Foreword by the Governor and Chair
Our Code is the foundation of who we are as an institution. It tells us how we put standards of public service into practice and is the Bank’s way of embodying the Seven Principles of Public Life. It sets the expectations and standards for how we do the right thing at the Bank by: acting with Integrity; demonstrating Openness and Accountability; being Honest and Speaking up.
Our Code outlines the policies and requirements that support those core values, and signposts where we can go for further guidance and advice. It also encapsulates how we should treat others and how we expect to be treated in turn, in line with Our Bank Behaviours.
All of us who work here at the Bank must adhere to Our Code. We attest to it on joining the Bank and repeat that process annually. This is how we confirm we have read and understood Our Code, and that we are abiding by its principles. The Governors and Bank’s leadership hold themselves to account against the standards set out in Our Code – we know and expect that you will too.
Finally, we want to underline how important it is that you raise any concerns you have or report any breaches of Our Code or Bank policies you think might have occurred. Our Code explains the many ways you can do this, in confidence. The important thing is that you say something, so action can be taken. The Bank does not tolerate retaliation of any kind.
Thank you for taking the time to read Our Code, and for your continued commitment to uphold the highest standards of public service.
The Bank’s reputation – and the trust and confidence of the public we serve – depends on it.
Andrew Bailey
Governor
David Roberts
Chair of Court
1: Welcome to Our Code
Our Code represents our commitment to public service and earning public trust, setting out the values that our colleagues, stakeholders and the public should expect from us.
We want to ensure the Bank is a place where people do the right thing, work together to further the public good – and are transparent if things go wrong.
The Bank’s position as a public body means that it has to apply – and be seen to be applying – the highest standards of ethical behaviour.
This is why we must all strive to follow >The Seven Principles of Public Life, which you will find embedded within Our Code.
The Seven Principles of Public Life
1. Selflessness: Holders of public office should act solely in terms of the public interest.
2. Integrity: Holders of public office must avoid placing themselves under any obligation to people or organisations that might try inappropriately to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships.
3. Objectivity: Holders of public office must act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias.
4. Accountability: Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.
5. Openness: Holders of public office should act and take decisions in an open and transparent manner. Information should not be withheld from the public unless there are clear and lawful reasons for so doing.
6. Honesty: Holders of public office should be truthful.
7. Leadership: Holders of public office should exhibit these principles in their own behaviour and treat others with respect. They should actively promote and robustly support the principles and challenge poor behaviour wherever it occurs.
Our Code and what is expected from us
Our Code draws attention to the core policies that uphold the values expected from us.
We are all expected to:
READ…
...Our Code and the policies referenced in Our Code.
FOLLOW…
…the requirements of Our Code and in the policies referenced in Our Code and complete any mandatory training assigned to us.
ASK…
…if we need clarification or advice.
We are also all expected to:
- Familiarise ourselves and comply with the requirements set out in the Bank’s other policies contained in the >Policy Bank and >Staff Handbook where these are applicable to us.
- Observe >Our Bank Behaviours which set out how we do things, how we treat others, and how we expect to be treated.
- Where needed, familiarise ourselves and comply with the conduct standards set out in the >Disciplinary process.
Doing the right thing – how we make decisions
If we are faced with a situation where we are feeling uncomfortable or not sure if our proposed course of action is the right thing to do, ask yourself:
- Is it in keeping with Our Code, Our Policies, Staff Handbook and Our Bank Behaviours?
- Would I be comfortable if my actions were made public or headline news?
- What would happen if everyone did it?
- Have I considered if there are biases or pressures that could be influencing me?
- What are the potential impacts of my decision?
If in doubt, you can test your proposed course of action: this could be with your line manager, a trusted colleague or subject matter experts.
2: Acting with integrity
We act with impartiality and integrity, and work selflessly in the public interest
We rightly take great pride in the objectivity and impartiality of our work. We take decisions fairly and objectively, using the best evidence available without discrimination or bias.
Our personal interests and relationships must never influence our decisions at work. We must be free of any perception that our decisions have been inappropriately influenced. We must not act or take decisions during our work at the Bank to gain financial or other material benefits for ourselves or others.
The Bank recognises the rights of staff to have a private life as citizens, and to manage their personal affairs. At the same time, we must be able to demonstrate our integrity and impartiality; the Bank’s reputation is vital to earning public trust – and would be hard to recover if lost.
