Ethics

In line with our values and the expectations of our customers and partners, we are committed to conducting all our interactions with all our stakeholders with integrity, high ethical and moral standards, and professionalism.

Code of Ethics

Our Code of Ethics applies to everybody working for or on behalf of FirstGroup and is supported by detailed policies and procedures which apply across the Group, including our Code of Conduct on Anti- Slavery & Human Trafficking Prevention and our Anti-Bribery Policy. Our Code sets out the standards which our customers and stakeholders expect of us, and which we expect of each other.

Code of Ethics

Human Rights and Modern Slavery

We are committed to recognising and preventing human rights breaches including modern slavery, human trafficking and child labour in all its forms and are committed to recognising human rights on a global basis. We have a zero-tolerance approach to any violations within our company or by business partners and suppliers.

We are committed to the prevention of modern slavery and human trafficking in all its forms, which extends to all business dealings and transactions in which we are involved, regardless of location or sector. Our Group-wide Modern Slavery Statement outlines our commitments and progress and is updated on an annual basis. It includes details on reporting and management include a Confidential reporting hotline.

Our Supplier Code of Conduct outlines our expectations from suppliers including a zero tolerance towards any violations.

FirstGroup Modern Slavery Statement

Supplier Code of Conduct

Whistleblowing

We have a whistleblowing policy and an externally managed whistleblowing service for colleagues available across the Group with a helpline (online and phone‑based) for the anonymous reporting of suspected wrongdoing, bribery, corruption or dangers at work.

The hotline is actively communicated to colleagues via a number of channels, as well as being available via the Code of Ethics and other policy and training materials.

All reported issues or concerns to the hotline are taken seriously and structures are in place to process reports and, where appropriate, investigate concerns and implement necessary mitigating steps, ensuring that confidentiality is respected at all times.

The Board also receives reports on the operation of and any matters reported to this whistleblowing hotline.

FirstGroup Whistleblowing Hotline

Whistleblowing External Policy Statement

Anti-Bribery and corruption

We base our business relationships on transparency, trust and accountability. We have a zero-tolerance approach to bribery, and never offer or accept any form of payment or incentive intended to improperly influence a business decision. We publish an internal Bribery Policy that applies across the Group and include this in our Code of Ethics to which all colleagues must attest on an annual basis.

The Group’s Anti-bribery Steering Committee has the primary and day-to-day responsibility to ensure that our internal control systems and procedures are effective in countering bribery and corruption.

We have a zero-tolerance approach to fraud, bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings. We expect our suppliers to undertake their work with a similar zero-tolerance approach. This is outlined in the Supplier Code of Conduct that all suppliers must sign. This Code outlines the expectations that suppliers must adhere to all laws, implement and enforce effective systems, ensure ethical tax strategies, and not accept bribes.

Anti-bribery and Corruption statement

Suppliers Fraud, Bribery and Corruption

Fraud

Fraud is any act of dishonesty or deception intended for personal gain or to harm the interests of others. This can include theft, tax evasion, misuse of company resources or false accounting. Fraud, in all its forms, is dishonest and criminal and will not be tolerated by FirstGroup.

We are committed to conducting all business activities in an honest and ethical way, and this is only possible if every employee, and all those we do business with, act with honesty and integrity. We have a Group-wide Fraud Policy and include Fraud in our Code of Ethics and Supplier Code of Conduct, both codes must be signed by all employees and suppliers respectively.

Fraud statement

Suppliers Fraud, Bribery and Corruption

Gifts and hospitality

Offering or accepting modest gifts or hospitality is an important part of building business relationships. However, gifts or hospitality should never affect, or appear to affect, business decisions. Our Group-wide Gifts and Hospitality Policy outlines clear guidelines for employees on what is and is not acceptable and the reporting and approval procedures. Gifts and Hospitality forms part of our Code of Ethics and must be attested to by all employees on an annual basis.

