It describes the Group's core standards, and must be adopted by all companies as a minimum standard.

It is published on our global intranet and incorporated into employment contracts wherever applicable.

This policy is also a living document. It is reviewed regularly, to ensure it continues to reflect our business model and areas of operation, and issued to all senior managers and executives.

Adherence to the policy is monitored regularly and reviewed annually as a part of our compliance processes. Senior managers are asked to reaffirm their personal commitment to it every year.