How we work, what we value

How we work, what we value Our Code of Business Ethics Partnership I Innovation I Community I Responsibility 2 CO N TENTS PAG E SE CT ION 04 IN...
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How we work, what we value Our Code of Business Ethics Partnership I Innovation I Community I Responsibility

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CO N TENTS

PAG E

SE CT ION

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INTRODUCTION

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A message from Sean

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About us

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Our culture

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ABOUT OUR CODE OF BUSINESS ETHICS

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Using this Code

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What this means for me

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IMPLEMENTING & MONITORING OUR CODE

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Guidance and questions about the Code

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Zero tolerance

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How to raise a concern

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Non-retaliation

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What does this mean for me?

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OUR PEOPLE

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Health, safety, welfare, environmental & quality management

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Inclusion, equality & diversity

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Discrimination, harassment, bullying & victimisation

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Unlocking potential

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Our relationship with our supply chain partners & third parties

CONTENTS

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OUR BUSINESS INTEGRITY

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Fraud, deception and dishonesty

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Bribery and corruption

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Gifts and hospitality

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Free and fair competition

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Conflict of interests

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OUR BUSINESS ASSETS

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Privacy laws, confidential information / information security

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External communications and social media

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Group property and resources

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Financial controls, records and reporting

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COMMUNITIES & SOCIETY

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Communities

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Environment

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Sustainability

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Human Rights

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Grants

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Political and public policy activities

Wentworth College, University of York, where UPP provides a home to more than 1,000 students.

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I N TR O DUCTION

I want everyone who works for UPP to be proud of our business and of our achievements for partners and the communities in which we are a part.

I NTRODUCTION

A message from Sean Dear Colleague, At UPP, we are committed to doing the right thing for our university partners, colleagues, shareholders, supply chain partners, the environment and our local communities. In an increasingly competitive marketplace, it is important that each of us understands the rules that we must follow and the conduct that is expected of us in order to do a great job and help UPP play a valuable role in society. Our Code of Business Ethics is designed to help protect us as we go about our work for UPP. It provides a framework which draws together the policies and procedures that guide our conduct with our values and behavioural framework. Wherever we work and whatever our role, the Code is there to help keep us safe and protect the reputation of our business among all our stakeholders. If you ever have concerns about your own conduct or that of another person, you must speak up straight away and talk to someone, which could be your line manager, members of Compliance or Human Resources or your local senior management team. We want to hear about it. It is essential that we create a supportive environment in which you feel able to raise concerns internally, which in turn will help protect and enhance the reputation of UPP. I want everyone who works for UPP to be proud of our business and of our achievements for partners and the communities in which we are a part. Knowing our policies, applying good judgement, being honest and speaking up are just some of the ways that we can build pride in UPP and help build a stronger business for the future.

Sean O’Shea

Group Chief Executive Officer July 2016

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I N TR O DUCTION

About us Our vision To deliver the very best student experiences, in partnership with great universities. Our mission To create exceptional academic infrastructure and support services in partnership. Our values Our business is built on strong values and together with our Code of Business Ethics, they inform the way we work and demonstrate what we stand for and where we want to be.

Partnership

Innovation

We create unique, long term partnerships which build value for our partners and support them in realising their vision.

Constantly improving our products and services is embedded in all we do.

Community

Responsibility

We create unique, long term partnerships which build value for our partners and support them in realising their vision.

We create unique, long term partnerships which build value for our partners and support them in realising their vision.

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I N TRODUCTION

Our culture The culture supporting our Code is articulated in our behavioural framework, Above and Beyond. This framework translates our values into what these mean to you in your day to day working life and helps articulate UPP’s culture.

Further information on Above and Beyond can be found on Campus, your intranet or else speak to your line manager or any member of the Learning & Development team if you have any questions.

By living and breathing Above and Beyond we will embody our values and achieve our vision and mission. We believe that it is not the job we do but how we do it that makes a difference and this involves doing the right thing, even when nobody is watching.

Above and Beyond

Julie Nguyen Company Secretarial Assistant

Our values help us to articulate and understand the way we support universities, their students, our employees and the communities in which we work.

