The
Collinson
Code
Conduct and Ethics 2020

Contents
A message from Christopher and David ........................ 4

4 We deal fairly with our people...............................................22

What is the Collinson Code?.............................................. 5

We are one team................................................................................23

What we aim to be............................................................... 7

We do the right thing.......................................................................23

Who is the Collinson Code for?......................................... 8

We prioritise health and safety.....................................................23

How do we use the Collinson Code?................................11

5 We strive for more.....................................................................25

1 We act with integrity..................................................................12

We have a higher sense of purpose............................................25

We comply with all relevant laws and regulations.................12

Our Purpose........................................................................................ 26

We proactively manage potential conflicts of interest........12

We stand up for what we believe in........................................... 26

2 We guard against financial crime.......................................... 14

6 We protect Collinson’s legitimate interests .......................27

We do not offer or accept bribes.................................................15

We don’t steal or misuse company assets...............................28

We exchange gifts and hospitality responsibly.......................15

We don’t disclose confidential information.............................28

We respect international trade sanctions..................................15

We maintain the integrity and security of our network .....28

We work to prevent and control fraudulent activity............ 16

We are responsible users of social media............................... 29

We guard against money laundering......................................... 16

We keep full and complete records........................................... 29

3 We deal fairly with our customers and suppliers...............18

Find out more....................................................................... 31

We promote fair competition........................................................ 19
We respect confidentiality, data protection
and information security................................................................. 19
We are building an ethical supply chain.................................. 20
We have clear standards on entering into contracts.......... 20
COLLINSON | The Collinson CodeCOLLINSON | The Collinson Code

A message from Christopher and David
Developed in line with our values and company policies, this Code of
Conduct details the expectations we should have of ourselves and eachother as representatives of Collinson.
The Collinson Code applies to each and every one of us, whatever ourrole, wherever we’re based. It will help us to identify and do the rightthing in a range of situations, using scenarios we might encounter in our
day to day work.
We are all personally responsible for complying with the Collinson Codeand you have the right to challenge any requests made of you which
you feel break the code. If you have any concerns about anyone at any
level within Collinson who you feel has breached the code, you will besupported in speaking up.
We’re incredibly proud of this organisation and of the work you doevery day to support our clients, our partners, our colleagues and ourcommunities. Adhering to the Collinson Code will help us protect ourhard-earned reputation and give us guidance on how to navigate any
uncharted waters we might encounter in the future.
The Collinson Code is how we do what we do, and at Collinson, we’re
proud to do the right thing.

Christopher Evans				David Evans
Joint CEO					Joint CEO

What is the
Collinson Code?
At Collinson, we know that the way we work is just as
important as what we do, which is why we’re committed
to operating in line with the Collinson Code.
The Collinson Code is our Code of Business Conduct andEthics. It’s a set of standards that detail how we go about
our work and the minimum expectations required of us
as we interact with our colleagues, clients, partners andstakeholders.
The Collinson Code helps us fulfil our legal and regulatory
obligations and comply with our internal policies,
but it goes further than just the letter of the law.
It helps us protect our reputation and makes sure
our actions are guided by our values to reflectwhat’s important to us.

OUR PURPOSE

What we aim to be
We aim to stand for more than just making money – we strive to be a business ourpeople are proud to work for, and a business our clients want to work with.

