Our Standards of Ethical Business Conduct provide a common set of practical guidelines to help make sure our behaviours are lawful, comply with our policies and licences and follow the values set out in our Framework for Responsible Business and our core values. We undertake online training for employees annually to ensure they understand the Standards.

This year, 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 2010/11, there were 13.9 substantiated breaches of the Standards per 1,000 employees compared with 13.6 in 2009/10. Offences could include such things as fraud, internet and email abuse, drugs and alcohol abuse, and misuse of Company vehicles and other assets. We take all breaches very seriously and disciplinary action can range from a verbal warning to dismissal.

More information on our approach to business ethics is included in the Corporate Governance section of our Annual Report and Accounts 2010/11, starting on page 80.