We therefore protect both ourselves and the Bank by making disclosures and seeking approval when required in the following policies.
Personal relationships
Why do we have this policy?
Our close personal relationships with others within the Bank, or in certain external organisations, could create or be perceived as creating a conflict of interest, or the perception of influence, or unfair advantage.
What must we do?
We must disclose our close personal relationships (spouse/partner, parents, siblings, and children) with those working in the Bank; in financial, economic, or political journalism; Bank-regulated firms and significant dealing counterparties of the Bank; firms holding or tendering for a contract with the Bank; or national elected public office. We must not participate in management decisions or decisions about the hiring, appraisal, pay or promotion of someone with whom we have a close personal relationship.
Prospective employment
We must disclose if we are participating in an informal or formal interview or selection process about prospective employment with: a Bank-regulated firm; a significant dealing counterparty of the Bank; a firm that we have contact with as a supplier of the Bank; or any other organisation that might create a conflict of interest (such as consultancy and legal firms providing advice or services to Bank-regulated firms).
- READ >Personal relationships policy.
Q&A
Q: I don’t want to tell my line manager I’m applying for a job with a regulated firm – how do I disclose this?
A: You must make the >Conflicts team aware promptly. Your confidentiality will be maintained unless the nature of the conflict(s) identified make a disclosure to management unavoidable. That would be discussed fully with you in advance.
Q: What happens if I declare a close personal relationship?
A: In many cases no further action is needed – a declaration is sufficient. However, a close personal relationship with someone working for an organisation with a financial interest in the activities of the Bank may mean you cannot take on or continue in roles that may give rise to an actual or perceived conflict of interest (for example, not directly supervising or contingency planning for a Bank-regulated firm, or carrying out a role that requires being part of specific insider lists).
Q: What is considered when putting measures in place to reduce risks?
A: Three key principles are considered:
Personal financial transactions
Why do we have this policy?
We must not seek to profit (or avoid loss) by making use of the privileged information acquired in the course of our duties at the Bank. Trading on the basis of inside information is a criminal offence.
What must we do?
We must gain pre-approval for certain transactions, and some financial transactions are never permitted. These requirements also apply to transactions where we are directing or advising on the investment decisions of someone else close to us. Once approved, a transaction must be executed promptly.
Some of the Bank’s most senior staff – members of Court and the policy committees – are additionally required to report all their financial assets and liabilities to the Secretary and ensure that their entry on the >Bank’s public register of interests is correct.
- READ >Personal financial transactions policy.
Q&A
Q: When do I need to seek approval for my mortgage?
A: Approval must be sought once a mortgage or remortgage offer is received (ie with the amount, interest rate being charged and length of any fixed period). You must wait for approval before accepting/signing the mortgage offer.
Q: Do I need to seek advance approval for the following transactions?
- Taking out a personal loan.
- Taking out a credit card.
- Opening a cash ISA.
- Opening a bank account.
- Transferring funds between accounts at the same firm.
- Paying off my mortgage.
- Purchasing items or services.
- Investing in one of the Bank’s core funds permitted within the Bank’s Supplementary Pension Plan.
A: No.
Financial relationships
Why do we have this policy?
The Bank needs to know about any ongoing relationships with financial institutions that might influence or be perceived to influence our judgement or affect our decisions at work.
What must we do?
We must each disclose if we (or an individual or organisation where we direct or advise on their financial arrangements) have any of the financial relationships listed in the policy. These must be disclosed at the time of joining the Bank and if/when they change.
- READ >Financial relationships policy.
Q&A
Q: Do I have to declare my shares or accounts?
A: We only need to declare shares and accounts if they are:
- Direct holdings of securities or related investments in a Bank-regulated firm or its financial holding company, including stock options and share related reward schemes.
- Accounts in a Bank-regulated firm of a value greater than the FSCS limit – currently £85,000 per person per firm (excluding those covered by temporary high balances protection).
Community and charity roles
Why do we have this policy?
The Bank encourages us to take on, in a personal capacity, roles with charities and community organisations. It is important that the Bank knows when we do so in order that any risks are identified and addressed.
What must we do?
We must disclose and gain consent when we seek to take on roles with legal duties or formal responsibilities (eg a charity trustee or a school governor). Compensation for these roles cannot be retained. If you wish to join the investment committee of a charity with which you are already involved, you should seek guidance from the Conflicts team.