To be a commerciallysuccessful and trusted
organisation

To deliver true job
satisfaction and asense of belonging forour people

To make Collinson aplace of innovation,ideas and creativity

To enhance thecommunities andenvironments where
we operate

COLLINSON | The Collinson Code

Who is the Collinson Code for?
The Collinson Code applies to every employee, director, contractor and consultant in
the organisation, wherever we work and whatever job we do. We also encourage third
parties who work with us to demonstrate their commitment to this or a similar setof standards.
As an employee, director, contractor orconsultant, you are responsible for:In addition, managers and team leaders are
responsible for:• Reading, understanding and operating within
the Collinson Code• Helping others to understand and comply
with the Collinson Code• Regularly reviewing the Collinson Code andusing it to guide your conduct and decisions• Acting as a role model for compliance with
the Collinson Code and our values• Asking your line manager or our Governance,
Risk and Compliance (GRC) Team about any
areas you’re unsure about• Including the standards and the spirit of
the Collinson Code in objective setting andperformance evaluations, and taking action
when these are not met• Undertaking training on the Collinson Codeand its underlying policies• Speaking up if you’re aware of any issues,concerns, or breaches of the Collinson Code• Ensuring our partners, clients and third parties
are familiar with the code and working withthose who share our ethical standards• Working to embed and promote theCollinson Code in the working environment• Providing support to investigationsof any breaches of the Collinson CodeHow do we use the Collinson Code?
The Collinson Code is a guideline
to help you make decisions anddo the right thing. It includes
specific advice on some scenarios,
but there might still be times
when you’re not sure which isthe best ethical or legal choice tomake. If you’re ever unsure whatchoice to make to comply with the
Collinson Code, you should seek
guidance from your line manager
if possible. If they can’t help, or if
you don’t feel comfortable raising
the issue with them, you should
contact our People & Culture,
GRC or Legal teams for advice
before making your decision.
As we operate in many countries
around the world, we cannot
assume the Collinson Codealways reflects the latest legal
requirements or local ethicalstandards in all locations.
In countries which set higher

standards, we expect our people
to comply fully with local laws inaddition to the Collinson Codeand to engage with our Legaland GRC teams. In countries
where local requirements are lessstringent than our own standards,
our people are still expected to
uphold the Collinson Code.
We all have a duty to speak
up if we have concerns about
potential breaches of the
Collinson Code. If you believe
you know of a situation whichmight violate the Collinson Code,you should report it to your line
manager or to our Legal or GRC
teams. You can also report iteasily by contacting SpeakUp@
collinsongroup.com. Anyone
reporting genuine concerns will
receive our full support, although
if you prefer, you can choose to
make your report anonymously

by following the Whistleblowing
Policy. We will make every effort
to fully investigate any reported
breaches, although this can be
more difficult with the limited
information available throughanonymous reports.
Any reports of breaches of the
Collinson Code will be investigatedby either a relevant line manager
or our Legal or GRC teams
as appropriate. If a breach isfound, this may result in serious
consequences for the responsible
party, including suspension,
demotion, immediate terminationand criminal prosecution.

COLLINSON | The Collinson Code1
We act with integrity
We act with integrity at all times, complying with the laws
and regulations of every country we operate in as well as
recognised international standards.

What does this mean?
We comply with all relevant laws and regulations
We recognise that we’re subject to local laws and regulations in every
country where we’re registered, where we operate and where we provide
our services. We’ll comply with all relevant laws and regulations andembed them into our policies, procedures and governance arrangements.

We proactively manage potential conflicts of interest
We never use our position, our influence or company information, assets
or resources in a way that improperly benefits ourselves or others. We
identify, manage and record potential conflicts of interest to ensure they
don’t lead to biased or unfair decision making. All of our people areresponsible for knowing their obligations under the Conflicts of Interest
Policy and following proper procedures to manage any that might arise.
COLLINSON | The Collinson CodeAPPLYING THE COLLINSON CODE
in negotiations with the company where
sales have increased this month. I’m not
Q We’reQ Our
my sister works. I’m sure I could get us a better
sure the process is fully compliant, but it’sdeal – can I discuss the details with her?

the results that count, right?

this would be a conflict of interest. Even if
we must ensure our processes are fully
A No,
A No,
you don’t talk about the negotiations with yourcompliant with all relevant laws, regulations
sister, you should declare this potential conflictof interest to your line manager or to our GRC
Team, to avoid any doubts arising later about
our decision making process.

brother just started working in one of our
Q My
contact centres, is this a conflict of interest?
necessarily! We’re happy for your family
A Not
members to join you in working at Collinson,
however we must make sure that your roles
and responsibilities don’t conflict in waysthat could unfairly impact either of you, e.g.
if one of you was responsible for the other’ssalary or performance evaluation. Contact
your line manager for advice.

and policies, both for our clients’ protection
and our own. We actively monitor signsof potential non-compliant sales, andexpect our people to speak up if they haveconcerns. Strong performance will only becommended if it’s achieved in the right way,in line with the Collinson Code.

Find out more
• The Collinson Group conflicts of interest andrelated party transaction policy

COLLINSON | The Collinson Code

What does this mean?

