Marks & Spencer Code of Ethics and Behaviors, Summaries of Ethics

Download Marks & Spencer Code of Ethics and Behaviors and more Summaries Ethics in PDF only on Docsity! Code of Ethics and Behaviours Please note: This is an exact copy of our internally focused Code of Ethics document. Any links, guides or policies referenced within are held on the Marks & Spencer Network. These will not be accessible outside Marks & Spencer Introduction At Marks & Spencer we are committed to our core values of Inspiration, Innovation, Integrity, and In Touch. They are key to the way we work and interact with our customers, suppliers and colleagues across the business and underpin our customer promise of ‘Enhancing Lives, Every Day’. Our Code of Ethics and Behaviours (the “Code”) outlines the standards and behaviours that help to shape and strengthen our culture. All colleagues are expected to uphold these high standards wherever in the world we conduct business, ensuring that honesty and integrity is maintained. The Code sets out in brief, with some explanation, key Company policies and procedures. This Code, although not addressing every situation you may face as an employee, does provide a guide to the values, behaviours and ways of working which are core to M&S and which each of us is responsible for upholding as an employee. You should read the Code carefully and refer to it if facing an ethical dilermma at work. It is essential to create a supportive environment in which you feel able to raise concerns internally without fear of disciplinary action. If you have any concerns or something you come across doesn't feel right, speak up. behaviours that are not in accordance with the Code, or the policies to which it refers, by following the procedure set out below: Line Manager In the first instance, you should consider raising your concern with your line manager. | le/she has 3 responsibility to listen and respond to any matter that is of concern to you. Concerns can be raised verbally or in writing. They may be able to agree a way of resolving your concern quickly and elfectively. Senior Manager If you feel that you cannot raise your concern with your line manager, for whatever reason, you should contact the senior manager in your business unit or store, who will consider the matter and, if appropriate, manage any investigation Independent Internal Hotlines If you Teel you need Lo raise Lhe issue oulside of your irnmrnediaLe working envirenrnent, or if you Teel Lhal, aller reporting the concern internally, the matter still remains unresolved, you should contact one of the following confidential hotlines; Email: confidential@marksandspencer.com Call from the Uk: 08000 150781 Call from the Republic of Ireland: 1860 411 063 International 144 (0) 208 718 5562 For more information and to view the policy in full please refer to the Whistleblowing Policy. Where appropriate, your concern will be referred to the Group Secretary who will inform the Chief Executive and the Audit Committee Chairman of any serious issues as a matter ol urgency. Audit Committee Review The Audit Committee reviews arrangements by which employees may, in confidence, raise concerns about possible inappropriate activity such as financial misreporting or other matters. Ihe Committee reviews concerns raised through the Whistlcblowing Policy to make sure that any significant matters receive independent investigation and appropriate follow up action. The Head of InLernal Audil and Risk reports any information on allegalions and investigation resulls Lo Lhe Audit Committee at least once a year Human Rights Ilurman rights are fundamental principles which allow an individual to lead a dignified and independent life. free from abuse and violations. We will not tolerate, nor will we condone, abuse of human rights within any part of aur business or supply chains, and we will take seriously any allegations that human rights are not properly respected. If you have reason to belicve that such aclivily is Laking place wilhin Lhe Company or in any of our supply chains, please report Lhis Lo your line manager, or call the Independent Internal Hotlines (details above). Bribery and Corruption We do not give or accept improper payments or gifts in order to conduct business anywhere in the world. We agree the terms of supplier payments at the start of business and pay in accordance with our contractual obligstions, We operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Company's behalf You should not get involved in any business transactions that could result in personal benefit. You should not use your position as an M&S employee to get discounts from contractors/suppliers unless they are corporate agreed discounts notified and made available to all ernployees, or do personal business, unless expressly authorised by management. Bribery, Gifts and Entertainment All employees must fellow the rules on Gifts, Hospitality and Entertainment, including declarations recorded on the individual Gift, |lospitality and Lntertainment Registers. In addition, employees of M&S Joint Ventures or subsidiaries, whether in the UK or elsewhere, are required to follow these standards. We also expect employces of our franchise partners and suppliers Lo conducl Lhernselves in accordance wilh Lhese slandards. The Anti Bribery Policy sets out what is and is not acceptable in general terms, but if you are in any doubt as to whether any conducl could arnounl Lo bribery, Lhe raller should be referred Lo Lhe Group Secrelary, who is Lhe Chiel Compliance Officer for this policy. It is essential that you read and comply with this policy. Fraud Fraud is deerned gross misconduct. Disciplinary procedures will be rigorously applied to any instances of fraud and are likely to result in dismissal. 