proud tradition of
else’s Intellectual Property? trading territory (Parallel Goods). What
creating and nurturing exciting brands, designs and products for our customers.
should I do?
••Don’t copy, use or be heavily inspired by
products and services. From the Tesco brand AA Know your market and what products and
and F&F clothing, through to our Finest food designs are already out there. You are free AA This may be ok, so long as you are not
other people’s ideas.
ranges and the Hudl device, our brands and to take some inspiration from existing ideas, breaching the brand owner’s rights.
innovation give us a competitive edge in a ••Always follow the Tesco Brand Guidelines and but don’t copy another product. The Legal For example, within the EU we can deal
crowded marketplace. seek approval from the appropriate Marketing team would be happy to discuss your new in parallel goods, subject to certain rules.
Director or governance group. product with you to make sure it’s ok to use. Rules vary from country to country and
We must always take care to protect our
••When you’re developing new ideas, keep the Legal team can provide specialist
intellectual property rights – from patents, QQ I’m planning on working with a third party to
advice if needed.
designs and copyright, to trademarks and trade them confidential and talk to Legal about how develop some new technology which could
secrets. Protecting what is ours helps us to to protect them. really improve efficiency at our distribution QQ We’re creating a new brand for a range of
••Consult with Legal before allowing third
ensure that it isn’t copied or sold by others centres. What steps should I take? bakeware products which we plan to sell in
without our agreement. several markets. How should we go about
parties to use our brands or other AA You should always put in place an agreement
choosing a brand name?
If we’re involved in creating new product intellectual property. with the third party which sets out who will
••Raise your concerns if you identify that
designs, brands or innovations for Tesco, we own any IP in the new technology. Your Legal AA Follow the Tesco Brand Guidelines and
must always understand our brand guidelines team can advise if the new technology can make sure your name is different from
another business has copied our ideas or
and know and respect the IP rights of others. be protected by a patent or any other form existing brand names used for identical
breached our IP rights.
Stealing someone’s idea reflects badly on Tesco of intellectual property right. and similar goods. You should also conduct
and it damages customer trust. ••Take care if you are looking to import “grey internet searches and use your market
goods” (sometimes called “parallel goods”). knowledge to help you. Don’t commit to one
Special rules are in place to ensure such brand too soon in case there are legal issues
goods area not counterfeit and that the with the name.
rights of third parties are not violated.
Where can I find
out more?
• UK Legal
Customer team
40 Code of Business Conduct Keeping the business safe 41Doing the right thing ensures that
we do not compromise ourselves
or the business by our actions
and that we are aware of the risks
we face as a global business.
This section of the Code covers a number
of important areas where we can protect
ourselves and our company from wrongdoing.
Fraud 44
Bribery 46
Gifts & entertainment 48
Conflicts of interest 50
Insider dealing 52
& market abuse
Engaging in political activity 54
Accurate accounting 56
& money laundering
4.Protecting
Keeping our 58
information secure
our
Social media & external 60
communications
reputation Keeping the business safe 43Fraud Questions & answers
Why does it matter? What does it mean for me? QQ A colleague in my distribution centre has QQ A colleague I work with has been submitting
••The main rule is simple. If you suspect been selling over-delivered stock on e-Bay. invoices from a supplier where the amounts
Fraud is a serious crime that harms our business
He says it’s for charity and was agreed with do not match the supporting documents.
and can have a significant impact on our costs theft or other fraudulent activity is taking
the DC Manager but I don’t know where the He claims the difference was agreed in a
and profits. The term fraud is commonly used place, you must speak up. Report it to your
money is going. What should I do? different contract, that they are “always
to describe theft through a wide variety of line manager, Personnel Manager or local
done this way” for this supplier and that
dishonest behaviours such as deception, Protector Line. AA Even if your concern is unfounded, it is
I can amend the documents so they match.