2
We guard
againstfinancial crime
We act in accordance with all applicable
UK and international laws and regulations
regarding the giving and receiving ofgifts, dealings with governments andpublic officials, international trade
restrictions and the possible use ofbusiness activity to transact proceedsof criminal activity or fraud.

We do not offer or
accept bribes

We exchange gifts andhospitality responsibly

We respect international
trade sanctions

We comply with all local andinternational anti-bribery and anticorruption laws in the countries
where we operate.

We recognise that the giving
and receiving of hospitality is an
important part of building business
relationships in many countries
where we operate, and we work
to ensure these arrangements arecarried out with integrity.

As a global business, we operate
in a complex trading environment,
and will work to ensure we don’t dobusiness with any countries, people
or businesses which have trade
sanctions or controls imposed
against them.

All of our people, regardless of thecountry or culture where they’re
operating, must understand andfollow the procedures detailed
in the Gifts and Entertainment
Policy, including the reporting andrecording of gifts, and when theyshould be politely refused.

We undertake due diligencewhen working with new clients,
customers and suppliers which
includes screening for any global
sanctions, restricted jurisdictions
and trade control lists whichmight be in place, and we repeat
these as required to keep up withinternational developments.

Collinson strictly prohibits thegiving or receiving of cash, gifts orvaluable items in order to win or
retain business, influence decisions
or secure an advantage. Bribery
is illegal and unethical and giving
or accepting a bribe could result
in severe penalties for both thecompany and the individual involved.
All of our people are responsible
for knowing their obligations
under our Prevention of Financial
Crime Policy and following proper
procedures to report and record
any gifts they might receive.

Collinson strictly prohibits thegifting or receipt of any cash, orcash equivalents such as shares,
loans, gift cards or vouchers,
between our people and any third
parties with whom Collinson has acurrent or potential relationship.

COLLINSON | The Collinson Code

24

We work to prevent andcontrol fraudulent activity

We guard againstmoney laundering

Fraud is a serious crime with thepotential to affect our businessand our customers. We recognisethat fraud can include dishonesty,
deception, theft and concealmentof fact, and may also occur throughthe dishonest use of our products,
services and internal processes. We
proactively assess fraud risks within
our business, maintain anti-fraud
controls to discourage and prevent
fraudulent activity, monitor and test
our processes and conduct fraud
investigations where necessary.

We understand that any businesscan be unwittingly used to process
and conceal funds associated withillegal and terrorist activity. To avoid
being used in this way, we undertake
comprehensive due diligence on
the businesses we work with. We
don’t work with new organisations
until we’re satisfied we understandthe financial background andstability of the business andcan identify the directors andshareholders in control.

APPLYING THE COLLINSON CODE
and some of my team have been invitedreceived an invoice for payment, but
Q Myself
Q I’veto lunch by a client to celebrate our hard work
the director of the company who we owe
on a recent launch. Can we accept?

hospitality is a normal business practice
A Yes,
and using it to promote and embed working

relationships is acceptable. But if the invitation
came at the time of a tender or contract
renewal, or was to an event, location or occasionof significant financial value, then you would
need to discuss it with your manager. Refer to
our Gifts and Entertainment Policy to help you
decide how to respond to any invitations.

working in a new international market
Q We’reand have been told it’s normal practice here

to pay cash to government officials to process
paperwork. Is this acceptable?

It’s never acceptable to make any form of
A No.
payment to government officials. It’s also not

Find out more
• Prevention of Financial Crime• Gifts and Entertainment Policy

COLLINSON | The Collinson Codethe money to has given me the details of his
personal bank account instead. Should I accept
his instructions and pay him the money?

invoices must be paid to the company,
A No,
using the bank details agreed in the purchaseorder or contract.

colleague has claimed expenses for a dinner
Q My
she had with her friends, and says this is finesince she was travelling for work at the time. Is
this acceptable?

acceptable to claim a certain amount for her
A It’sown meal in line with our Travel Expenses Policy,
as this is considered ‘personal subsistence’,
which is an allowable expense, but she cannot
claim the cost of her friends’ meals.

acceptable to make payments to anyone tofacilitate any service or process. If you receive arequest like this, refer it to your line manager or
our GRC Team.

