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Insider trading toolbox


Our policies, procedures and other resources

Group policies are available on our website and can be viewed here.

These policies and supporting procedures form the Serco Management System (SMS). The SMS sets out for each policy area requirements by role so you can understand what is expected of you. It also provides supporting procedures and related documents. 

Access to these documents is for Serco colleagues only and you will need to log into myserco to access them. If you have problems accessing them, please request a copy from your manager.

You can access the following here:

  • Group Policy Statement

    • Governance, Legal & Assurance

  • Function policy

    • Insider Information and Share Dealing

  • Guidance

    • Share Dealing Code



The period of at least 30 days before release of relevant interim and full year results. A notification is sent to Restricted Persons setting out the start and end of a closed period.

Any publicly traded or quoted shares or debt instruments of Serco Group plc (or of any of the Company’s subsidiaries or subsidiary undertakings) or derivatives or other financial instruments linked to any of them.

Anyone conducting any transaction on his or her own account or for the account of a third party, directly or indirectly, relating to Company Securities or on the price of related derivatives.

Information of a precise nature, which has not been made public, relating, directly or indirectly, to the Company or any Company Securities, and which, if it were made public, would be likely to have a significant effect on the price of any Company Securities. 

The UK version of the EU Market Abuse Regulation (596/2014).

Means any employee considered by the Company to have ongoing access to confidential and/or Inside Information as part of their day-to-day role.

If you're a manager

  • Never act on or disclose confidential and/or inside information or encourage another person to deal in any company's shares on the basis of it, even if they do not directly profit.

  • Abide by the Financial Conduct Authority's Disclosure Rules when dealing in Serco's stocks and shares. This includes specific restrictions if you have inside information.

  • Ensure those have potential access to insider information get written approval before trading in Company shares.

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Bribery and corruption

We never take or offer any kind of bribe.

Gifts and hospitality

We always check before giving or receiving any gift or hospitality.

Conflicts of interest

We always declare any potential conflict of interest. If we’re not sure, we ask.

Working with communities

We support and respect the communities we work among.

Political activities and payments

We keep our relationships with government honest.

Competition and antitrust

We always compete fairly and openly.

Working with others

We deal fairly and honestly with suppliers, strategic partners and agents, and expect the same of them.

Trade sanctions and export controls

We take care to know and follow the rules.

Accurate records, reporting and accounting

We always maintain accurate records, reports and accounts.

Tax evasion

We never do it, or help anyone else to.

Money laundering

We will not take part in any money laundering activity, and do all we can to stop it.