4 The Company's Group Fraud Policy defines Fraud as the deliberate action by any person, or deliberately allowing an action Lo be Laken, Lo create, falsify, deslroy, deface, or conceal any account, balance, record or document, or impersonate, deceive, or misuse their position with the intention of Obtaining money, assets, services, information or any other benefit which would otherwise be denied; DislorLing personal or business performance; Causing a loss to the Company or another party eg supplier, third party contractor, customer or employeey, Prejudicing Lhe Company's righls, cornpelilive posilion or business repulalion, or Lhose of anoLlher parly (as above} and/or e = Attempting or assisting in any of the above, You must follow Company procedures when dealing with the Company’s property, goods and cash. When dealing with financial transactions you must also follow Company policies, including Invoice Authorisation Controls, Procurement & Contract Policy for Non-Merchandise Spend and Lhe Group Investment Policy. When Lravelling and claiming expenses you must follow the Business Travel and Fxpenses Policy, Conflicts of Interest You should not put yourself in a position where you are involved in an activity for personal gain, to you or your family, which conflicts with the Company’s interests. Conflicts of interest can take many forms including, but not limited to: e = Engaging in any activity that competes with M&S; ¢ Taking personal advantage of an opportunity that belongs to M&S e Engaging in a business relationship on bchalf of M&S where you or a family member has an interest in the other parly, including a direcLorship or shareholding, unless previously advised Lo, and agreed by management Inside Information and Share Dealing Cornpariies listed on the | ondon Stock Fxchange are required to comply with the UKI 4's | isting Rules and Disclosure and lransparency Rules. Ihese Rules require ernployees to comply with the Company's Share Dealing Code if they have access through their roles. to unpublished, confidential and precise information relating to the Company's shares which could signilicanlly affecl Lhe share price inside information). LisLed companies are also required under Lhe Markel Abuse Regulation to maintain a list of employees who regularly come into contact with this inside information, directly or indirectly, in the course of their role. Colleagues who are covered by the Share Dealing Code will be notified and added to the Company's Restricted Dealing List. Whether you are covered by the Share Dealing Code or not, it is a criminal offence for anyone Lo deal in a cornpany’s shares il Lhey are in possession of unpublished price sensilive inforrnalion about Lhal Company. 2 Working Relationships Ihis section sets out the Company's key policies and procedures. Detailed policies and guidelines are contained in the People Policies section of the People Hub in M&S World. Your line manager will be able to give further guidance on any other specific policy or procedure relevant Lo your work area Customers M&S values the loyalty and confidence of cur customers above all else, Our values of Inspiration, Innovation, Integrity, and In louch underpin our customer promise of ‘Lnhancing Lives, Lveryday’. We will always try to make sure our labelling, advertising and other forms of communication are clear, honest and accurate and we will always work to respect cultural and ethical beliefs, We welcome customer feedback and try wherever possible to act on it to continually improve the service we offer. We make sure any complaints are managed fairly and prolessionally wilhin appropriate Limescales. Information Lhal we hold about our customers will be handled properly and responsibly. It is our responsibility to protect our customers’ persorial data. Colleagues AIL M&S collesques work hard with the common aim of ensuring our customers sre at the heart of everything we do. We are committed to an active Equal Opportunities Policy. from recruitment and selection, through training and development. appraisal and promotion, right up Lo retirement. We Lreal everyone equally regardless of age, gender, gender rea NnmMent, colour, ethnic or national origin, disability, hours of werk, nationality, religion or belief, marital or civil partner status, disfigurement, political opinions or sexual orientation. We treat all colleagues with dignity and respect and expect colleagues to treat each other and our customers in the same way. We all have 3 responsibility not to indirectly support unfair behaviour by ignoring what is happening sround us. It is Company policy to promote an environment free from discrimination, harassment, and victimisation where everyone will receive equal Lrealment. Please see more inforrnalion on our Bullying ancl Harassment Policy. ALL decisions relaling lo employment practices will be objective, free from bias, and based solely on work criteria and individual merit. In every set of circumstances we aim to find the ‘best fit’ between personal requirements and business needs. As a company, M&S is committed to providing clear, honest and accurate communication directly to colleagues. Through the Business Involvement Groups (BIG), the Company's network of elected employee representatives, the Company informs, involves and consults with colleagues as set out in the BIG constitution. You have the chance to voice your opinions and ideas, gel answers and have your views represented when Lhe business considers changes Lhal affect you. The BIG network enables all employees to have an opportunity to positively influence the business we work in We care aboul your wellbeing and work wilh UK rnanagers Lo provide Occupational Health support Lo employees. We also. have a 24-hour confidential employee ‘live Well Work Well’ helpline on 0703 783 8778, which employees can call to discuss. any personal issues. We will not compramise the health and safety of aur employees. We will offer ongoing training and development to enhance your career opportunities within the Company or elsewhere. Ihe Company recognises the importance of respecting your privacy and the need for apprapriste safeguards in relation to the collection, storage and processing of personal data. We expect that all information held about employees will be deall wilh properly and responsibly. IL is everyone's responsibilily lo handle information properly. You must never knowingly provide false information to the Company or about the Company to anyone clse. You must never use Lhe Cornpany’s narne or resources lor personal gain or insider knowledge Lo profit from buying or selling Cornpaniy shares. The work and ideas that are created whilst working for the Cormpany are owned by M&S More information on behaviours Lowards cusLomers and colleagues is given in Lhe Disciplinary Conduct & You Guidelines. The repercussions of failing to abide by company standards are set out