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A B O UT OUR CODE OF BUSINESS ETHICS

About our Code of Business Ethics The principles outlined in our Code are designed to help guide how we do business. This Code:

Sets out our responsibilities towards our stakeholders

Applies to everyone working for and with UPP: colleagues, university partners, supply chain partners and agents

Provides guidance to help resolve dilemmas about business conducts

Identifies how we are expected to act in relation to our values, laws and regulations that control our operations

A BOUT OUR CODE OF BUSINESS ETHI C S

Using this Code

What this means for me

• Each section of this Code is underpinned by our policies and working procedures which can be found on our intranet, Campus

We expect you to:

• This Code cannot address or anticipate all the ethical dilemmas we might encounter as part of our business. It is intended to guide us in how we act with integrity, good conscience and judgement based on our values at all times

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• Behave in an ethical manner, apply good judgement and take pride in your actions • Comply with the principles outlined in this Code and fulfil your legal and regulatory obligations • Understand our values and apply them to your work • Speak up if you feel a working practice is not ethical or safe or if it breaches this Code • Refer to our policies and procedures which underpin the Code

Nina Thorpe Cleaner, UPP at Nottingham Trent University

We work really hard to create a happy environment for all our students, so they can feel at home. It’s wonderful getting to know each one and really rewarding to see them enjoying their surroundings.

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I M P LE MENTING AND MONITORING OUR CO DE

Implementing and monitoring our Code If you are a line manager, you have an important role in ensuring this Code and the values that underpin it are understood and applied by your team. In particular, we expect you to: • Be a role model, leading yourself and others by example • Creating an inclusive culture where people feel their effort and contribution is valued • Demonstrating and role modelling best practice • Supporting and inspiring others to do a great job • Ensure your team members are familiar with our Code and that they understand it • Hold your team members accountable for complying with it • Ensure that your team members receive relevant training delivered through regular training sessions, workshops and as part of the induction process for our new colleagues The Group Director, Compliance is responsible for dealing with breaches of this Code and will ensure that appropriate disciplinary action is taken where required.

We will monitor compliance with this Code on an ongoing basis and produce regular reports in respect of both our financial and non-financial affairs. Our auditors may be asked to report on any practice they discover in the course of their work which appears to breach this Code.

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I MPLEMENTING AND MONITORING OUR CODE

Guidance and questions about the Code The Code cannot cover every situation. If you are ever unsure about what to do, you should ask yourself:

Does it feel right? Am I being fair & honest?

Is it legal?

Will my action stand the test of time? Could I justify it to my family?

How would it look on the front page of the newspaper?

How will I feel about it afterwards?

If you answer ‘no’ or ‘I’m not sure’ to any of these questions then you should seek support. You should speak to your line manager or another colleague you trust, as they may be able to give you the guidance and advice you need. You can also ask the Compliance team.

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I M P LE MENTING AND MONITORING OUR CO DE

Zero tolerance As you would expect there are some aspects of our business where we have one approach. This includes a zero tolerance stance on: • Criminal activity • Miscarriages of justice • Danger to health and safety • Damage to the environment

• Bribery, financial fraud or mismanagement • Negligence • Breach of our internal policies and procedures • Conduct likely to damage our reputation • Unauthorised disclosure of confidential information • The deliberate concealment of any of the above matters

• Failure to comply with any legal or professional obligation or regulatory requirements

Lancaster University’s award winning Eco Residences, home to nearly 4,400 students during term time.

I MPLEMENTING AND MONITORING OUR CODE

How to raise a concern

Non-retaliation

We all have a responsibility for implementing the content and spirit of the Code, as well as for speaking up if we suspect it has been or could be breached. If you see behaviour at work which you feel may be a breach of our Code, or seems illegal or unethical, please report it.

We take a non-retaliation approach to whistleblowing when a genuine concern has been reported. No action will be taken against you if you report such concerns, even if proven to not result in a compliance breach. We will also not criticise you for failure to speak up on earlier occasions.