COLLINSON | The Collinson Code3
We deal fairly
with ourcustomers
and suppliers
We’re proud to work with our diverse
global network of customers, suppliers
and partners, and we give them ourword that we’ll operate in an ethicalmanner, uphold local legislation andwork to improve the communities
we’re a part of.

COLLINSON | The Collinson Code

What does this mean?

We promote faircompetition
We believe in our products andservices and compete firmly but
fairly by offering our clients thehighest standards we possibly can.
We do not engage in manipulativeor restrictive practices such as pricefixing, collusive tendering, market
sharing or the inappropriate useof information. We comply with all
relevant competition and antitrust
legislation and communicate
honestly with our clients. We
aim to offer the best choices on
the market through the use ofhigh quality partner and supplier
networks, and will ensure that
information and decision making is
as transparent as possible to allow
fair access to these networks.

We respect confidentiality,
data protection and information security
We recognise that our customers,clients and people must be able totrust us with sensitive information,
and we take our responsibility tosafeguard their privacy seriously.
Data is a fundamental element ofour business, and we are committed
to managing data accurately,
securely and transparently. Our
people undergo rigorous dataprotection training and receive
support and assistance from our
Data Protection Office (DPO).

We embrace a culture of privacy
by design and default, integrating
data protection and privacy into
everything we do. We comply withlocal regulations in every market
where we provide services andsafeguard personal data in allcontracts and agreements.
We never source information
through unethical channels.
If we receive confidential
information in error, we willsecurely destroy it and help toensure the breach is contained.

COLLINSON | The Collinson Code

We are building
an ethicalsupply chain

We embrace the role businesses
can play in addressing some of ourbiggest environmental and societal
concerns. We help businesses makeprogress in these areas by working
with suppliers whose values alignwith ours. Assessing potential
suppliers against the Collinson
Code and our Expectations for
Ethical Supply is a key step in both
our structured vetting process andour decision making.

We have clear
standards onentering into
contracts
We have a Governance Playbook
which contains details andprocedures that we expect all ofour people to follow when entering
into a business transaction on
behalf of Collinson, no matter
how big or small. Everyone mustensure they have the authority toenter into any agreements they
are proposing to make, and allcontracts must be in writing. Before
you enter into a new contract, oramend an existing one, make sure
you review the latest version of theGovernance Playbook.

APPLYING THE COLLINSON CODE

Find out more
• Governance Playbook• Golden Rules• Expectations for EthicalSupply• Data protection and
Governance• Information security and
Employee Privacy Policy

client accidentally sent me a document that
Q Aincludes
details of our competitor’s wholesale

has approached me saying they want
Q Someone
to make a subject access request. What does thisshould contact our Legal Team immediately
A You
for advice on how to respond before deleting theis a statutory process where an individual can
A Thisask to receive a copy of any data we hold on them.

You can also approach ourGRC, Legal or Procurement
teams for help and advice.

Q

I’ve received a confidential commercial proposal
from a supplier. Can I read it on my train journey?

A

Yes, as long as you take appropriate care to protect
the information, including making sure nobody cansee your device screen. You should avoid printing
the information and must never forward it to yourpersonal email account.

pricing. What should I do?

information. You must not share, save or forward
the information you received.

mean, and what should I do?

Contact the Data Protection Office for guidance.

want to send an email to a distribution list I’ve
Q Ifoundof customers from 10 years ago – can I use it?
to the Data Protection Office, as there are
A Speakcertain rules which govern whether we can or

can’t contact old customers, and whether we cankeep or must destroy their contact information.

of my suppliers won’t sign our Expectations
Q One
for Ethical Supply, can I still use them?
should talk to your supplier to find out the
A You
reasons why they don’t want to sign, and thencontact our Procurement Team for advice on how
to proceed.

COLLINSON | The Collinson CodeCOLLINSON | The Collinson Code

What does this mean?

4 We deal fairly with
our people
We know our people are the key to our success. We work hard tomaintain a safe, healthy and diverse working environment where
we demonstrate our shared values, every day.

We are one team

We do the right thing

We prioritise health and safety

Diversity and inclusion are at
the heart of who we are. We’recommitted to maintaining aworkplace that’s free fromdiscrimination against any age,gender, sexual orientation,transgender status, religion, race,
caste, disability or any other factor.
We’re proud to have thriving
employee-led networks throughout
our diverse global workforce. We
firmly believe that everyone has arole to play at Collinson, including
taking responsibility for respecting
the dignity of others.

