(including Whistleblowing)

Code of Responsible Business Conduct update

Date: 9 July 2013

19 April 2023 2

Code of Responsible Business Conduct (CoRBC)

• Updated April 2013 – Section 5b Gifts and Entertainment (G & E)– Clearer guidance on both giving and receiving G&E– For major sporting and other similar Corporate Events the presumption is

now no attendance• case to be made by exception with Director/Chief Officer and ratified by Conduct

Compliance Officer– Tighter line on Conflict of Interest– Charity events are still encouraged - in individual’s own time and expense –

so:• Meal and moderate ‘refreshment’ is acceptable (normally within the notional £50 UK

Bribery Act guideline)• Transport – acceptable if shared (e.g. minibus) and preferably with other organisations

too (not just SL personnel). Sole use transport not normally acceptable• Accommodation – not acceptable – individual personal expense

– Please don’t offer what we can’t accept– Speak with Conduct Compliance Officer to agree what is OK beforehand

Whistleblowing

• In CoRBC (Section 6)• Available to anyone working on SL’s behalf:

– SL, ASW, CSW, T2…Tn contractors and sub contractors– Various routes:

• Preference is via own organisation unless that is conflicted

• Can come to SC Ombudsman, CCO, or outside to (e.g. Regulators, Safecall)

• Certain specific matters - protected disclosure applies

• Anonymity – is allowed; prefer to have name in confidence

– Discussion aids proper understanding and investigation