THE WAY WE DO THINGS AT WHITBREAD The Whitbread Global Code of Conduct 2011
Contents The Whitbread Way Forward
Foreword from Andy Harrison
How to use the Code of Conduct
Our people Human rights Equal opportunities and diversity Respect in the workplace Staying safe at work Getting involved
6 6 6 6 7 7
Our business Fair competition Conflicts of interest Political activities Gifts and entertainment Bribery Protecting company property Accurate accounting practices Keeping Whitbread information confidential
8 8 8 9 9 10 10 10
Foreword from Andy Harrison Dear Colleagues,
The Whitbread Way Forward Our aim is to build the best large-scale hospitality brands in the world by becoming the most customer focused organisation there is. Anywhere.
By engaging our people and putting our customers at the heart of everything we do, we’ll deliver profitable growth for our shareholders.
We’ll do this by providing outstanding value and making everyday experiences feel special – so that our customers come back time and time again.
To achieve these ambitions, we all need to work to the highest standards. Whenever we’re dealing with each other, customers, suppliers or stakeholders, we need to behave ethically and with integrity.
Whitbread’s Core Values Genuine Really caring about customers Confident Striving to be the best at what we do
This document is our Code of Conduct. It sets out the principles that shape the way we work together. It spells out the standards we set for ourselves and explains how we can achieve them. It’s important that everyone understands what’s expected of them, so if there’s anything you’re not sure about, please speak to your line manager.
Committed Working hard for each other Whitbread in Numbers We will measure our continuous improvement using the WINCard for our People, Guests, Investors and the Community.
We like to celebrate when we get things right and to recognise people for living up to our values. But equally, if someone doesn’t live up to this Code, we want to be able to do something about it. To help you speak out if you need to, we’ve set up a confidential helpline. The number is 0800 282 714. We’re all responsible for representing Whitbread and protecting our reputation. By following this Code of Conduct, we can be the best at what we do.
Andy Harrison Chief Executive
The Whitbread Code of Conduct
How to use the Code of Conduct
Most decisions we make are down to common sense. But it’s not always obvious what’s right or what’s legal in any given situation. If you want to be sure that what you’re doing or planning to do is appropriate, then use this Code as a guide.
Our customers are at the heart of everything we do. We care about them and we want to give them a really special experience, so they come back to us time and time again. We’re all responsible for delivering that experience. Customer focus should be at the forefront of your mind while you’re working for Whitbread. That means understanding what our customers need and expect from us.
If the Code doesn’t tell you everything you need to know, then you can find out more by looking at our policies. These are documents that give more detail on the subjects the Code covers, from human rights to information security. There’s a list of the relevant policies on page 12 along with details of where you can find them.
Every customer is different, and we need to treat each one as an individual. But there are some general principles to remember. Always treat each customer with the same respect and integrity and offer each one the same high standards of service. Never discriminate against a customer because of age, sex, colour, nationality, ethnicity, religion, disability, family status or sexual orientation.
However, it’s not always possible to refer to written documents before you take action. So if you’re not sure about something, ask yourself these questions before you act: • Is what I’m doing within the law? • Is it in line with our values and this Code? •D o I feel comfortable with what I plan to do? •H ow would I feel if it were featured in the newspapers or on the television tomorrow? •H ave I understood the risk and the possible implications of what I am doing? •H ave I tried to find the right advice to make an informed decision? If in doubt, talk to your line manager.
Complying with the law We make sure that our policies and procedures comply with the law of any country in which we work and we expect you to comply with them at all times. We don’t condone law breaking and we will help the authorities deal with any offenders.
The Whitbread Code of Conduct
Our people Human Rights Everyone deserves the right to live and work with dignity. There are basic standards of human rights that Whitbread will respect at all times. They relate to issues such as fair pay, child labour, humane treatment and working conditions.
If you believe that you or your colleagues aren’t being treated with the respect you deserve, talk to your line manager or call the anonymous Speaking Out helpline 0800 282 714.
We expect our business partners to respect these standards too. We will only work with organisations that have the same respect for people’s working conditions that we do. We encourage you to read our Human Rights Policy. If you see any abuses of the policy, then please report it to your Line Manager, or call the Speaking Out helpline 0800 282 714 straight away.
