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Definitions

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A

Anti-trust laws

Anti-trust laws exist to stop any attempt to restrict free and fair competition, such as price-fixing. Many countries apply these laws both inside and outside their borders, so their scope is international. It can be a criminal offence to violate these laws, involving severe penalties - including prison for individuals and heavy fines for companies.

B

Bribery

Bribery means giving or receiving an unearned reward to influence someone's behaviour. One common form of bribery is a "kickback" - an unearned reward following favourable treatment. Both are corrupt.

Bullying

Bullying means any offensive, abusive, intimidating or insulting behaviour or abuse of power that makes someone feel upset, threatened, undermined, humiliated or vulnerable.

C

Charitable activities, donations and sponsorship

We actively encourage involvement and participation in charitable activities and causes. But we do need to make sure that the charity in question is legal and appropriate, its activities are proper, and it really is raising money for good causes. We should not end up supporting something we don't want to support, or cannot support for legal or ethical reasons (for example, donations to political causes).

Cloud Computing Security

If you plan to store data or use applications outside of Serco's own infrastructure (i.e. in the 'Cloud'), you should check for any legal or contractual restrictions that may prevent the data being hosted in another country. You should also follow the Cloud Security Standard Operating Procedure and complete the necessary risk assessment. And you should consult the owner of the data to ensure it conforms to any additional requirements they may have.

Code of Conduct

A code of conduct tells all employees what the company expects in the way of behaviours and practices and compliance with policies, standards and the law.

Our Code is part of defining who we are, and tells everyone what they can expect of Serco, and what Serco expects of them. It is also a way of thinking about what's the right thing to do, and actively seeking help and advice when you are not sure.

Compliance

Our Code isn't a contract of employment, but once you are employed by us you must follow the Code. If you don't, it can have serious consequences. Many parts of Our Code are based on laws and regulations. If we don't obey these, the company or individuals could face fines, legal penalties or even imprisonment.

But violating Our Code also damages our reputation, and undermines the trust of our customers, our people and the communities we work among.

So as well as obeying the laws of the country we work in, we should always comply with Our Code, and never knowingly allow or encourage anyone to do anything that violates it. And if we think there is a violation, we should report it. Any of us can be dismissed, or even face criminal proceedings, if we fail to do these things.

Confidential Information

There are many kinds of confidential information. Some examples are: information about finances, business plans or practices, marketing plans, pricing policies, specifications, systems, relationships, costs, strategies, information about employees, customers, partners or third parties, agreements, and intellectual property such as technical information, innovations, improvements, know how and trade-secrets.

Conflicts of Interest

When your private interests interfere, or could appear to interfere, with the best interests of Serco, it's a conflict of interest. Your own business judgement may be improperly influenced as a result of the conflict, or because you or someone you know may benefit at the expense of the company or another employee.

Organisational Conflicts of Interest

When a company could end up with an unfair competitive advantage in the market, it's an Organisational Conflict of Interest (OCI). If we don't identify and resolve them, they can do enormous harm. One example is when we employ someone who has access to proprietary information or who might be able to influence Government decisions that could benefit Serco. This is called "Unequal Access to Information". But there are other kinds of OCIs as well. Whenever you think there may be an OCI you should raise it at once.

Corruption

Corruption is any unlawful or improper behaviour that seeks to gain an advantage through illegitimate means. Bribery, abuse of power, extortion, fraud, deception, collusion, cartels, embezzlement and money laundering are all forms of corruption.

Critical Incidents

Whenever there is a critical incident, there's huge pressure to communicate what has happened at the earliest possible opportunity. However, what people first read and hear about an incident will shape their perceptions of what's going on. So it is really important that we make every effort to get the facts right, and be clear about what we do and do not know, so we are accurate and concise when we communicate what has happened. We should also follow local arrangements, which will be detailed in a crisis management plan.

D

Decision Making Guide

Our Decision Making Guide gives you a step-by-step process to work things through to a clear conclusion, when faced with a dilemma or uncertainty.