We are committed to doing theright thing as one of our core values,
and want to make sure we do rightby our people. We value eachand every member of the global
Collinson team, and believe theyshould be treated in the right way,by the company and by each other.

We have the highest concern
for the health and safety of ourpeople and anyone connectedwith our activities. We work to
identify and eliminate hazards,
going over and above regulatory
requirements in many of our
locations in our efforts to provide asafe working environment. We takeresponsibility and expect everyone
to show leadership in creating andmaintaining a safe workplace. We
also support our people with adetailed Substance Abuse Policy
designed to maintain a drugfree environment.

We are committed to providing
equal opportunities, work life
balance and an open culture whereconcerns can be freely shared.

Abusive, harassing, racist, sexist
and any other offensive conduct,
including the use or distribution of
offensive material, is not tolerated
at Collinson, and we will make every
effort to confidentially investigate
and resolve any concerns.

Find out more
• Health and Safety• Equal Opportunities• Dignity at Work and Harassment• Alcohol and Substance Abuse Policy

COLLINSON | The Collinson CodeAPPLYING THE COLLINSON CODE
hiring for a new member of my team
Q I’m
and need to decide between an equally wellqualified man and woman. I don’t want tohave to hire maternity cover if the woman
gets the job and then takes time out to have afamily, can I choose the man on this basis?

this would be gender discrimination,
A No,
which is both illegal and unethical. If you’retrying to decide between two well qualified
candidates, you can use further interviews,
reference checks and second opinions to help
you choose, and you can also ask our People
and Culture Team for more advice. Hiring
decisions should be based on job related skills
and performance, rather than assumptions
about gender roles. At Collinson, we support all
families, irrespective of gender, and encourage
gender diversity in the workplace.

enjoy the work I do, but my line manager
Q Isometimes
says demeaning things about
my age, since I’m younger than most of
my team. Can I apply for a transfer toanother department?

shouldn’t have to move departments in
A You
order to be free of discrimination. If someone

else’s behaviour is making you uncomfortable,
we’ll support you in whatever way we can.
If you don’t feel like you can speak to yourteam leader about this, you can approach ourPeople & Culture Team for help and advice.

5
We strive for more
We believe that we don’t have to choose between
making meaningful change and running a
successful business.

What does this mean?
We have a higher sense of purpose
Many of the world’s best performing companies prove thatit’s possible to achieve success while also making a positive
difference in the world. At Collinson, we want to be more thanjust a profitable company or market leader. We measure our
success by the impact we have on those around us. Our purpose
is a small statement supporting a huge belief that we stand formore than just making money.

Find out more
• Corporate Responsibility Strategy• Expectations for Ethical Supply

COLLINSON | The Collinson CodeCOLLINSON | The Collinson Code

Our Purpose:

We stand up for what we believe in

To be a business our clients are proud to work withand our people are proud to work for:We make sure our actions and decisions are guided byour values, and always push ourselves and our wider
networks to treat people fairly and operate in a socially,
environmentally and economically sustainable way.

• To be a commercially successful and trusted
organisation• To make Collinson a place for innovation, ideas andcreativity

We know the passion and dedication of our teamcan make a real difference to causes we care about.
We’ve identified four areas of focus in our Corporate
Responsibility strategy and support our people as they
dedicate their time and effort to:• To use a share of our profits, assets and people toenhance the communities and environment where
we operate• Improving the lives of underprivileged and at-risk
young people• To deliver true job satisfaction and a sense of
belonging for our people

APPLYING THE COLLINSON CODE
helping a local charity with their Christmas
Q I’m
fundraising event, can I use this as myvolunteering day?

A

Yes, as long as you have permission from yourline manager. Feel free to share the details of
the event on Workplace!

COLLINSON | The Collinson Code• Changing the conversation on mental healththrough raising funds and awareness• Strengthening communities to make the change
they want to see in the world• Making decisions which support long term
environmental sustainability

6 We protect Collinson’s
legitimate interests
We conduct ourselves responsibly, and don’t take advantage ofthe trust that’s placed in us.

