Business ethics and human rights
As a multinational organisation operating across diverse geographies and jurisdictions, we remain committed to upholding strong business ethics and we have placed a strong emphasis on driving further improvements, including the revision and introduction of Group-wide policies and the implementation of new mandatory compliance training. Our enhanced policies aim to foster responsible practices, uphold human rights throughout the Group and its value chain and protect our reputation with stakeholders. We fully recognise the potential impact that any breach of ethical standards could have on the wellbeing and livelihoods of our employees, as well as those within our supply chain, and are dedicated to mitigating these risks through continuous improvement.
Group‑wide policy revision and summaries
We have recently updated our policies to reflect a centralised Group position. The policies are summarised below, and longer descriptions can be found in the Pepco Group Policy Handbook. These revisions strengthen core principles aimed at safeguarding our employees and the business, while promoting a culture of trust and integrity. Additionally, as part of our proactive approach to maintaining a culture of transparency, ethical conduct and compliance across the Group, employees are required to complete a dedicated training module based on this updated policy suite. Our mandatory Group-wide compliance training initiative and user platform was extended in FY24, focusing on critical topics such as anti-bribery and corruption, fraud prevention, whistle blowing and human rights. The training is interactive, tailored to our specific industry and business areas, and aligns with the standards and principles outlined in our updated Group policy suite. To ensure inclusivity and engagement across the Group, the courses were translated into multiple languages. We are actively monitoring completion rates and we have over a 90% completion rate reported across all entities. Additionally, we have published an annual training plan to support the release of new topics, which will be subject to ongoing review and update.
Anti-bribery and corruption
Bribery is illegal in all the countries in which we operate. It damages markets and communities and transfers resources into the wrong hands. Our position on bribery and corruption is clear: we do not engage in corruption, and we never request, pay, authorise, or solicit or accept bribes, facilitation payments or kickbacks, regardless of local custom or practice. There were zero confirmed cases of bribery and corruption in FY24.
Anti-fraud
Pepco Group has zero tolerance of fraud committed by anyone associated with it and takes all appropriate action to prevent fraud in respect of its activities. We recognise that the impact of fraud on economies, communities, businesses and individuals can be devastating, and we therefore do not tolerate any form of fraud connected with our business. We are committed to complying at all times with applicable anti-fraud laws wherever in the world we operate.
Anti money-laundering and terrorist financing
We do not assist, support, participate in or permit money laundering or terrorist financing. Even the slightest suggestion of being involved in any such activity would be extremely damaging for the Group.
Gifts and hospitality
The proper management of the giving and acceptance of gifts and hospitality is key to avoiding the risk of actual or perceived improper influence and obligation. We prohibit the giving or receiving of any gifts. Hospitality must be appropriate and approved through the correct channels.
Conflicts
We try to avoid conflicts wherever possible. Even where there is no ill-intention, the appearance of conflicting interests can compromise integrity and damage the Group’s reputation and image. We should never put our own interests ahead of those of the business, even if it appears that the decisions may be beneficial for everyone.
Charitable donations, sponsorship and political donations
Making charitable donations and supporting community-based initiatives across the jurisdictions we, and our suppliers, operate in is an important part of our social responsibility commitment. We must ensure that donations to charities or political organisations are made properly, and that we only support reputable organisations, whilst complying with the law and best practice.
Due diligence
Our third-party relationships can present risks to the business. We could be investigated or prosecuted and suffer significant financial and reputational damage if we are associated with people and/or companies who engage in wrongdoing. We therefore need to understand who we are dealing with and how they operate. We do this by conducting due diligence and assessing all suppliers and third parties with which we interact during the course of our business.
Sanctions and export control
We are committed to complying with our legal obligations relating to sanctions and export controls. As the Group continues to expand its sourcing footprint worldwide, we need to ensure that we are vigilant and maintain robust compliance practices that keep pace with the rapidly evolving legislation and the geographical reach of our business.
Competition law
Pepco Group is committed to fair competition across our operations anywhere in the world. We do not engage in practices that restrict fair market competition and are committed to complying with competition laws in the markets in which we operate.
Anti-tax evasion
Pepco Group is committed to acting ethically and professionally in all our business dealings and takes a zero-tolerance approach to tax evasion or the facilitation of tax evasion, whether under UK law or under the law of any foreign country. We implement and enforce effective systems to counter tax evasion and its facilitation.
Human rights
Pepco Group is committed to business practices in our operations and supply chain throughout the world that do not infringe human rights and that are aligned with international standards of responsible business conduct, including the conventions of the International Labour Organisation (ILO).
Environment
At Pepco Group, we are committed to conducting business in an environmentally responsible manner. We recognise the importance of sustainability and strive to reduce our environmental impact in key aspects of our operations and supply chain.