Discrimination

At Serco discrimination means treating one person or group unfairly, unequally or disadvantageously because of their:

sex, race, colour, national or ethnic origin, sexual orientation, gender identity or expression, religion, political belief, trade union activity, marital status, caring responsibilities, disability, age, or citizenship.

We want everyone at Serco to be absolutely clear: we will not tolerate any form of discrimination.

Donations (Political)

We do not contribute to any political party, politician or candidate for public office, or try to raise funds for them.

There's one exception: where we have a legitimate voluntary Political Action Committee (PAC) or similar voluntary contribution scheme. In this case, employees can freely contribute donations, but there are very strict conditions, and these sorts of schemes are only allowed in some countries.

Although it is in the Company's name, the scheme must be run independently, and the Company must not have any influence on its management. If properly formed and governed, the Regional CEO can then authorise it, and permit appropriate political contributions to be made, so long as they are strictly in accordance with applicable laws and regulations.

Donations (Charitable)

We actively encourage involvement and participation in charitable activities and causes. But we do need to make sure that the charity in question is legal and appropriate, its activities are proper, and it really is raising money for good causes. We should not end up supporting something we don't want to support, or cannot support for legal or ethical reasons (for example, donations to political causes)

Document Classification

Classifying our documents and emails, based on the information they contain, is a vital part of information security at Serco. It helps to ensure every piece of information is stored, handled and shared in the right places with the right people.

You need to understand our different classifications and select the right one for every document and email you create or change. It is your responsibility to know and understand the policy and guidelines for Information Privacy Classification:

Serco Restricted and Sensitive (SRS)

SRS is our highest classification. We use it ONLY for the most sensitive and valuable information, requiring the greatest level of security. SRS information must only be shared on a need to know basis and restricted to authorised personnel only.

Serco Business (SB)

SB should be used for our day-to-day business information that is generally available within our offices, systems and intranet, or when sharing relevant business information with intended third parties. Think carefully before sharing SB information outside of Serco as disclosure to the wrong people may cause unwanted exposure to the inner workings of our business and customers.

 

 

 

E

Employee Insider

If you regularly or periodically possess inside information or have it because of a project you are working on, then you are an Employee Insider. The Company Secretary will tell you this in writing. Employee Insiders cannot deal in company shares without written approval.

Expenses Reporting

To make sure we are charging our customers properly for our efforts and they are getting what they paid for, it's vital that we maintain accurate timekeeping and expense reporting at all times. Different business units have different ways of doing this. If you have a question, ask for help. Take the time to get it right!

Follow our Travel Standard and use Serco Travel when travelling on Serco business, and always keep proper records and receipts for any travel expenses you claim.

Exports, Imports and Other Trade Restrictions

We will comply with national and international restrictions on Trade and Exports/Imports and all legitimate sanctions and boycotts. However, we do not comply with illegal sanctions, and will not engage in prohibited or restrictive trade practices. Sometimes this can result in a legal conflict, in which case you should always seek legal advice by referring the matter through your division's General Council or Commercial Lead for a resolution.

We will comply with legitimate special trade restrictions. For example, in some countries there are laws covering the transfer of equipment, software, services or technology to a foreign country or foreign person. These can include potential transfers to other parts of Serco, and can even apply to any foreign nationals working on our team.

F

Facilitation payments

are sums of money paid to an official to speed up or "facilitate" their actions. That's why they are sometimes referred to as "grease" or "speed" payments. Whatever the local custom, Our Code forbids facilitation payments to be made anywhere in the world. We make no distinction between them and bribes, no matter how small the amount.

Fraud

If you deceive someone by misrepresenting or dishonestly reporting facts to gain an advantage, it's fraud. It is also fraud if you get someone else to do it. Fraud is usually carried out for gain, and it is a very serious crime. In some counties the deception doesn't even have to be deliberate - you can face criminal charges just for carelessly allowing it to happen.