in the Disciplinary Policy Shareholders M&S is owned by the individuals and organisations that invest in our shares. We sre focused on building 3 sustainable business for the long term, generating sharcholder value through consistent, profitable growth. We keep honest and accurale records of our perferrnance, and are comrniLled Lo high slandards of governance and Lransparenl reporting. As an integral part of planning and review we have an ongoing process in place for identifying, evaluating and managing the significant risks to achieving business goals. A detailed report on governance is set out for shareholders in our annual report which is available on the corporate website at corporate marksandspcncer.com/home. As a diverse retail business. it is not appropriate to have a single charity partner. At a corporate level we've built strategic partnerships wilh a nuriber of fundraising partners. SLores are able Lo select a Local Charily of Lhe Year Lo raise money for or support one of the Company's corporate partners. In addition, there is a small amount of budget allocated via the Store Cash Management System that enables stores to support local causes with donations of up to £50 throughout the year. For more information refer Lo Lhe ‘In Touch wilh your Comrnunily frarnework’, The Company does not support the following causes: Personal appeals on behalf of individual people, including overseas trips Advertising or goodwill messages Political parties Third party fundraising on behalf of a charity Religious bodies, except where the project provides non denominational, non sectarian support for the benefit of a projecl Supplying clothing, other than in exceptional circumstances as we already have corporate partners in place We encourage our employees to become involved in their local. communities. The Company offers employees one day's paid time off for volunteering to support a charity or local cause of their chaice. Lmployees wishing to take advantage of this must follow The Charity Volunteer Day Policy. In addition, if a team of five or more employees fundraise for a charity they can apply to have the funds matched. Employees can also support one of the corporate charity partners cach month with a direct donation through the Company's Payroll Giving scherne. 4 Company Property and Resources Information Governance Information Governance is our sysLem for handling and controlling inforrnation, including personal dala, confidential materials, and other important information, We are committed to goad Information Governance which involves compliance with all applicable legal and regulatory obligations, keeping deta secure and ensuring that we are able to access and use information for legitimate business purposes. Personal Data M&S is cornmilled Lo handling personal inferrnalion in line wilh dala proleclion laws. Wherever you work in Lhe business, as an M&S employee you have an important part to play in enabling us to meet this commitment Our Dala Proleclion Policy sels oul Lhe rules which all ernployees rnust follow when handling personal information. IL will help you ‘Do the Right Thing’ te protect yourself and our business, by protecting any personal information you handle. As an employee iL is your responsibility Lo ensure Lhal all personal inferrnation is handled in compliance wilh dala protection laws and the applicable M&S policies, This applies to all information, held on computer or in hard copy files, from which a person could be identifiable. Beware of people trying to obtain information to which they are not entitled Do not access personal data about pcople without appropriate authorisation, only use it for legitimate legal or business purposes and only hold the information as long as is necessary Lo carry oul Lhe business or legal Lask. Confidential Business Information Information about future marketing or promotional activity, eg brand launches, promotions, sales, or “discount days” should never be disclosed in advance of being announced. Our communications are scheduled to give customers time to plan a shopping trip, without compromising our sales before the promotion starts, or giving our competitors an opporlunily Lo damage our business. If inforrnalion gels ino Lhe wrong hands il could affect our cornpelilive advantage, cause financial loss, damage our reputation, or breach legal/regulatory requirements, Protect Company information by following the Information Security Procedures Use of Information Technology (‘IT’) The use of Lhe Company's IT facilities are subjecl Lo Lhe Cornpany’s IT policies and procedures which are aimed abl protecting IT equipment, systerns, networks and information including smart phones and other hand held devices. Using I] equipment inappropriately can result in the security of these systems being vulnerable. You will find detailed guidance on the use of IT equipment, email and the internet in the Computer User Agreement which is presented to you each time you log on Lo your cornpuler. Failure Lo follow and adhere Lo Lhis AgreernenL and other related policies including Lhe guidance for users of srnall mobile computing devices (smart phones and PDAs) may result in disciplinary action: up to and including dismissal Deliberate or serious bresches may lead to criminal prosecution. Reduce the risk of theft, particularly of portable equipment, damage and unauthorised access to computer systems by following Company procedures above and care aboul such equiprnent as Lhough iL was your own. Innovation and Intellectual Property As a lerm of your employment wilh M&S, Lhe Company owns any inventions, discoveries, improvernents, brands anc designs you make during the course of your employment and all related intellectual property rights, The Company will be entitled to the exclusive use of these rights, 3s far as the law permits and you will have no right to use thern for your own purposes unless otherwise agreed in writing. Copyright and similar rights in work created during your employment will also be owned by Lhe Company and you agree Lo waive any moral righls you may have. IL is also a Lerm of your ernployment that you do everything necessary, during or after your employment, fo enable the Company - at its request and expense - to obtain patents, design, copyright, trade mark and similar protection in any part of the world.