- READ >Community and charity roles policy.
Q&A
Q: Do I have to seek approval to take on a charity role such as scout/guide leader, volunteering at a charity shop, fundraising for a charity?
A: No.
Directorships
Why do we have this policy?
Taking on directorships, particularly of trading companies, gives rise to a range of financial, legal, and reputational risks. This is why we need to seek the Bank’s approval where this is the case.
What must we do?
We are not allowed to become directors (executive or non-executive) of companies without the Bank’s advance consent. Permission will not normally be granted where the company is running a business and will not be granted for an organisation engaged in financial markets, or Bank-regulated firms and their holding companies. Non-trading companies – for example those set up by leaseholders to manage a freehold and directorships of charities – are likely to raise fewer concerns.
- READ >Directorships policy.
Q&A
Q: While working at the Bank can I set up a directorship to manage a buy-to-let property?
A: No, this is not permitted.
Other employment
Why do we have this policy?
Some other employment may be entirely compatible with our roles at the Bank. For example, external members of our policy committees would normally have other such roles. But others may be incompatible with the proper performance of our Bank duties and may give rise to a conflict of interest, a perception of advantage, or a risk to the Bank. This is why we need to seek the Bank’s approval where this is the case.
What must we do?
We must seek advance approval from our Head of Division to undertake any other employment. This covers any paid or unpaid work undertaken for another employer under contractual obligation (so not volunteering for a charity), for example, working as a professor or lecturer at a university, or as an adviser to research groups (where unrelated to our Bank roles). It also covers self-employment as a sole trader, within a partnership or via a limited company in which you are a shareholder.
- READ >Other employment policy.
Entertainment and gifts
Why do we have this policy?
Acceptance of gifts or entertainment from third parties we have contact with through our work could open us up to perceptions that our decisions were unduly influenced. It is a crime to offer, promise or give a bribe to another person, or to request, agree to receive or accept a bribe from another person.
What must we do for entertainments and gifts received through our work?
Decline:
- Any offer of entertainment that might be seen as excessive, putting the recipient under an obligation, offered to influence a procurement decision, in doubtful taste, liable to bring the Bank’s name into disrepute, or disproportionately lavish.
- Gifts as far as possible.
Accept only with approval: the types of entertainment and gifts, listed in the policy, received as part of your work at the Bank.
No action is needed in relation to:
- Invitations from personal friends that are not offered in an official capacity and do not involve corporate hospitality.
- Tea, coffee, and biscuits received through our work.
- Trivial or ephemeral gifts (eg calendars).
- READ >Entertainment and gifts policy.
Q&A
Q: What counts as ‘entertainment’ to be reported?
A: ‘Entertainment’ includes all hospitality received through your work including:
- Meals (including working lunches, breakfasts, and dinners), drinks.
- Paid-for outings of all kinds (including a complimentary paid-for place at an event, any related travel, refreshments, accommodation and/or expenses).
Q: What gifts received through our work can never be accepted?
A:
- Cash or retail vouchers (except for commemorative coins/specimen notes).
- Electronic devices (for security reasons).
Political activities
Why do we have this policy?
The Bank is apolitical, and we must ensure we protect our reputation for impartiality, while recognising that staff may wish to engage in political activity.
What must we do?
We must not engage in political activity while on duty or using Bank premises, systems, or resources. We must gain advance approval if our personal political activity is likely to include involvement in party organisation, fundraising or campaigning. We must seek advance consent with at least three months’ notice to stand for local or national elected office. If standing for a remunerated elected office, we must take unpaid leave from the Bank (and must resign from the Bank immediately if elected). We must avoid speaking publicly or publicly expressing views on matters of national political controversy relating to our work and the role of the Bank, where this could call into question our own political impartiality in the way we carry out work for the Bank, or the apolitical status of the Bank itself.
- READ >Political activities policy.
Conflicts of interest – decision tool
The decision flow chart below can help if we are not sure if we need to declare a potential or actual conflict of interest.
Do you have a conflict?
Could your personal interests or relationships influence – or be perceived as influencing – the decisions you take?
READ...
...Our Code and the relevant policy to assess whether you could have a conflict of interest.
FOLLOW…
…the requirements in the relevant policy and/or any risk mitigation agreed with your manager and/or the Conflicts team.
ASK…
…whether it could look like a conflict to someone inside or outside the Bank. If unsure email the Conflicts team.