You must report any behavior which you suspect to be unlawful or criminal. This could be bribery, fraud or a breach of data privacy. You must also report abuse of our systems, processes or policies. This could be bullying or harassment, potential conflict of interests, danger to the health and safety of colleagues or the public, potential abuses of human rights or serious environmental issues.

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O UR P EOPLE

What does this mean for me?

THERE ARE THREE WAYS TO SPEAK UP

For colleagues – Report it internally to your line manager or refer to the Whistleblowing Policy. We know it is not always easy to raise your concerns. To make it easier, we have an open communications policy so we encourage you to discuss any issues or potential issues that concern you with your line manager.

Report it confidentially to our whistleblowing hotline on 0800 1116 390. This service is available to all colleagues and all our external stakeholders including our university partners, supply chain partners and agents. We appreciate that you may want to report your concern to someone who is further removed from the situation as there may be occasions when reporting a concern internally is not appropriate or does not feel like the right approach.

Our external stakeholders including our university partners, supply chain partners and agents can also report concerns. Contact our Group Director, Compliance by emailing: [email protected]

Your relationship with the Group will not be affected by an honest report of actual or potential infringement of our Code Your concerns will be taken seriously and investigated quickly. If you wish, your anonymity will be protected, we will keep what you tell us private, subject to our legal obligations, and ensure you are updated throughout the investigation process.

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O U R PEOPLE

Our people Health, safety, welfare, environmental and quality management We are committed to the continuous improvement of our health, safety, welfare environmental and quality management systems. We have established policies and procedures in place for all colleagues, visitors, residents and others who may be indirectly or directly affected by our business. We also provide training, instruction and supervisions to underpin our approach. We all have a requirement to assist with the prevention and investigation of accidents, ill-health, negative environmental impacts (including pollution prevention) and quality risks along with the maintenance of safe and healthy working conditions.

TO ACHIEVE THIS EACH INDIVIDUAL SHALL

Take care of their own health, safety and welfare and that of any person who could be affected by their acts or omissions.

Bring to our attention any unsafe acts or conditions that they witness, experience or are made aware of.

Our fully certified systems – ISO9001, ISO14001 and BS OHSAS 18001 – have the active commitment and accountability of all management and colleagues.

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O UR P EOPLE

Inclusion, equality and diversity At UPP we see the differences between people as strengths. We value the rich diversity and creative potential that people with different backgrounds, skills and abilities bring to the workplace.

We want to ensure that those who come into contact with UPP are treated equally and with fairness and consistency at all times.

We will not tolerate discrimination in our workplace and are committed to providing opportunities in recruitment, remuneration, training and promotion of colleagues, as well as to eliminate direct or indirect discrimination in the workplace on the grounds of any protected characteristics. These are: • age • disability • gender re-assignment • marriage and civil partnership • pregnancy and maternity • race • religion or belief • sex and sexual orientation. We are committed to eliminating discrimination amongst our workforce and comply with the Equality Act. We evidence this by providing support, training and advice throughout UPP.

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O U R PEOPLE

Neil Barron Maintenance Supervisor, UPP at Griffon Studios, Imperial College London

UPP offers a great range of training and development. I always feel my skills set and career development is well supported.

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O UR P EOPLE

Discrimination, harassment, bullying and victimisation We treat any acts of discrimination, harassment, bullying or victimisation against other colleagues, university partners or supply chain partners as disciplinary offences and these are dealt with under our disciplinary procedure.

Discrimination, harassment, bullying or victimisation may constitute gross misconduct and could lead to dismissal without notice.

Unlocking potential We recognise that our current and future success depends on the skill and ability of our colleagues. We are committed to providing a range of learning and development solutions that help us to deliver our services and organisational objectives and are appropriate to personal development needs. Any decisions relating to learning and development will be made fairly and consistently and in line with UPP’s inclusion, equality and diversity policy.

