Ethical code statement A guide to how we conduct our business responsibly

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Our ethical code statement

Our ethical codeOur corporate values, ethical code statement and group policies are the guiding principles that shape and inform our actions and behaviours. Below we set out our ethical code commitments which detail how we do business, engage with clients and manage our relationships with end customers, suppliers and third parties.

Social responsibilityWe manage our business to deliver long-term value for all our stakeholders including the communities and the wider environment in which we operate

Professional conduct We are honest, law abiding and act consistently with the standards of behaviour we expect of each other

Customer interestsWe support customers to achieve positive outcomes

Working togetherWe treat each other fairly, equally and are inclusive

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Customer interests

Working together

Professional conduct

Social responsibility

Applying our ethical code commitmentsWe expect our businesses and our employees to demonstrate these commitments in their decision-making and conduct. We recognise that some situations can be more ethically challenging than others to determine the appropriate response. We also recognise that no ethical code, values, or policy could fully address all the ethical scenarios that any business or its employees may face.

That’s why our ethical code commitments rely on all employees to:

f apply good judgement and help others to apply our Code commitments

f ask questions and challenge if they are uncertain

f report any concerns they may have in relation to ethical conduct and support those who raise them to us

We have a dedicated ethical code section available on our intranet, Capita Connections that provides further support and guidance. This connects to Capita policies that set out the rules and requirements that all employees must follow and that help us to conduct our business in a responsible way.

Particularly, to be Open

V O I C E

Our ethical code commitments embody and help us demonstrate our corporate values.

We expect all of our

employees to read our Ethical Code statement and

use the dedicated Ethical Code section on Capita Connections.

Employees should ask questions if they are unsure how the code

commitments and related policies apply to their role

and responsibilities

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Our ethical code statement

Professional conduct f We compete fairly and in the interests of the markets we operate in

f We act both in the spirit and intent as well as the letter of the law and regulations; this means,

f We aim to avoid and report any conflict of interest and appropriately manage those where we cannot

f We do not tolerate bribery - including the acceptance or giving of any gift or hospitality, charitable donations or sponsorships that may lead to an undue business advantage

f We do not use inside information for personal financial or business advantage

f We do not tolerate fraudulent activity and take the necessary action to prevent, detect and report it

f We are apolitical as a business and do not make political donations

f We maintain competency in our role including undertaking all Capita mandatory training when required

Working together f We do not tolerate bullying, harassment or victimisation

f We protect the privacy and personal information of our employees

f We maintain a safe working environment and take responsibility for our own safety, health and wellbeing as well as others who may be impacted by our actions

f We help to look after Capita’s reputation and understand our personal obligations in relation to this (including how we use social media)

Customer interests f We put customer interests at the heart of our business planning and decision making and manage the risks that may prevent this

f We are open and transparent in our communications

f We learn from customer feedback and address complaints effectively

f We keep customer assets and information safe, up to date and treat these with appropriate confidentiality

Social responsibility f We respect human rights, do not tolerate child labour and support the prevention of modern slavery

f We assess and take appropriate steps to improve our environmental impact

f We support the communities we operate in and are a part of, including through charitable and community programmes

f We encourage diversity among our suppliers, treat them fairly, deal with them openly and stick to our contract terms

Bringing our commitments to lifeOn this page we have set out what each ethical code commitment means to us with examples of how we bring them to life through our business decision making and conduct.

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Challenging and reporting ethical concernsCapita’s open door policy helps us to encourage a culture of active listening by supporting employees to raise any concern openly at any time in confidence.

If employees raise concerns that there may be potential criminal matters that have or are taking place, or failures in applying key Capita policies, then our speak up policy requirements must be followed.

Our speak up policy supports the interests of all employees, our customers, shareholders and industry regulators covering the circumstances of ‘protected disclosure’ by our employees of serious concerns.

Both our open door and speak up approach encourage employees to raise concerns to their line manager or supervisor in the first instance. Employees can also report matters dealt with under our speak up policy through our dedicated ‘whistleblowing’ channel if it would be more appropriate to raise them in this way or if a speak up matter is not being dealt with.

Our speak up policy also sets out that employees may also raise ‘protected disclosure’ concerns to external bodies such as regulatory or professional bodies covering specific industries.

Third parties and suppliersWe consider third parties who represent us and suppliers who provide goods and services to us as being an extension of our business. That’s why we work with them to ensure that they act in a way that is consistent with, our ethical code commitments and our policies. We will consider terminating contracts with third parties and suppliers who fail to do so.

Capita policies linked to the ethical code commitments Our policies describe in more detail the rules and requirements our businesses and employees must follow to conduct our business in a responsible way. Employees can use our dedicated ethical code section available on our intranet, Capita Connections, to link to related policy requirements.

For more information please contact:corporate-responsibility@capita.co.uk www.capita.com

Formed in 1984,

Capita employs 67,000 people,

interacting with 45 million people annually.