Be aware…
The Bank also has other specific policies designed to protect our reputation for integrity and impartiality that we need to be aware of:
- When incurring travel and expenses costs on behalf of the Bank, we must ensure that these are in accordance with the Bank’s >Travel and expenses policy.
- If contractual arrangements are below £500, and for certain categories of expense over £500, the >Non-travel expenses policy applies.
- If we purchase or authorise the purchase of other goods or services on behalf of the Bank, we must follow the Bank’s >Procurement policy.
- The Bank is committed to high standards of financial crime prevention, must comply with financial sanctions legislation, and has zero tolerance for tax evasion.
- As outlined in the >Anti-Money Laundering, Counter Terrorist Financing and Financial Sanctions policy we must disclose to our line management or the >Money Laundering Reporting Officer, as soon as reasonably possible, information or suspicions regarding money laundering, terrorist financing, proliferation financing activity, non-compliance with financial sanctions or tax evasion.
3: Demonstrating openness and accountability
We are trustworthy and keep systems and resources secure
We are responsible for the resources and information entrusted to us in our work and are accountable for managing those with due skill and care. We must communicate effectively to each other, to Parliament and Government, to those we regulate and to the people of the United Kingdom. We welcome that our decisions and actions are subject to public scrutiny. Our communications are open, transparent, and straightforward.
When sharing information inside or outside the Bank we must maintain the security of all information. We all sign the >Declaration of Secrecy when joining the Bank. This requires us to observe the strictest secrecy with respect to information of any kind acquired in the course of our duties relating to matters concerning the Bank and others with whom we have dealings (for example, the firms that we supervise). It is a criminal offence to make unauthorised disclosure of certain information, including information obtained under the regulatory powers of the Bank or the PRA.
We must use the Bank’s resources responsibly, ensuring value for money. Failing to do so exposes the Bank to financial, legal and reputational risk. We protect ourselves and the Bank by following the policy requirements to keep and protect our records and information.
Record keeping
Why do we have this policy and standards?
Good record keeping is vital; records represent the Bank’s institutional memory and allow for proper debate and questioning. In the course of our work at the Bank we make critical policy, supervisory and operational decisions that have a broad impact. We are accountable for those decisions, and we must properly and securely maintain our records.
What must we do?
We all have a responsibility to ensure our records are authentic, accurate, timely, complete, appropriately classified, and retained in line with our records management policies and standards. The Records management policy sets out an overall framework to achieve this and is supplemented by the supporting policies noted below.
- READ >Records management policy; >Creating records of meetings, committees and calls policy; >Audio and audio visual recording of meetings policy; and >Internal and external information sharing policy.
Privacy and data protection
Why do we have these policies?
We will all handle personal data in some form in carrying out our roles. This means we all have a part to play to help protect the rights of individuals and ensure that the Bank complies with data protection laws.
What must we do?
We must all be able to recognise the personal data we come across, understand our individual responsibilities when handling personal data and know where to go for further advice. Executive Directors and Directors have additional responsibilities for the use of personal data in their business areas.
- READ >Privacy and data protection conduct policy. Executive Directors and Directors also need to read the >Privacy and data protection management policy.
External communications and engagement
Why do we have this policy?
Engagement and how we communicate with external contacts is a core part of achieving our mission. Comments from any of us who work at the Bank can carry great weight and can have unintended reputational consequences.
What must we do?
We must not interact with any media contacts, including via social media, blogs, or chat rooms, without the prior approval of the Bank’s Press Office, and we should always exercise judgement in our social interactions with them.
When we use personal social media, we must be mindful not to leave ourselves and/or the Bank open to unwanted attention or reputational harm and be cautious of engaging with someone we do not directly know. We should not use our Bank email addresses or provide Bank information or photographs which might allow others to access the Bank’s systems or our colleagues’ personal information.
In addition, policy committee members must adhere to the communications guidance for committees where this is in place.
- READ >External communications and engagement policy.
Be aware…
The Bank also has other specific policies to support our accountability and security that we need to be aware of:
- The Bank is subject to the Freedom of Information Act 2000 and so we need to forward requests for information to the Information Access team promptly as required in the >Freedom of Information Requests process.
- When planning to work from abroad we must follow the >Working from abroad (non-business travel policy).
Security conduct
Why do we have this policy?
