SLM 3.05.01
Issue 2
A Nuclear Management Partners company operated under contract to the NDA
TheSellafield Ltd
Code of Responsible Business Conduct
Our commitment and our values
Integrity
Learning Safety
Respect
People
Commitment
SLM 3.05.01
Issue 2
SLM 3.05.01
Issue 2
A message from the Board of Directors
Our reputation with our community, customers, regulators and the general
public is essential to the long term success of Sellafield Ltd.
To protect and enhance our reputation the achievement of consistently high
standards of integrity, honesty and personal commitment to act in accordance
with our values is crucial.
Our company vision is focussed on ‘safe, sustainable, world class
performance and transparent partnering with all stakeholders’. To deliver this
aspiration we must set out and be committed to high ethical and operational
standards in all that we do. Our values are completely aligned to achieving
this.
This Code of Responsible Business Conduct (the Code) sets out the minimum
personal and professional standards that we should adopt and provides
guidance to achieve these requirements. Management, Unions and staff at all
levels in the organisation have contributed to the production of this Code.
The content is based on the knowledge and skills of our people and in
particular draws on the real life experience of dealing with complex and
difficult issues. Consequently, it has real relevance to what we do every day.
Our business very often sets stricter standards than those in the outside world
and our values depend on each of us taking the responsibility to do the right
things in our daily endeavours.
We would encourage everyone in the business to take time to read the Code
to learn from the experiences of others and to avoid errors that harm the
reputation of the business and/or ourselves.
In particular it is important to remember that Safety (and especially nuclear
safety) must be at the heart of everything we do.
Please take the time to read this Code and work with your colleagues to find
ways of continuously improving our practices.
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Table of Contents
Message from the Board of Directors
1. Overview of the Code of Responsible Business Conduct
a.
b.
c.
d.
e.
f.
g.
h
i.
Our Code of Responsible Business Conduct
Everyone is responsible, everyone is accountable
Supporting our mission
Living our values
Doing the right thing:
understanding responsible business conduct
Enforcement and discipline
Asking questions and getting help
Our expectations for leaders and managers
How to use this guide
8
8
8
9
10
11
11
12
12
2. Safety, health the environment and quality
a.
b.
c.
d.
Safety
Environment
Health
Quality
14
15
15
15
3. Responsible personal conduct
a.
b.
c.
d.
e.
f.
g.
h
i.
Use of Information Technology
Avoid conflicts of interest
Prohibited payments
Drugs and alcohol at work
Keeping your personal information safe
Personal security
Security and safeguards on our sites
Fraud or theft from the company
Managing information and accounts
18
20
20
22
24
24
25
26
28
4. Working together
a.
b.
c.
We promote equal opportunity and diversity
We demand a workplace that is free of any form of
harassment or bullying
Training and development
30
30
30
5. Working with our customers, the community, regulators
and contractors etc.
a.
b.
c.
d.
e.
Bribes or illegal payments
Gifts and entertainment
Political contributions
Social and environmental responsibility
Stakeholder relations
34
36
38
38
39
6. Reporting concerns
a.
b.
Page 5
Reporting concerns
List of policies
Integrity. Safety.Respect.Commitment.People.Learning.
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43
SLM 3.05.01
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1
Overview of the Code of
Responsible Business
Conduct
SLM 3.05.01
A
Issue 2
Our Code of Responsible Business Conduct
This Code is intended to guide us, as the people of Sellafield Ltd, through the
decisions that we have to make to do our jobs responsibly, safely and ethically.
We all have a duty to know what is required of us in conducting business in a
professional manner.
Knowing what is required of us in our roles is our responsibility.
B
Everyone is responsible, everyone is accountable
Everyone, including the Board of Directors, the Sellafield Ltd Executive, other
leaders, managers and employees, agency and contractor staff working on
our sites or for our business must comply with this Code. It will help guide
everyone through our expectations, providing the information that we need to
help to understand and comply with our requirements and the law.
The Code also explains what we should do if we witness behaviours that do
not align with our requirements.
C
Supporting our mission
Sellafield Ltd and its people will achieve the NDA-assigned missions
through safe, sustainable, world-class performance and open,
transparent partnering with all stakeholders to become the site and
workforce of choice for potential new missions.
By acting responsibly in business we will support our Mission and help secure
our future success. Whatever our role, our behaviour and input in executing
our strategy and raising concerns in a responsible and lawful manner is the
key to our success as an organisation.
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D
Issue 2
Living our values
We are managing one of the most challenging nuclear inventories in the world
today. To do this safely and effectively, with the trust of our customers, the
community and other stakeholders we must all act in accordance with our
values, to the highest standards and in compliance with the law.
Our values are:
Quote from
our Managing
Director
Integrity
We will do what is right
Safety
We will actively care for each others safety
Respect
We will value people as they are - their abilities,
contributions, and participation of all
Commitment
We will do what we say when we say we will do it
People
We will enable and encourage each individual to
achieve their full potential
Learning
We will create a climate of continuous learning
Our values are an important part of the way we do business. We all have a responsibility
to ensure that we live by our values and to challenge each other where we perceive that
values are not being met
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E
Issue 2
Doing the right thing: understanding
responsible business conduct
Our Code is intended to enable compliance with company policies. The law
and policy can change so it is up to each of us to ensure that we have the
latest information to hand and that we use our common sense and sound
judgement where things do not feel right.