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O U R PEOPLE

Our relationship with our supply chain partners and third parties We are committed to only working with third parties whose own standards are consistent with our Code of Business Conduct. We also believe that third parties are entitled to expect of us the same standards of conduct that we expect of our colleagues and others. The development of a responsible supply chain is critical to the success of our business in the future. UPP will take steps to ensure that our partners share our responsible value and that we in turn treat them with trust and transparently. We evaluate, select and performance manage our supply chain partners openly using clear and objective criteria.

Caroline Addo Receptionist, UPP at Griffon Studios, Imperial College London

The team here is like a little family. We do everything we can to make sure the residents have everything they need and we have a great relationship with them.

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O UR B USINESS INTEGRITY

Kieren took part in a Prince’s Trust ‘Get Into Facilities Management’ programme in 2012 and has worked for UPP ever since.

Kieren Hobday Maintenance Assistant, UPP at Plymouth University

My experience on the UPP Prince’s Trust ‘Get Into’ scheme was a game changer and enabled me to get a job I love with amazing people. It’s why I get up every day.

O U R BUSINESS INTEGRITY

Our business integrity Fraud, deception and dishonesty We will not defraud or deceive anyone or act dishonestly, and we will protect the Group at all times. We will not tolerate corruption and dishonesty and would rather step away from a business opportunity than compromise our integrity. Each member of the UPP management team will be familiar with the types of improprieties that might occur within their area of responsibility and will be alerted for any indication of irregular activity. Any irregularity that is detected or suspected must be reported immediately to the Compliance team.

Bribery and corruption We aim to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We implement and enforce effective systems to counter bribery and corruption. We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct.

We take our legal responsibilities very seriously. It is a criminal offence to offer, promise, give, request, or accept a bribe. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.

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O UR B USINESS INTEGRITY

Gifts and hospitality We allow reasonable and appropriate gifts and hospitality to be offered or accepted as part of a normal business relationship. However, we have strict conditions for colleagues to follow including registering all gifts and hospitality - offered or accepted. We never offer or accept gifts or hospitality if it may improperly influence a business decision or impair independence or a judgment.

Free and fair competition We believe in free and fair competition. We never seek, accept or discuss confidential information with competitors. Anti-competitive practices can damage our business. We never encourage our university partners, supply chain partners or former colleagues of competitors to provide information that they should keep confidential. We also never: • Enter into any price-fixing arrangements • Share sensitive information • Attempt to rig bids • Undertake restrictive practices with our competitors or our supply chain partners; directly or indirectly • Undertaking any of these practices will lead to disciplinary action

Conflict of interests Conflict of interests arises when a colleague (or their friends or family) could personally benefit from their part in the conduct of UPP’s business, or be perceived to be. Colleagues must always act in the best interests of the Group. We must always avoid situations in which our personal interests or actions could conflict or appear to conflict with the Group’s best interests.

Any questions or concerns that there may be a conflict of interests should be discussed immediately with our Compliance team.

O U R BUSINESS ASSETS

Our business assets Privacy laws, confidential information / information security Information is one of our most valuable assets and we do all that we can to protect it. We ensure that the systems and networks in which we hold personal data and confidential information are kept secure. Secure information helps to ensure business continuity and reduce disruption by preventing or minimising the impact of security breaches. It also demonstrates to all our stakeholders that we handle their information with care giving them added confidence in our integrity. We have a responsibility to keep confidential information safe and make sure it never gets into the wrong hands. We will only release confidential information to those who have a legitimate need to know. If you are a university partner, supply chain partner or an agent and have received confidential information from us in error you should immediately notify your UPP contact and refrain from further distribution.

We will only collect and retain personal data for the effective operation of our business and in accordance with all applicable privacy law.

UPP provides a home to nearly 5,000 students together with its long term partner, the University of Reading.

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O UR B USINESS ASSETS

External communications and social media The way we conduct ourselves in public can have a huge impact on the way people think and feel about UPP. We will always communicate openly and transparently with all our stakeholders within the bounds of commercial confidentiality. Using social networks and online communities offers great benefits to us as individuals and as a business to communicate what we are doing, whether to colleagues, partners or other stakeholders. We live in a world where news travels increasingly quickly, and where internal communications can rapidly become external communications. If wrong or incorrect information becomes public by whatever means, it can damage our reputation, our competitiveness and the trust placed in us by our partners. If you are representing the Group externally in an official capacity or if you are communicating on social media and can be identified as a UPP colleague, you should always make sure the way you behave is respectful. Use sound judgment and common sense at all times and never makes remarks or post comments, images or links that are incorrect or offensive.