Child Labour Remediation policy
The Pepco Group has a zero-tolerance approach to child labour. We are clear that there must be no recruitment of child labour or exploitation of children in any part of our supply chain.
Whistle blowing
Pepco Group is committed to conducting business with honesty and integrity and creating a culture of openness and accountability. We encourage people to raise concerns and are committed to supporting those that do. We strongly believe that this ethos will contribute to the success of our business, our people and our reputation.
Grievance mechanisms and remediation
Since 2021, the independent whistle blowing provider, Safecall, has been used by the Group. Over this period, the number of reported cases has varied, prompting us to focus on improving the quality of reports through training and to implement a more refined investigation process in FY24. As part of these ongoing efforts, a report assessment process was introduced earlier this year, overseen by the Group compliance team. This process ensures that reports are directed to the appropriate subject matter experts for management and investigation, providing greater visibility at the Group level and a more efficient experience for the reporter.
Our Whistle Blowing policy has also been updated as referenced in the policy section to reinforce our commitment to conducting business with honesty, integrity, and promoting a culture of openness and accountability. Maintaining a zero-tolerance stance on retaliation, we strongly encourage individuals to voice their concerns and remain dedicated to supporting whistleblowers. Going forward, we will incorporate cases of retaliation into our metrics, which are designed to monitor the overall effectiveness of the programme.
To ensure independence from local management when investigating cases, we have implemented measures that drive impartiality and objectivity throughout the process. This includes diverting certain cases to our Group-level team and introducing an investigator conflict of interest declaration ensuring that sensitive or complex matters are handled without bias or influence. Additionally, our newly introduced “triage process” further reinforces independence by reviewing and classifying cases centrally, ensuring they are escalated to the appropriate level for investigation and resolution. This structure helps maintain the integrity and fairness of all investigations.
Managing third parties
We have further refined our approach to managing third-party relationships and the risks they present to the Group, achieving significant progress in recent months. To strengthen our position, we have updated our Supplier Code of Conduct, which will be re-published in FY25. This revision reinforces our commitment to acting ethically and responsibly in all regions where we operate. Our goal is to source products and services in a manner that is ethical, sustainable, and socially responsible. The revised Code protects the integrity of our supply chain and outlines our minimum expectations for how suppliers should operate, helping us uphold our commitment to ethical business practices.
In addition to complying with legal requirements and our Code, we expect our suppliers to be guided by our dedication to ethical behaviour and to make the right choices. We fully support our suppliers in continually improving their social and ethical practices. Connections to individuals or companies involved in misconduct could lead to investigations or legal actions, resulting in serious financial and reputational damage. With a network of suppliers across China, Bangladesh, Hong Kong, India, and Pakistan, our due diligence process must address both country- specific risks, such as corruption and human rights concerns, and broader risks, including politically exposed persons (PEPs), sanctions, and watchlists.
Additionally, we have focused on enhancing our third-party due diligence process. Given that third parties carry varying levels of risk, the depth of scrutiny applied will be adjusted accordingly. This approach allows the Group to make informed decisions on whether and how to engage with each third party. By improving our methods, collecting valuable data upfront, prioritising key jurisdictions, and evaluating the availability and quality of data available in those regions we are better equipped to assess these relationships both initially and on an ongoing basis. This puts us in a stronger position to support and grow the business.
Our approach to tax
We aim to be clear and proactive in our interactions with tax authorities. Alongside our Corporate Criminal Offence Policy, our Speak Out Policy and whistle blowing hotline are available in the event that concerns are raised about our business conduct and integrity in relation to tax matters. No specific concerns were raised in this respect through these channels in FY24. We do not currently report on assurance metrics specifically related to tax matters; however this is an area that we will consider for future development. Further description of the risk and its potential impact as well as the steps we take to mitigate the risk are set out in the risk and governance section of this report.
Data protection and privacy
This year we have taken significant steps to enhance our data protection and privacy practices. We are working towards implementing a robust Privacy Management Platform to strengthen our accountability and compliance with GDPR and other relevant regulations. We have expanded cooperation among Group companies to establish a unified approach to data protection and privacy, aligning policies, frameworks, and functional accountability. Group-wide training programmes have been launched to engage employees in privacy matters, raising awareness and fostering a culture that values and protects personal data.
We are committed to continuously enhancing our technical and operational controls to secure the data we manage. This commitment is demonstrated by our active data protection committees and teams across the Group. Additionally, we have established active processes to uphold data subject rights, ensuring timely responses to requests. In FY24, we were not subject to any fines or corrective actions by any relevant Data Protection Authority.