G

Gifts and Hospitality

mean anything of value that you give or accept, either directly or in kind. Any gift or hospitality you accept from someone should be something that you would be able to give them as a proper and appropriate business expense. "Proper and appropriate" is what matters. For instance, if an existing supplier invites you to share a box at a football match, you should record this, but it is appropriate. However, if a prospective supplier hoping to get a contract from you does the same, that is not appropriate.

We have a standard reporting process to register gifts and hospitality we give or receive anywhere in the world. You can find this at https://gandh.serco.com. As a minimum, all gifts or hospitality with a value over £100 (or equivalent in local currency) must have management approval and must be registered. However, this limit may be less depending on local procedures.

You can get approval by either speaking directly with your Manager or through the Gifts and Hospitality Register. The system will email your gifts and hospitality submission to your Manager for approval.

You can also access the Gifts and Hospitality Register through the sayno toolkit

Unacceptable gifts

There are some types of gifts that are never acceptable. These include cash, securities, and personal cheques or payments to or for the benefit of individuals.

Government work

Our work for Governments sometimes also requires us to make special arrangements that ensure national security and interests are safeguarded. We always comply with any legitimate requirement or agreement of this kind.

From time to time we will be asked to cooperate with internal or Government inspections or investigations. We always cooperate, and always comply with the law.

Grievances

You might want to raise a grievance about things like:

  • Something you are being asked to do as part of your job
  • The terms and conditions of your employment contract, for example, your pay
  • The way you're being treated at work, for example, if you're not given a promotion when you think you should be

If you have a grievance, use your local grievance procedure to tell us, and we will ensure it is addressed. If unsure, speak to your manager or Human Resources.

H

Harassment

Harassment means any behaviour that offends someone, violates their dignity or intimidates or humiliates them. This includes:

bullying, using threatening, abusive or insulting words, physical threats or assault, unwanted physical or psychological contact, or open hostility in the workplace.

Hospitality and gifts

mean anything of value that you give or accept, either directly or in kind. Any gift or hospitality you accept from someone should be something that you would be able to give them as a proper and appropriate business expense. "Proper and appropriate" is what matters. For instance, if an existing supplier invites you to share a box at a football match, you should record this, but it is appropriate. However, if a prospective supplier hoping to get a contract from you does the same, that is not appropriate.

We have a standard reporting process to register gifts and hospitality we give or receive anywhere in the world. You can find this at https://gandh.serco.com. As a minimum, all gifts or hospitality with a value over £100 (or equivalent in local currency) must have management approval and must be registered. However, this limit may be less depending on local procedures.

You can get approval by either speaking directly with your Manager or through the Gifts and Hospitality Register. The system will email your gifts and hospitality submission to your manager for approval.

Human Rights

Human Rights are the basic rights and freedoms that belong to every person in the world. They include the right to life, the right to respect for private and family life and freedom of thought, religion and expression.

The Universal Declaration of Human Rights defined by the United Nations sets out what these fundamental rights and freedoms are. They are integral to International Law.

Underlying our own Values is the right everyone has to be treated with dignity, fairness, equality and respect, and we are committed to applying these principles in our business every day, everywhere.

Human Rights: Direct and Indirect Abuse

If a company causes or carries out a violation of Human Rights, that Is direct abuse. And if a company is forced into violations because of the laws of the country in which it is operating, that is direct abuse too.

A company can also indirectly violate Human Rights. This is often referred to as being "complicit in an abuse". It is usually the result of someone in a company's network of business relationships committing an abuse, like a supplier, third party - or even a customer.

I

Imports, Exports and Other Trade Restrictions

We will comply with national and international restrictions on Trade and Exports/Imports and all legitimate sanctions and boycotts. However, we do not comply with illegal sanctions, and will not engage in prohibited or restrictive trade practices. Sometimes this can result in a legal conflict, in which case you should always seek legal advice by referring the matter through your division's General Council or Commercial Lead for a resolution.

We will comply with legitimate special trade restrictions. For example, in some countries there are laws covering the transfer of equipment, software, services or technology to a foreign country or foreign person. These can include potential transfers to other parts of Serco, and can even apply to any foreign nationals working on our team.

