Standards of Conduct Policy

3. Key Requirements

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

3.1 Key Principles

Living Our Values

BBB values are a foundation for everything we are and stand for as a business and positively shape our corporate culture as we grow. Our core values are:

We are committed

We are passionate about fulfilling our mission to make finance markets work better for UK businesses, whilst delivering commercial and socially responsible outcomes.

We are collaborative

We support, respect and encourage each other as colleagues and work in true partnership with our stakeholders.

We are creative

We question the status quo, challenge ourselves, and strive to find new ways to deliver in an ever-changing world.

3.2 Behaviours Expected of Colleagues

Colleagues must, at all times, act in accordance with the following overarching principles:

• Integrity - this is as simple as always doing the right thing for the right motives and subjugating personal interests with a professional duty of care. Acting with integrity generates trust and respect from those we deal with, benefiting Colleagues and BBB. You should not allow personal or BBB interests to compromise your commitment to acting in the public interest.
• Act fairly, honestly and transparently - Colleagues must always act in a fair, transparent and honest manner in all their professional actions and any private actions which may affect BBB’s conduct or reputation.
• Respect others - Colleagues must not discriminate against or harass partners, suppliers, stakeholders, other relevant third parties or other Colleagues or any other person with whom BBB has dealings for any reason whatsoever, notably with regards to age, gender reassignment, marital or civil partnership status, pregnancy or maternity, disability, race, colour, nationality, ethnic or national origin, religion or belief, sex, or sexual orientation, in line with the Diversity, Equity and Inclusion Policy. Colleagues must treat fellow colleagues with respect and behave in a collective, collaborative, co-operative and non-bullying manner in accordance with BBB’s Anti-Harassment and Bullying Policy.
• Impartiality - Colleagues must not allow the way in which they meet their obligations to BBB to be affected by changes of government or political persuasion but will approach each issue purely on its individual merits. There are constraints, dependent on a Colleague’s seniority, relating to a Colleague’s ability to become active in European, national, regional or local politics as a representative of BBB, as this could be perceived to compromise the Colleague’s impartiality. This can include constraints on candidacy for election, on canvassing, and on public speaking on politically controversial issues. Further specific guidance is issued by Cabinet Office when elections are imminent, and Colleagues will be obliged to read and comply with them. General guidance can be obtained from HR at any time. Colleagues must also be wholly impartial in their dealings with other Personnel and avoid any appearance of bias or showing favouritism.
• Objectivity - all decisions that Colleagues are involved in and any recommendations that Colleagues make must be based on a rigorous analysis of the facts and implications of the available evidence. Where the facts available are insufficient to complete an objective analysis, Colleagues must seek further advice/analysis from their Line Manager and/or HR before acting.
• Comply with the law, regulations and professional standards - Colleagues must comply with the laws, regulations and professional standards that apply to their professional activities at all times. 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 BBB.
• Manage conflicts of interest - Colleagues must manage conflicts of interest between BBB and its partners, suppliers, stakeholders and other relevant third parties or the Employees of these groups in conformity with the Conflicts of Interest Policy and any other relevant BBB policy and procedures.
• Colleagues must manage conflicts of interest involving them personally - notably relating to personal dealings in securities, outside commercial interests, gifts and offers of hospitality in accordance with the Conflicts of Interest Policy and Gifts and Hospitality Standards and Market Abuse Regime (‘MAR’) policy.
• Protect BBB’s interests - Colleagues must make the best possible use of BBB’s assets and resources and take all possible measures to prevent the misuse of these assets and resources for any other person’s benefit, whether knowingly or through negligence.
• Behave professionally and responsibly - Colleagues must respect professional confidentiality; act with loyalty toward BBB, i.e. avoid acting contrary to its interests unless such action can be considered as legitimate and necessary; exercise discretion and reserve when speaking outside BBB on any subject relating to BBB, unless authorised to do otherwise; contribute to implementing BBB best practices, particularly in the areas of risk management, prevention of financial crime, and internal control.

3.3 Policies and Procedures

BBB has a range of policies and procedures which set out the control objectives, principles and other core requirements for the activities of BBB. The policies describe in more detail the rules everyone at BBB is expected to follow. The Policies do not form part of the contract of employment of any Employee however, 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 BBB Intranet.

3.4 Raising a Concern

BBB is committed to maintaining a culture of openness and transparency. Actions contrary to the Standards of Conduct and instances where our values and principles are not being applied may damage the reputation of BBB. If any Employee witnesses or has concerns such activity is taking place, the Employee should consult the Speak Up Policy or Grievance Policy & Procedure or Anti-Harassment & Bullying Policy for further guidance. BBB 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 any Personnel witnesses or has concerns such activity is taking place, the individual should consult the Speak Up Policy. Personnel supplied to BBB by external organisations should speak with their own employer in relation to any concerns that relate to them personally.