We always strive to operate to the highest standards of corporate governance and we believe in strong business ethics, based around our Framework for Responsible Business, our Standards of Ethical Business Conduct and our core values.

In 2010, we amended and reissued ‘Doing the Right Thing – Our Standards of Ethical Business Conduct’. Doing the Right Thing provides a common set of practical guidelines to help ensure our behaviours are lawful, comply with our policies and licences, and follow the values set out in the Framework and our core values. We undertake face to face training of new starters and are making available online training for employees annually to ensure they understand the Standards.

We have taken steps to prepare for the implementation of the Bribery Act 2010 which comes into force in the UK in July 2011. This has included undertaking a risk assessment, review of Company policies (including Doing the Right Thing mentioned above) and an extensive training and awareness programme that will include eLearning for all employees.

In 2008, we published a position statement on responsible lobbying.

Our performance measure in this area is number of substantiated breaches of our Standard per 1000 employees.