What does this mean?
We don’t steal or misusecompany assets

We don’t disclose
confidential information

We maintain the integrity
and security of our network

We are responsible users ofsocial media

We keep full andcomplete records

We’re all expected to be
responsible in our use ofcompany assets, whether they’retangible assets such as products,
equipment and facilities orintangible assets like intellectual
property, trade secrets andconfidential information. We don’t
use company assets for personaluse, or make them available foranyone else’s personal use.

We never share confidential or
proprietary information about
Collinson, our suppliers, customers,
or other stakeholders with anyone
outside the company, even after weleave the organisation, without priorconsent or legal obligation. If weknow this type of information, we
never use it for our own benefit or
the benefit of those connected to us.

We abide by our Information
Security Policy and do not sharepasswords or access to any
Collinson computer or database,nor do we use Collinson systems or
equipment to commit illegal actsor to violate Collinson policies andprocedures, including the Collinson
Code. We do not share or
distribute unauthorised software
and we seek urgent advice from
our Cyber Security Team if we feelour devices or networks may havebeen compromised.

We expect all those associated with
Collinson to use good judgement
when discussing the company, ourbrands and the industries in which
we operate. Everyone is expected
to ensure that their statements andopinions are clear and leave no room
for misinterpretation, do not bring
Collinson into disrepute and do not
violate any part of the Collinson
Code or associated policies.

We will always fully and fairly
disclose the financial condition of
the business, accurately recording
and reporting accounting and otherrequired information and using thisinformation to make sound businessdecisions. We are all responsible
for ensuring that our accounting
records do not contain any false orintentionally misleading entries andno attempt to present misleading
information will be tolerated.

We accept that the intellectual
property of Collinson products andservices belongs to Collinson, not to
any individuals, whatever their role
may be, and we don’t dispose ofor destroy information or physicalassets without prior consent.

COLLINSON | The Collinson Code

Find out more
• Information Security• Acceptable Use• Social Media• Expenses Policy

All of our people should
ensure they keep accurate anddocumented records in supportof claims for expenses, including
overtime payments, travel andmeals and sales activity.

COLLINSONCOLLINSON| The| CodeCollinsonof Conduct
CodeFind out more
If you have any questions about how the Collinson Code applies to your role, contact your line
manager in the first instance.

APPLYING THE COLLINSON CODE
learned that a
Q I’vesupplier of ours is about

to announce huge newinvestment that will
significantly increase
their share price. Can I tellmy friends and family toinvest before the publicannouncement, to help
them make some moneyfrom the stock market?

this would be an
A No,
inappropriate use ofconfidential information,
which you are not permitted
to share with those outsideof the company.

COLLINSON | The Collinson Codeclaimed expenses for
Q I’vea train ticket I bought to

go to a conference, but I’ll
now be getting a lift froma colleague. Can I keep themoney I received?

this would be a
A No,
fraudulent expense claim.

You should cancel the ticket
to receive a refund, andreimburse the expenses
you claimed. Your colleague
may be able to claim
expenses for the mileage
involved in driving you bothto the conference.

noticed a colleague’s
Q I’vesocial media page as it’s

linked to Collinson. They’reusing offensive language
and, in some cases,
discussing client issues. Is
this acceptable?

We expect our people
A No.
to behave respectfully andresponsibly, and to treat
customer relationships
confidentially. You shouldraise your concerns withyour line manager
or our People andCulture Team.

To raise concerns about possible breaches of the Collinson Code, you can contact your line
manager, the relevant team below, or email SpeakUp@Collinsongroup.com.
If you have questions about specific parts of the Collinson Code, contact the most appropriate
team:

People & Culture

Procurement

PeopleandCulture@collinsongroup.com

Procurement@Collinsongroup.com

For enquiries on People and Conduct issues.

For enquiries on ourcing and working
with suppliers.

Governance, Risk and Compliance (GRC)
Risk@collinsongroup.com

Data Protection Office (DPO)

For enquiries on Risk Management
and Regulatory issues.

Data.Protection@Collinsongroup.com
For enquiries on data protection issues.

Legal

Corporate Responsibility

Legal@collinsongroup.com

csr@collinsongroup.com

For enquiries on Legal andContract issues.

For enquiries on corporate responsibility,
including environmental andsustainability issues.

COLLINSON | The Collinson Codecollinsongroup.com

COLLINSON | The Collinson Code