As set out in the >Governors’ security charter, we all have a responsibility to keep the Bank safe and secure. If we fail to protect the Bank’s assets there is the potential for operational, reputational and/or legal harm.
What must we do?
- Classify and handle Bank information securely, in line with the requirements set out in the >Information Security Classification Scheme standard.
- Exercise caution when participating in sensitive meetings ensuring we cannot be overheard by unauthorised individuals.
- Only conduct Bank business using Bank authorised devices, systems and platforms.
- Use long, strong and unique passwords that are managed securely.
- Clearly display our security pass on Bank premises (whether by a lanyard or other means), removing it and storing it securely when we leave.
- Take care to manage our online presence to ensure it does not increase the likelihood of us, or the Bank, becoming a target for hostile threat actors.
- Report any security incidents, including suspicious activity or >data losses, as soon as possible.
- READ >Security conduct policy and >Information security classification scheme standard.
Q&A
Q: I have received a suspicious email, what do I do?
A: Please report any suspicious emails immediately by selecting the ‘Report Phishing’ button in Outlook. You must be vigilant to emails from people you don’t know, especially if they come with links or attachments, or unusual requests from people you do know.
Q: What information am I allowed to send to my personal email address?
A: You must not send information you create, receive, handle or process as part of your work at the Bank to your personal email address. This includes performance reviews. Limited exceptions apply (see >Security conduct policy).
Q: Is the use of Bank IT resources strictly limited to Bank business?
A: Occasional and limited personal use of Bank IT resources is permitted; however, it must not conflict with our work or compromise the security of the Bank. Be mindful that the use of Bank IT resources is monitored and recorded, with the expectation that you must always display reasonable and professional conduct. The >Monitoring notice, sets out the extent to which the Bank monitors use of its equipment. Access to offensive and inappropriate content is strictly prohibited.
4: Being honest and speaking up
We are truthful and speak up if something doesn’t feel right
We are all encouraged to raise issues or concerns, whether they relate to the behaviour or practice of colleagues which we believe might be in breach of Our Code, the >Staff Handbook, Bank policies in the >Policy Bank, or might create a risk to the Bank’s work or reputation; or we receive information that could suggest misconduct by external market participants.
Raising a concern where colleagues are behaving inappropriately or when we think something is going wrong are an important ways in which we all promote an open and honest culture at the Bank. We want to learn why mistakes occur and respond supportively. We are committed to fostering an environment where individuals feel safe and have the confidence to raise concerns without fear of retaliation or reprisal.
We protect ourselves and the Bank by speaking up through the channels outlined in the following policies.
Anti-bullying and harassment policy
Why do we have this policy?
The Bank does not tolerate any form of bullying, harassment, or victimisation and is committed to creating a culture and workplace free from these.
What must we do?
We are expected to work in line with Our Bank Behaviours, ensuring we treat others inclusively and with respect and dignity. We should actively discourage harassment, bullying or victimisation by making it clear we find such behaviours unacceptable. The Bank provides a number of routes to raise these concerns.
- READ >Anti-bullying and harassment policy
Q&A
Q: How do I raise a concern about possible bullying, harassment, victimisation, or any other inappropriate behaviours?
A:
1. If possible, raise this directly with the person. The earlier a concern is raised; the more effective resolution can be.
2. If it is not possible to raise this directly with the person you can speak to your line manager and/or HoD. Other informal resolution options (such as mediation or a facilitated conversation) and avenues for support can be found in the >Informal resolution guidance.
3. If the matter is too serious, or informal resolution has not been effective, you must speak to the Employee Relations team who can provide confidential advice and support in resolving the issue either informally or formally via the >Grievance process. If the investigation uncovers serious concerns or if the grievance is found to be raised with malicious intent, disciplinary action may be taken.
Colleagues should also consider discussing their concerns with Unite, who can provide further support through both the informal and formal process.
Internal whistleblowing
Why do we have this policy?
When things are going wrong in an organisation the signs are often spotted but colleagues may not feel confident enough to raise a concern. Management may not listen; or be seen as the problem. When things go wrong in the Bank, we want all colleagues to feel confident to raise a concern, either with line management, or to designated staff outside the management line, without fear of retaliation or reprisal.
What must we do?
If we have a concern about wrongdoing, risk or malpractice within the Bank that affects others or the Bank as a whole – such as possible fraud, criminality, breach of a legal obligation, environmental damage, or a danger to the Bank and its staff – it is vital that we raise concerns so it can be addressed.
