Code of Business Ethics
SECTION 1
This code applies to all of the operations of FirstGroup and its subsidiaries and sets out the minimum standards which the Board of FirstGroup expects from staff in their internal and external dealings with colleagues, customers, stakeholders and third parties.
1.1 Basic Standards of Conduct
(a) We will conduct every aspect of our business with honesty, integrity and openness, respecting human rights and the interests of our employees, customers and third parties.
(b)We will respect the legitimate interests of third parties with whom we have dealings in the course of our business.
(c) We will maintain the highest standards of integrity - for example, we will not promise more than we can reasonably deliver or make commitments we cannot or do not intend to keep.
1.2 Employees
Each FirstGroup company
(a) is committed to creating and maintaining a safe and healthy working environment for its employees.
(b) will strive to create a workplace in which there is mutual trust and respect and where every person feels responsible for the performance and reputation of our company.
(c) will respect the individual and each other's rights, customs and traditions including the right to freedom of association and the right to decide whether or not to join a trade union and will negotiate in good faith with the properly elected representatives of its employees.
(d) will work towards achieving a diverse workforce, recruiting, employing and promoting employees only on the basis of objective criteria and the qualifications and abilities needed for the job to be performed.
(e) will maintain good communications with employees through our information and consultation procedures.
(f) will assist employees in realising their potential.
1.3 Customers
(a) FirstGroup is committed to providing safe, value for money, high quality, consistent, accessible and reliable services to its customers.
1.4 Shareholders
(a) FirstGroup will conduct its operations in accordance with the principles of good corporate governance.
(b) We will provide timely, regular and reliable information on the business to all our shareholders.
1.5 Business Partners and Stakeholders
(a) We aim to develop strong relationships with our suppliers, stakeholders and others with whom we have dealings, based on mutual trust, understanding and respect.
(b) In those dealings, we expect our partners to adhere to business principles consistent with our own.
(c) FirstGroup companies will conduct their operations in accordance with the principles of fair competition and applicable regulations.
1.6 Compliance with Law
(a) All members of the Group will comply with the laws and regulations applicable wherever they do business. Appropriate training will be provided for employees as necessary.
1.7 Business Integrity
(a) No FirstGroup company shall offer, give, seek or receive, either directly or indirectly, inducements or other improper advantages for business or financial gain and no employee may offer, give, seek or receive any gift or payment which is, or could be construed as, such. If an employee is in any doubt as to whether he or she may accept an offer, that employee should discuss the issue with his or her manager, Group Legal Director or General Counsel.
(b) FirstGroup accounting and other records and supporting documents must accurately describe and reflect the nature of the underlying transactions.
(c) No undisclosed or unrecorded account, fund or asset will be established or maintained.
(d) FirstGroup will not facilitate, support, tolerate or condone any form of money laundering.
1.8 The Environment
(a) FirstGroup is committed to making continuous improvement in the management of its environmental impact.
(b) We will work with our partners to promote environmental care, increase understanding of environmental issues and disseminate good practice.
1.9 Community Involvement
(a) FirstGroup strives to be a good corporate citizen and to fulfil our responsibilities to the societies and communities in which we operate.
1.10 Conflicts of interest and confidentiality
(a) Whilst FirstGroup respects the privacy of its employees, all FirstGroup employees are expected to avoid personal activities and financial interests, which could conflict with their responsibilities to FirstGroup.
(b) FirstGroup employees and consultants must not seek gain for themselves or others through misuse of their positions or company property.
(c) All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) should be disclosed to and discussed with an employee's line manager.
(d) Information received by anyone in the course of his or her employment must not be used for personal gain or for any purpose other than that for which it was given.
(e) Where information is confidential, that confidentiality must be respected.