••Don’t do business with companies with a
forgery, lying and concealment of material facts. important that you speak up. If you are not
What should I do?
comfortable speaking to your line manager
Fraud may occur in many different parts of our reputation for fraudulent activity. Always
or the DC Manager, you can call Protector AA You should refuse to amend the documents
business, including during online transactions, conduct due diligence on new third parties
Line and raise your concerns. You will not be and ask your colleague to obtain correct
at the tills, during the transportation of goods before you work with them.
required to give your name when you call. ones. Inconsistent invoices and documents
••Look out for fraud “red flags” and take action
through our distribution system or in the office.
are a “red flag” for fraud or fraudulent
QQ A colleague was travelling for work recently
Tesco is the victim of fraud, so we all have a if you identify them. Red flags include sudden activity and we reduce those risks by
and took some friends out for dinner and
responsibility to protect the business from changes in lifestyle, such as extravagant keeping accurate records and invoices. If
submitted the meal for reimbursement
fraudulent activity, whoever commits it. We purchases of cars or other high value items. you are still unsure what to do then raise
as an expense? She says this is fine as she
••Always be aware of our travel and
place significant trust in our colleagues to you concern with your line manager.
often forgets to submit other expenses so
act honestly at all times, so we will always
expense policies. everything “balances out” ultimately and I
investigate and take action when fraud is
should do the same. Is this acceptable?
committed against our business.
AA No. By submitting these expenses she
is committing fraud. Personal expenses
should reflect what charges you have had
whilst working.
Where can I find
out more?
• Group Safety,
Security and
Resilience team
44 Code of Business Conduct Keeping the business safe 45Bribery Questions & answers
Why does it matter? What does it mean for me? QQ My colleague has boasted that her suppliers QQ I often engage with consultants who obtain
••Never give bribes, payments, gifts such as know they must “look after her” if they want permits I need for the business. A new
As a business operating stores and buying from
to keep working with Tesco. Is that right? consultant has offered to reduce the admin
suppliers around the world, we must be alert cash or any other benefits to persuade
and waiting time by half but isn’t clear how
to the risks associated with bribery. We pride someone to act in your favour. AA No. It is a breach of our gift policy to
they do this. Should I be concerned how they
••Never seek or accept bribes, such as gifts or
ourselves on our reputation for acting fairly and solicit entertainment or other benefits in
do it if they can deliver what I need?
ethically wherever we do business. return for buying goods or services from a
entertainment to give business to a new or
supplier, it may also be bribery. You should AA Yes. The actions of those who act on our
It is important that everyone understands our existing supplier.
raise your concerns right away. Speak to behalf pose significant risks of bribery for
••Know and understand the third parties we
zero tolerance approach to bribery and our
your line manager or contact Legal or Loss us. It is important we are clear on exactly
commitment to reduce corruption around
engage by conducting due diligence on them, Prevention & Security. what they are doing and how they are
the world. Bribery is illegal in all the countries
in particular on those that perform services acting on our behalf. Our reputation is too
in which we operate. It damages markets and QQ In my market it is not illegal to pay the local
on our behalf. important to risk being damaged by an act
communities and transfers resources into the official a small amount of cash to get my
••Be mindful of the bribery risks posed by of bribery and we can be liable even if we
wrong hands. paperwork stamped. Is this a problem?
were unaware of it. Speak to your local
engaging with public officials and ensure
As a business we expect everyone who AA Yes. This is actually a small bribe also Legal contact and ensure that you conduct
our engagements are always open, honest
works with us to adopt the same zero known as a ‘facilitation payment’ and appropriate due diligence on all third
and transparent.
tolerance approach. The UK has some of is illegal under UK law, even if you are parties before they act on behalf of Tesco.
the strictest bribery laws in the world and ••You can use legitimate fast-track processes working for Tesco in another country.
they apply to everyone who works for us, in order to expedite routine decisions Like all bribes, facilitation payments
including agents and contractors. UK citizens but never make payments directly to must be refused and reported.
may even be prosecuted for acts of bribery public officials in order to secure a permit
committed abroad. or licence.
••Make sure you are fully trained on bribery
and corruption risks and issues we may
face across the business.
••Co-operate fully with law enforcement
agencies and investigators and support
prosecution or disciplinary action where
sufficient evidence exists.
Where can I find
out more?
• Group Legal
Business
Integrity team
46 Code of Business Conduct Keeping the business safe 47You can also read