An important part of keeping a safe working environment is working without the influence of alcohol, illegal drugs or other substances that might alter your judgement and abilities. If you’re aware of any behaviour like this that might cause a safety or environmental hazard, then you must tell your line manager or call the Speaking Out helpline 0800 282 714 straight away.
Equal opportunities and diversity We believe that a diverse organisation encourages a full range of ideas and better decision making. We encourage diversity at Whitbread and we believe in equal opportunities for all. Always treat your colleagues, customers and suppliers with respect and integrity and don’t discriminate against anyone for any reason. If you’re recruiting, developing, compensating, promoting or transferring someone, or ending someone’s employment, base your decision solely on that person’s ability, qualifications and potential.
Getting involved We want our people to feel engaged in what we’re doing and motivated to do a great job. We regularly ask for your opinions and feedback. For many of us this is through the Your Say survey, which is a way to give your honest views anonymously. We use what you tell us to create an action plan and make improvements across the company.
Respect in the workplace At Whitbread, we respect each other. All of us have important jobs to do and everyone should be free to perform their job well. We are all responsible for creating an environment of mutual respect.
There are also more regular ways to get involved. Your line manager is always there to listen to any suggestions or issues you might have. They’ll also hold a development review twice a year, to talk to you about how you’re getting on and how we can help with your personal development.
Respecting your colleagues means you never: •U se abusive language; •S exually or physically harass; •E ngage in bullying; or • Use any unwelcome behaviour towards a colleague or person doing business with Whitbread.
The Whitbread Code of Conduct
Staying safe at work We want to keep everyone safe. We’ll give you the safety training and information you need to keep you and your environment safe, but if you’re not sure about anything, check with your line manager. As well as our policies and procedures, there are a number of important laws and regulations that affect how we work. If you need more information, ask your manager or take a look at our Health and Safety Policy.
Our business Political activities We don’t engage in any political activity as a company. This means we don’t sponsor any political parties and we don’t make any donations or contributions. But we do respect everyone’s political views. Everyone at Whitbread has the right to hold whatever political views they want.
Fair competition Competition laws give customers choice. They’re there to make sure customers pay a fair price for the products and services they buy. It’s against the law for companies to make agreements amongst themselves that could undermine competition or disadvantage customers. So think very carefully before you talk to a competitor. Never discuss prices, costs, services, territories, customers or any other business matters that aren’t public knowledge. It could damage our reputation and leave us open to legal challenge or financial penalties.
You’re allowed to participate in the political process as long as it’s voluntary and it’s in your own personal time. It is not appropriate to use any of the company’s funds for political activities. And never offer our facilities to political organisations free of charge, or at a discounted rate.
It’s also against the law to mislead customers with our marketing material. All statements that sell or market products and services must be true and fair and must comply with local laws and regulations. Conflicts of interest We want all of our business decisions to be made fairly and objectively. You should always act in Whitbread’s interests, rather than your own, when you’re making business decisions. Conflicts between your interests and the company’s can hurt our business and reputation even when you don’t intend to do anything wrong. Ask yourself how your actions and relationships might appear to others. You need to tell your line manager if you think you might have a conflict of interest. Conflicts of interest could include: •a ctivity outside work that might affect your work at Whitbread; •a ny financial interests you have in other companies Whitbread deals with; or •a situation where you’re dealing with someone as part of your work who’s also a close friend or a member of your family. If any of these situations arise, then tell your line manager straight away and hand over the decision to someone else.
The Whitbread Code of Conduct
Gifts and entertainment We all deal with customers, clients or businesses regularly. This means that sometimes you might be offered a gift, hospitality, service or other benefit that could place you or Whitbread in an awkward position. Before you offer or accept a gift or entertainment from a business contact, ask yourself the following questions: • Could it be against the law? • Does this offer look odd or out of place under the circumstances? • Does the offer seem high in value? • Has this person tried to give me more than one gift recently? • Would the company or I be embarrassed if the offer became public? • Is this person a government official, for example a health and safety officer or benefits agent? If the answer to any of the above is “Yes”, then please don’t make or accept the offer. Many people working directly with customers or guests are offered tips for their services. Receiving tips for doing your job well is fine, but please don’t ask for tips. If you’re not sure whether it’s OK to accept a gift, then talk about it with your line manager. If you are in any doubt at all, it’s best to say no. You can find more information in our Hospitality and Gifts Policy.