Group property and resources We are all personally responsible for the assets we use at work and for using them responsibly at all times. Group property and resources include both our physical and intangible assets.

Physical assets are things like:

Intangible assets include:

• materials

• information

• supplies

• intellectual property

• equipment

• brand value

• photography

• our colleagues’ time and talents

• computers • mobiles • cash

We respect and protect the Group’s property and resources, and do not use them for any improper purpose.

O U R BUSINESS ASSETS

Financial controls, records and reporting We must all ensure our financial reports, as well as other reports and records are complete and accurate. We always report openly and honestly on our business performance. Falsifying any records, be they expenses, timesheets, operational compliance key performance indicators, supplier invoices or company accounts, is fraudulent and may result in incorrect business decisions being made that could have a significant impact on our reputation. Any suspicion that there is an irregularity in any Company books, reports or invoices or a weakness in any of our accounting systems, or something appears wrong, should always be reported at once. Even if it is unintentional, to keep or submit financial documents that are inaccurate, incomplete or misleading is against the law and we do not permit it.

Students’ Union, Nottingham Trent University

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CO M MUNITIES AND SOCIETY

Communities and society

Members of the UPP team on site at the University of Reading, pictured with Prince’s Trust ‘Get Into’ graduates.

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COMMUNITIES AND SOCIETY

Communities

Environment

We are committed to doing the right thing for our university partners, colleagues, shareholders, supply chain partners, the environment and our local communities. Investing in the communities is an essential part of our values and strategy. We believe that our ability to build and support communities, on and off campus, helps us to care for students and colleagues and to recruit the right talent for the future.

We appreciate that all the resources we use, the waste we create and our energy use contribute to our total carbon footprint and additional negative environmental impacts. Working with our colleagues, university partners and supply chain partners, our aim is to reduce our carbon footprint and adverse environmental impacts wherever possible.

Sustainability

Human Rights

Whether looking for the right funding solution, or assessing our local and wider environmental impact, long-term sustainability is key to the way we do things. We design our partnerships by carefully aligning our interests with those of our partners. This ensures that our solutions, products and funding are always sustainable, stable and fit for the long term.

We have a responsibility to respect human rights, as articulated in the Universal Declaration of Human Rights. We always work to ensure that we do not infringe on human rights through any of our operations or business relationships. Likewise, we expect our university partners, supply chain partners and agents to abide by this principle. As a Group, we comply with the provisions of the Modern Slavery Act 2015 and expect those we work with to do the same.

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CO M MUNITIES AND SOCIETY

Grants We receive many requests for grants from universities and other charities, in particular projects that support institutions’ cultural and charitable goals. To ensure that clear and fair governance is shown, all applications of this kind are considered by our independent corporate charity, UPP Foundation. The eligibility criteria for grants can be found via the UPP Foundation website: www.upp-foundation.org.

Political and public policy activities We make sure any public policy or political activity we undertake is lawful, ethical and within our Code and, as a Group, we do not participate directly in party political activities. Charitable or political donations or sponsorships and gifts to third parties, can only be made on the direct authority of the Group Chief Executive Officer.

Kathryn Brown Deputy General Manager, UPP at Nottingham Trent University

We are in a privileged position to be able to gain first hand insights into what universities and their students really want from us.

Notes

For more information, including copies of policies and other documents referred to in this Code, visit the Policy Centre on Campus, your intranet. An electronic version of this Code is also available on Campus or at www.upp-ltd.com. Useful contacts

Whistleblowing 24-hour line

0800 1116 390

Group Compliance

[email protected]

Group Human Resources

[email protected]

Learning & Development

[email protected]

Corporate Communications

[email protected]

Group Health & Safety

[email protected]