Code of Conduct

3. Key Requirements

Colleagues are expected to uphold the following principles and behaviours when carrying out their duties on behalf of the Bank or representing the Bank in any way.

3.1 Key Principles

All Colleagues are expected at all times, when acting in a work related context or otherwise representing the Bank, to act in accordance with the following overarching principles.

Act with integrity

This is as simple as doing the right thing for the right motives and with a professional duty of care. Acting with integrity generates trust and respect from those with whom we deal. Misleading or attempting to mislead others is an obvious example of behaviours demonstrating a lack of integrity. Failing to act when action is needed can also contravene this principle.

Act with due skill, care and diligence

Colleagues must have the necessary skills, experience and capability to perform their role with due skill, care and diligence. Colleagues, in conjunction with their line management, are responsible for identifying any gaps in competence and addressing them within agreed timescales. Where gaps are identified, alternative arrangements for the completion of tasks should be implemented until such time as they can fully meet the requirements. Managers have an important role to play in ensuring that tasks are only delegated to Colleagues that are fully able to perform them. Colleagues should ensure they are properly qualified and able to undertake the work that they do and, if they have any concerns, speak to their line manager.

Be open and co-operative with the FCA and other regulators

As our business model develops, we will be increasingly in scope of regulatory scrutiny from the FCA and potentially other regulators. As with all our professional dealings with external stakeholders and our shareholder, we must be open and co-operative with them. Colleagues engaging with regulators should, unless they have been explicitly instructed otherwise by the regulator, speak with Risk and Compliance in advance of their engagement to ensure that accurate records of the engagement be maintained. 

Pay due regard to the interests of customers and treat them fairly

The Bank is required to consider the interests of multiple different stakeholders, many of whom might be considered customers in the widest sense of the word. Colleagues should consider who our customers are, what, if any, obligations our relationships with them create, and pay due regard to each of their interests. 

Observe proper standards of market conduct

‘Market’ here should be considered more broadly than financial markets such as the London Stock Exchange (as an example) and include activity related to the private purchase or sale of financial instruments or financial markets more generally. We may for example be in possession of confidential company information which may impact on valuation or government intentions toward financial markets policy. This Code expects Colleagues to treat such information appropriately.

Act to deliver good outcomes for our customers

We must not assume SMEs and individual retail customers have any significant financial knowledge.

3.2 Behaviours Expected of Colleagues

By demonstrating certain attributes and behaviours we can better deliver the key principles. These should be considered minimum standards that we each aspire to exceed rather than merely meet.

All Colleagues are also expected to:

Be honest 

Always act honestly in all their actions. This is perhaps most critical when things go wrong. Honest mistakes will happen – how we deal with them can define us. The Bank expects Colleagues to identify and admit mistakes promptly as they occur and work with others (not alone) to rectify them and put in place agreed processes that can mitigate the risk of them happening again.

Be respectful

Colleagues must treat partners, suppliers, stakeholders, other relevant third parties and other Colleagues with dignity and respect at all times. Colleagues must not engage in behaviour that is inappropriate or unacceptable in a professional working environment. This includes, but is not limited to:

• Bullying, harassment or sexual harassment
• Discrimination or harassment of any individual
• Intimidation, abusive or threatening behaviour
• Violence or aggressive conduct
• Conduct that creates a hostile, degrading or offensive working environment

Such behaviours fall below the standards expected by the Bank, are inconsistent with its values and expected standards of conduct, and will be treated seriously. Behaviour of this nature is referred to as non financial misconduct. Any such conduct may result in internal disciplinary action.

The Bank’s Diversity, Equity and Inclusion and Prevention of Bullying, Harassment and Sexual Harassment policies provide further details on these expectations.

The Bank recognises that open, honest and constructive discussion is an essential part of effective working relationships. This includes providing challenge, giving feedback, and engaging in robust but respectful debate.

Such interactions, where conducted in a professional, respectful and proportionate manner, do not constitute non financial misconduct.

Be impartial

Not allow the way in which they meet their obligations to the Bank to be affected by changes of government or political persuasion but will approach each issue purely on its individual merits. Colleagues should also be wholly impartial in their dealings with other Colleagues and stakeholders avoiding any appearance of bias or favouritism. As a government-owned institution, colleagues must be mindful of the need to maintain political impartiality and avoid conflicts of interest. Any intention to stand for elected office, undertake political activity, or engage in public political roles must be declared in advance and approved through the external appointments and conflicts of interest processes. Each case will be assessed on its individual merits, taking into account factors including: 

• The nature and seniority of the colleague’s role at the Bank
• Any actual or perceived conflicts of interests
• The potential impact on the Bank’s reputation and public confidence

The visibility and nature of the proposed political activity. In certain circumstances, particularly for senior roles or where conflicts cannot be appropriately managed, approval may not be granted.

Be objective

Decisions that Colleagues are involved in and recommendations that Colleagues make must be based on a rigorous analysis of the facts and implications of the available evidence.

Manage corporate conflicts of interest

Manage conflicts of interest between the Bank and its partners, suppliers, customers, stakeholders and other relevant third parties in accordance with the Conflicts of Interest Policy and any other relevant Bank policy and procedures.

Manage personal conflicts of interest

Manage personal conflicts, notably relating to personal dealings in securities, outside interests, gifts and offers of hospitality and act in accordance with the Conflicts of Interest, Gifts and Hospitality and Market Abuse and Insider Dealing policies.

Avoid misuse of the Bank’s assets and resources

Take all reasonable measures to prevent the misuse of the Bank’s assets and resources for any other person’s benefit, whether knowingly or through negligence.

Behave professionally and responsibly

Exercise discretion when speaking outside the Bank on any subject relating to the Bank, unless authorised to do otherwise.

Comply with the law, regulations and professional standards

Comply with the laws, regulations and professional standards that apply to their professional activities at all times, and in particular they must ensure that they meet any personal obligations imposed by law e.g. in relation to money laundering, including undertaking any training directed by the Bank.

3.3 Policies and Procedures

The Bank has a range of policies and procedures which set out the control objectives, principles and other core requirements for the activities of the Bank. The policies describe in more detail the rules everyone at the Bank is expected to follow. The Policies do not form part of the contract of employment of any Employee, but it is the responsibility of all Colleagues to be aware of the Policies that are relevant to their role. All policies can be found on the Bank’s Intranet.

3.4 Raising a Concern

The Bank is committed to maintaining a culture of openness and transparency. Actions contrary to the Code and instances where our values and principles are not being applied may damage the reputation of the Bank. If any Colleague witnesses or has concerns such activity is taking place, the Colleague should speak with their line management or a member of the HR team. The Speak Up Policy or Grievance Policy or Prevention of Bullying, Harassment and Sexual Harassment Policy also provide further guidance. The Bank expects Colleagues to raise concerns over any breaches (or potential breaches) of this Policy and to co-operate with any investigation that may result.

If anyone witnesses or has concerns such activity is taking place, they should consult the Speak Up Policy. Individuals employed by external organisations should speak with their own employer in relation to any concerns that relate to them personally.

From time to time Colleagues may need to seek guidance on whether a past, current or proposed course of action meets the required standards. A Colleague’s initial discussion will ideally be with their line manager, who will either help the Colleague to resolve the issue or escalate it further for guidance and resolution.

Where an individual considers anything in this policy may conflict with another duty (for example those relating to membership of a professional body) they should discuss this with their line manager or, if their line manager is involved in the conflict, a member of HR or Compliance.