Our business Bribery Whitbread is strongly opposed to all forms of bribery. A bribe involves the promise of money, a gift or a favour to influence someone’s behaviour so they don’t perform their role properly. It is a personal criminal offence in most countries and can lead to large fines for the company. It can also damage our reputation.
Creditors, government officials, partners and people from all across Whitbread all need to access books, records and statements about our financial performance. These must give fair and accurate information and be protected from unauthorised viewing, damage and loss. It’s important that you keep all documents safely and for the right length of time. All people who work regularly with our data and records need to follow our guidelines and procedures. If you are unsure of anything, always check with your line manager.
Never give or accept a bribe. Please also make sure that third parties working on our behalf understand that we do not approve of giving or accepting bribes.
Keeping Whitbread information confidential Please be aware of where you are when you are discussing or working on company matters.
If a guest offers you a tip for your services, that’s OK. However, it’s not OK to accept money from an individual or organisation that might then expect you to promote their company.
Whitbread’s business information is one of our most valuable possessions. We follow all data privacy laws and trust you to keep non-public information confidential. This includes company information and information that relates to guests, suppliers and partners.
If you’re asked for a payment from a foreign public official in order to get a business advantage, you should refuse and then always speak to your line manager or the legal department in the UK. Protecting company property We all use company property as part of our jobs. This includes buildings, vehicles, equipment, supplies, computers, software, networks, e-mail and voicemail systems. It also includes things like brands, trade marks, corporate opportunities, trade secrets and business information.
Please make sure all personal data is taken care of and is never lost, destroyed or seen by anyone without permission. You can use anonymous data where and when necessary. This means removing names, contact details or any other information that could identify an individual. Don’t share confidential information with anyone without legal or company permission. If you’re unsure whether data or business information is confidential, speak to your line manager before telling anyone else. Also let your line manager know if any personal data has been shared or used without permission. Our Corporate Communications Policy, Information Security Policy and our Data Protection Policy can give you more information.
Please look after company property as if it were your own. We understand that from time to time our employees use company property for personal reasons in exceptional circumstances. This could mean using the internet or company phones. Accurate accounting practices Honest and accurate records help our shareholders see how their investments are being looked after. They’re also a legal requirement.
The Whitbread Code of Conduct
We have designated people who are solely responsible for talking to the media. This is to make sure that no confidential data or business information can accidentally be made public. So, please don’t talk to the media, even if they approach you. 10
Here’s a list of the policies we refer to in the Code of Conduct.
We want all of our employees to be safe and supported in their work place. If someone is behaving in a way that’s harmful to our employees, customers, or to the reputation of Whitbread, we’d like to know about it.
Human Rights Policy The basic standard of human rights everyone at Whitbread can expect.
We want you to feel you can speak out if you notice any harmful behaviour or misconduct.
Responsible Sourcing Policy What we expect from the suppliers we work with.
Harmful behaviour or misconduct can mean: •B ehaviour that breaks the law or company policies • Malpractice and mismanagement •H arassing or bullying employees, customers or any other individuals •D anger to the health and safety of customers, employees or other individuals • Damage to the environment •D eliberately concealing information in relation to any of the above.
Hospitality and Gifts Policy Our approach to business hospitality and gifts. Health and Safety Policy The procedures that keep us safe at work. Corporate Communications Policy Our approach to communicating with the media, our shareholders and the City. Information Security Policy Our approach to keeping our systems secure.
Our employees are always protected if they speak out in good faith. You should feel able to talk about any worries or problems with your line manager or another responsible person, without fear of victimisation or dismissal. Any issues raised will always be investigated in a fair and balanced way.
Data Protection Policy Our approach to looking after our customers’ data. Anti-Bribery Policy We never accept or give a bribe.
Although you should always feel safe talking to Whitbread about any harmful behaviour or wrongdoing, we realise that speaking out can be difficult. If you feel uncomfortable talking to someone at work, there’s an independent and confidential helpline run by Positive People Company (PPC) open 24 hours a day, 365 days a year. You don’t have to leave your name, but your PPC counsellor will encourage you to if it will help us to resolve the problem.
You can get a copy of each policy from the intranet or by requesting a hard copy from the Legal Department in the UK.
Our employees deserve the best working environment possible and our customers deserve the best service we can offer. You help us to achieve this and you can help us to keep it that way. Speaking Out Number: 0800 282 714 Lines are open 24 hours a day, 365 days a year. The Whitbread Code of Conduct