Gifts and Hospitality statement

Competition laws

Competition laws exist in all our markets, and breaking these laws, even unknowingly, may mean significant penalties and disruptive investigations for companies and individuals. Breaches also damage our reputation as a business, and erode the trust our customers have in us. Our customers should be confident that FirstGroup has earned their business and acted independently and fairly when proposing pricing and services. We support free and open competition. We gain competitive advantage by providing the highest level of service, not through unethical or illegal business practices.

We require all employees to attest to the Code of Conduct that includes a section on Competition Laws. This document outlines the expectations and requirements of employees and where to report suspected breaches including a Confidential Hotline. We also publish an internal Competition Laws Policy that applies Group-wide.

Our Supplier Code of Conduct must be signed by all suppliers and includes a section on fair competition and trade. The Code requires suppliers to be committed to fair competition and must conduct their business in line with all relevant antitrust laws, competition laws or related regulations. Suppliers must adhere to all international trade regulations and export control regulations.

Competition Laws Statement

Suppliers Fair Competition and Trade

Insider dealing

Insider trading can distort markets and is illegal. Our investors rely on our continued openness and honesty, so there are serious repercussions for breaching the rules. We all have a responsibility to know and abide by the law on insider dealing. We require all employees to sign the Code of Conduct that includes a section on insider dealing and have an Insider Dealing Policy. We also have our own Share Dealing Code which applies to certain individuals and imposes additional obligations.

Insider Dealing Statement

Political activity

As a business, we engage with public bodies and government at all levels on a variety of issues. We must be able to demonstrate a political neutrality and willingness to work with elected representatives from any mainstream party, to provide services to the local community. We require all employees to sign a Code of Conduct that includes information on political activities and have an internal Political Activity Policy.

Political Activity Statement

Freedom of association

We believe that our success depends on trust and respect for each other. This includes respecting both the right of our employees to join a trade/ labor union of their choice and the right not to join a union at all. We are committed to respecting our employees’ freedom of association. These rights are outlined in our Code of Ethics, signed by all employees, and our Trade/ Labour Unions Policy that applies Group-wide.

Our Supplier Code of Conduct also outlines the requirements regarding freedom of association. Suppliers must recognise the rights of workers to choose whether or not to be represented by a trade union and to organise and engage in union activities. Where workers’ representation and collective bargaining are restricted by law, suppliers should facilitate open communication and direct engagement between workers and management to ensure that workers’ rights, needs and views can be considered and acted upon.

Political Activity Statement

Suppliers Freedom of Association

Tax strategy

The tax we pay is an important part of our wider economic and social impact and plays a key role in the development of the countries where we operate. We regard it as a critical element of our commitment to grow in a sustainable, responsible and socially inclusive way. Our tax strategy outlines our commitment to managing our tax affairs in a way that sustainably benefits the customers and communities we serve.

In addition, we also outline our expectations of suppliers regarding tax in our Supplier Code of Conduct. This includes requirements that suppliers must not ask or encourage a FirstGroup employee to engage in a relationship with them which could result in the reduction or diversion of any taxes from any relevant authority. Suppliers must not engage in any form of facilitating tax evasion, nor aid, abet, counsel or procure the commission of a tax evasion offence by another person. All suppliers must sign and comply with the Code.

FirstGroup Tax Strategy

Suppliers Fraud, Bribery and Corruption

Discrimination, bullying and harassment

Behaviour that makes someone feel intimidated, degraded, humiliated or offended has no place in our workplace. Harassment or bullying of anyone, particularly on the grounds of race, colour, religion, age, gender, disability, national origin or sexual orientation is completely unacceptable and will not be tolerated. We therefore take a zero-tolerance approach to bullying and harassment. Our Code of Conduct outlines our expectations for colleagues, to which all employees must attest.

Equally we expect our suppliers to adhere to the same standards. Our Supplier Code of Conduct, that applies to all suppliers, ensures that there is no discrimination, no harsh or inhumane treatment, no abuse and that workers have clearly defined procedures and a confidential whistleblowing procedure.

Employees Discrimination, Bullying and Harassment

Suppliers Discrimination, Bullying and Harassment

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