Inside information and Insider Trading

Inside information is confidential information not generally known to the public. If you have access to it and use it or disclose it to someone else in order to gain unfair benefit in the market place - for example, to buy or sell stocks or shares or influence their price before others know what you know - it's called "insider trading." This is absolutely forbidden.

J

K

L

Lobbying

In some countries special laws and procedures govern the way lobbyists and consultants must behave. It's really important to know these and make sure we follow them.

M

Money Laundering

Money laundering involves trying to "launder" the proceeds of criminal activity such as terrorism, drug trafficking and fraud into legitimate funds or assets. Sometimes this also involves using legitimate funds to finance terrorism. Money laundering depends on misrepresentation or creating a false reporting trail. We comply with money laundering and anti-terrorism legislation around the world, and apply due diligence checks on all those we do business with.

N

O

Organisational Conflicts of Interest

When a company could end up with an unfair competitive advantage in the market, it's an Organisational Conflict of Interest (OCI). If we don't identify and resolve them, they can do enormous harm. One example is when we employ someone who has access to proprietary information or who might be able to influence Government decisions that could benefit Serco. This is called "Unequal Access to Information". But there are other kinds of OCIs as well. Whenever you think there may be an OCI you should raise it at once.

P

Political donations

We do not contribute to any political party, politician or candidate for public office, or try to raise funds for them.

There's one exception: where we have a legitimate voluntary Political Action Committee (PAC) or similar voluntary contribution scheme. In this case, employees can freely contribute donations, but there are very strict conditions, and these sorts of schemes are only allowed in some countries.

Although it is in the Company's name, the scheme must be run independently, and the Company must not have any influence on its management. If properly formed and governed, the Regional CEO can then authorise it, and permit appropriate political contributions to be made, so long as they are strictly in accordance with applicable laws and regulations.

Personal Data

Personal data means any information relating to or capable of identifying an individual, whether directly or indirectly. This means that the information says or reveals something private, personal and of meaning about someone, and that it must reveal who that person is (either by itself, or when combined with other information that we hold), This information may relate to any person who has directly or indirectly come into contact with Serco.

Personal data has a wide scope and includes: contact details such as names, addresses, telephone numbers, email addresses and dates of birth; salary; opinions about someone; identification numbers; IP addresses and biometric data (ie. fingerprint or iris scan data); information contained in call recordings; CCTV and other information related to your employment and the services we provide to our customers, partners and the users of our services.

Q

R

S

Safety

We want no one to come to harm because of the work we do. So we continually develop and improve our systems and processes to keep everyone safe and well.

Everyone at Serco is responsible for safety. We expect you to:

  • Actively promote our safety culture and follow our health and safety standards and processes
  • Understand your personal responsibilities and your personal contribution to maintaining a safe workplace.
  • Exercise proper care for your health and well being, and that of everyone who may be affected by what you do - or don't do
  • Work within any method statement or risk assessment that applies to your work
  • Wear proper items of personal protection equipment when required, and request replacements if the equipment is damaged.
  • Only operate plant and equipment after you've been trained and are registered as a competent user.
  • Report any defective plant or equipment, or any work activities you believe to be unsafe
  • Stop work if you believe you are unable to perform your duties safely, and immediately report why.
  • Never participate in disorderly behaviour, substance abuse or any other activity which could cause injury to you or others
  • Report any accident or dangerous occurrence
  • Assist with any investigation into an accident or incident.

SayNo Tool and App

Our SayNo Tool and App has been designed to help you find answers to lots of issues you might face when dealing with suppliers and third parties, So why not check it out? You can find it at http://serco.saynotoolkit.net/

Speak Up

No matter where you work in Serco, if you believe Our Code is being broken, then you should report it. We absolutely prohibit retaliation towards anyone who reports a violation or helps an investigation, and we will protect you and respect you for having the courage to live Our Code. There are many ways you can do this. You can find out how online, or at the back of your own copy of Our Code.