- READ >Internal whistleblowing policy.
Q&A
Q: How will the Bank treat me if I blow the whistle?
A: The Bank treats whistleblowing seriously; we consider every concern reported. We don’t tolerate retaliation against anyone who raises a concern. You will not lose your job or suffer any penalty as a result of raising genuine concerns. There may be circumstances when you would prefer to speak confidentially – if so, please say so when raising a concern and your identify will be kept confidential (unless required by law). There may be times when we are unable to resolve a concern without revealing your identity. In such cases, we will discuss with you whether and how the matter can best proceed. You also have the option to remain anonymous if you would prefer not to share your identity.
What are the avenues for raising a concern?
If you have personal concerns about how you have been treated…
…Contact Employee Relations via OBS who can support informal resolution or formally via the Grievance process. Other avenues of support are included in the >Anti-bullying and harassment policy.
If you have a concern about malpractice or misconduct within the Bank that affects others or the Bank as a whole, you can speak with…
…your line manager.
…another manager in your area.
…one of the Secretary’s Department’s nominated people or any of the people listed in the >Internal whistleblowing policy.
…the Unite Seconded Representative. You don’t need to be a member of the Union.
Be aware…
The Bank also has other specific policies to support our ability to speak up that we need to be aware of:
- The Bank is required to report any instances of external misconduct it identifies in the financial sector, such as fraud, market abuse, or dishonesty.
- If we encounter any suspicions or are informed of such misconduct during our financial operations or market intelligence gathering activity, we must email >M&B Misconduct escalations and restrict access to this information – including not sharing this with colleagues or external parties.
- Outside of these operations, we must direct external individuals or any evidence or indications of external misconduct to the Legal Directorate’s >Intelligence and whistleblowing (IAWB) team.
Security vetting standard and changes of personal circumstances
Why do we have this policy?
The Bank’s approach to security clearance aligns with the guidance provided by the Government and helps preserve the Bank’s reputation for financial integrity by giving, at a point in time, a certain level of assurance as to an individual’s suitability to have trusted access to sensitive information or locations.
What must we do?
We should declare immediately to the Security vetting team any change in personal circumstances that may affect security clearance, such as: being arrested, bailed, summonsed, receiving a police caution, being charged with a criminal offence, or being convicted (other than minor road traffic offences), a change of nationality, severe medical or psychological illness, changes to our personal financial situation or any change in name or details of any new partner with whom we are living as a couple since last completing a vetting Security Questionnaire. If we find ourselves in financial difficulty or hardship, we are encouraged to approach the Staff Counsellor for support, who acts independently from management.
5: Other important things to know
If we make a mistake
We are trusted to make the right decisions in line with Our Code, the >Staff Handbook, the Bank policies in the >Policy Bank and legal requirements. But it is inevitable that sometimes mistakes happen. The Bank gives credit for acting with integrity and taking prompt responsibility for mistakes. The Bank does not have a ‘one strike and you are out’ approach for an honest mistake.
If we fail to comply or are suspected of failing to comply with Our Code or a Bank policy (whether because of a mistake or deliberately) this may be referred to the Compliance Division and/or to the Bank’s Employment Relations team, as appropriate, depending on the nature and seriousness of the breach.
Breaches or alleged breaches referred to the Compliance Division will be assessed swiftly, consistently and fairly in order to mitigate the risk of harm to the Bank under the >Breach management policy. Individuals may receive training, increased support and, if applicable, will be expected to correct any declarations or take other remediation action.
Alleged breaches which are referred to the Employee Relations team may be further investigated and, if sufficiently serious, may be addressed via the >Disciplinary process – and may result in disciplinary sanctions up to and including dismissal.
If we are a people manager
All of us who are leaders and people managers must:
- Act as role models and leaders, exhibit Our Bank Behaviours and The Seven Principles of Public Life in how we conduct ourselves.
- Challenge poor behaviour – encourage others to speak up if they have concerns and support those that do (including ensuring there is no retaliation for >Internal whistleblowing).
- Ensure the individuals on our teams receive the guidance, resources and training they need to understand what’s expected of them to follow the requirements in Our Code and the policies in Our Code.
- Understand and adhere to the additional requirements for managers in the policies in Our Code see >Our Code and compliance guidance for managers.
