Code of Responsible Business Conduct update

1. Code of Responsible Business Conduct update (including Whistleblowing) Date: 9 July 2013

2. Code of Responsible Business Conduct (CoRBC) • Updated April 2013 – Section 5b Gifts and Entertainment (G & E) • Clearer guidance on both giving and receiving G&E • For major sporting and other similar Corporate Events the presumption is now no attendance • case to be made by exception with Director/Chief Officer and ratified by Conduct Compliance Officer • Tighter line on Conflict of Interest • Charity events are still encouraged - in individual’s own time and expense – so: • Meal and moderate ‘refreshment’ is acceptable (normally within the notional £50 UK Bribery Act guideline) • Transport – acceptable if shared (e.g. minibus) and preferably with other organisations too (not just SL personnel). Sole use transport not normally acceptable • Accommodation – not acceptable – individual personal expense • Please don’t offer what we can’t accept • Speak with Conduct Compliance Officer to agree what is OK beforehand

3. Whistleblowing • In CoRBC (Section 6) • Available to anyone working on SL’s behalf: • SL, ASW, CSW, T2…Tn contractors and sub contractors • Various routes: • Preference is via own organisation unless that is conflicted • Can come to SC Ombudsman, CCO, or outside to (e.g. Regulators, Safecall) • Certain specific matters - protected disclosure applies • Anonymity – is allowed; prefer to have name in confidence • Discussion aids proper understanding and investigation