Special Agreements

In several countries we have particular arrangements with governments. Each will set their own conditions, with which we always comply. For instance, in the U.S. we have adopted a set of rules based on our Special Security Agreement (SSA) that address proper handling of classified and other sensitive U.S. Government information. These require that our US colleagues get permission before meeting with Serco colleagues from outside of North America and follow particular rules once that permission has been granted. For example, they must keep a record of all phone and in-person contacts with these colleagues.

Social Media

Social media refers to websites and applications that let users create and share content and participate in social networking. It includes sites such as Facebook, YouTube, LinkedIn, Twitter, MySpace, blogs, wikis and newsgroups. But it also includes any means through which you can digitally post text or images to someone else.

Social media - your responsibilities:

  • You are responsible for everything you publish on social media. If you identify yourself as a Serco employee, then you should abide by the behaviours and values of Our Code
  • Your profile and content should be consistent with the way you would present yourself and Serco to colleagues and customers
  • You should not post indecent, offensive, discriminatory or defamatory content
  • Your content should respect all religious, political, economic and racial differences and opinions
  • Your content should respect others' privacy
  • Anything you state as fact must be correct and fair, and where you make mistakes, you should correct them as soon as possible.
  • Using social media in the workplace with company facilities must be in line with our standards on acceptable use.

T

Tax Evasion

This is fraud which deprives a Tax Authority of money it is entitled to. Tax Evasion is a criminal offence. In some countries it is also an offence to deliberately and dishonestly take action to help someone else evade tax.

Time and Expense Reporting

To make sure we are charging our customers properly for our efforts and they are getting what they paid for, it's vital that we maintain accurate timekeeping and expense reporting at all times. Different business units have different ways of doing this. If you have a question, ask for help. Take the time to get it right!

Trade Restrictions

We will comply with national and international restrictions on Trade and Exports/Imports and all legitimate sanctions and boycotts. However, we do not comply with illegal sanctions, and will not engage in prohibited or restrictive trade practices. Sometimes this can result in a legal conflict, in which case you should always seek legal advice by referring the matter through your division's General Council or Commercial Lead for a resolution.

We will comply with legitimate special trade restrictions. For example, in some countries there are laws covering the transfer of equipment, software, services or technology to a foreign country or foreign person. These can include potential transfers to other parts of Serco, and can even apply to any foreign nationals working on our team.

Travel

Follow our Travel Standard and use Serco Travel when travelling on Serco business, and always keep proper records and receipts for any travel expenses you claim.

U

V

Values

Trust

We work hard to earn trust and respect. We deliver on our promises; are open, straightforward and honest; do the right thing; and take personal responsibility for getting things done.

Care

We care deeply about the services we provide, the communities we serve, and we look after each other. We work together to deliver high-quality public services, often of great importance to the nation and the communities we serve. We take care of each other, and those we serve, and we aim to make a positive difference to people’s lives.

Innovation

We aspire to be better than anyone else at what we do. We continuously improve our ways of working, and try new ideas, big and small. We share our knowledge and experience and embrace change, knowing that if we don’t provide innovation and value for money to our customers, our competitors will.

Pride

We want to be proud of what we do. We know that the work we do is important, and we take pride in doing it well. We value energy and enthusiasm, skill and experience, and an ability to make hard work fun. We contribute both as individuals and as part of a team.

Violence

Violence isn't just physical violence. It is any behaviour that makes someone else feel threatened. Examples of violence include: verbal abuse, offensive language, racist or sexist remarks, threatening to do harm, or physical attacks, including spitting and throwing objects.

W

X

Y

You

When Our Code refers to "You" that doesn't mean some people don't have to comply. "You" means all of us, whatever job we do at Serco. It also includes everyone who works with us in a full time, part time or temporary job, and all the contractors we work with around the world.

We are also determined to only work with partners, third parties and customers whose standards are consistent with ours.

Z

Zero Harm

Zero Harm is our vision of achieving a workplace where no one comes to harm because of the work we do.