The following simple checklist is intended to assist with decisions we need to
make each and every day:
Ask yourself:
• How would I feel if someone else was doing what I am doing or
proposing?
• Would I be concerned if my actions were being scrutinised?
• If the media published details on what I am doing would I be
comfortable about explaining it?
• Would I be comfortable explaining the details to NMP or NDA?
• How would I feel if my family and friends examined my actions?
• Am I setting a good example to others?
• Should I be consulting with colleagues with specialist knowledge or
insight? Would they do what I am proposing?
• Would my actions call my or the company’s integrity into question?
Even the appearance of a conflict between your personal interest and the
interest of the company or another stakeholder could have a negative impact
on how we are viewed by the public and the company. With regard to the
relationship with the NDA it is important to recognise that this is governed by a
complex range of contractual obligations.
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F
Issue 2
Enforcement and discipline
The expectations and behaviours outlined in the Code, and contained in our
existing Policies and Procedures, are key to the continued success of our
business and our position in the local community. Where breaches occur, the
relevant policies will be enforced. Non-compliance with our policies is always
taken seriously by Sellafield Ltd.
All failures to meet the high standards that are required by our company
policies, or the legal requirements within which we all operate, are always of
concern.
Any formally investigated and confirmed breach of policy or procedure does
have the potential to result in disciplinary action against employees. This
could result in a range of sanctions, up to and including dismissal, or for nonemployees of Sellafield Ltd it may result in permanent removal from the sites
we operate.
It continues to be a requirement that everyone should co-operate fully with
any internal investigations being carried out in relation to suspected breaches
of our Company Policy and Procedures or non-adherence with the Code of
Responsible Business Conduct.
G
Asking questions and getting help
The right answer is sometimes hard to find. Not everything is black and white.
Sometimes grey areas and outside circumstances require us to look hard at
the facts and make decisions that test the limits of our prior experiences.
Always ask for input. Help is just a phone call away!
• While you can start with any of the people listed here, we encourage you
to first talk with your line manager. Whenever possible, you should discuss
your question with your line manager. Try to work together to resolve your
concern or decide if you need additional help
• Alternatively: Speak with your Union representative
• Call the Sellafield Ltd external helpline, a confidential, and if required
anonymous helpline to report concerns. This is known as Safecall. The
Safecall number is 0800 915 1571 or email [email protected]
• Contact Human Resources, Legal Services or Internal Audit
• Contact the Compliance Officer (see below)
For more specific guidance on ethical conduct or on the implementation of our
Code, the Office of the Managing Director has appointed a Compliance Officer
who can be contacted on any aspect of this Code and will be able to provide
further guidance and assistance as well as a route for approving certain
activities where this is required.
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H
Issue 2
Our expectations for leaders and managers
Whilst this Code sets out our expectations of everyone, we place a higher
expectation on those who lead and manage to set and demonstrate high
standards and to provide help and support to others in the workplace.
We expect those who supervise others to set high standards in promoting our
values and thereby enabling compliance with this Code. This includes:
• Living and communicating our Code.
• H
elping those being supervised to understand their responsibilities under
the Code.
• Protecting the health and welfare of everyone.
• Communicating clear expectations.
• Behaving ethically and with integrity in everything that you do.
• Monitoring compliance with and enforcing the Code consistently.
• Cultivating a learning and questioning environment.
• Enabling individuals to do the right thing.
I
Talking Point
How to use this guide
Throughout this guide you will see a number of ‘talking points’ included.
These are aimed at highlighting situations that you may be faced with or need
to think about. The approach or action you should take is then outlined in
terms of whether you should STOP, TAKE CARE or PROCEED.
Where you see this symbol there is more information available on the
intranet to support the area of the Code being referred to.
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Issue 2
2
Safety, health, the
environment and quality
Our overriding business priorities are to ensure nuclear
safety and leave the lightest possible footprint on the
environment. We all have a personal accountability to
deliver this.
SLM 3.05.01
A
Issue 2
Safety
Safety is a corporate value for Sellafield Ltd and is the priority for everything
that we do. We share a responsibility to continuously improve our safety
performance.
We will set demanding standards for safety and environmental care in nuclear
clean-up. The vigorous application of our safety principles and fundamentals is
key to delivering these standards.
Our safety principles
We believe:
• A
ll events or incidents leading to injury, and occupational illnesses are
preventable.
• S
afety is everyone’s personal responsibility and it is delivered through
personal ownership and action.
• M
anagers are accountable for leading by example, clearly setting direction
and demanding the highest standards.
• E
xcellence in safety requires working together with our employees,
contractors, suppliers and customers.
• G
ood safety is good business, and continuous improvement is essential to
our success.
Our safety fundamentals
We will:
• N
ot compromise on our standards and expectations, holding everyone
accountable for safe and environmentally responsible behaviour.
• C
ommunicate, celebrate and share success, show pride in our successful
safety performance and act on learning.
• M
ake nuclear safety our priority, without compromising the highest
standards of radiological safety, conventional health and safety and
protection of the environment.
• A
pply fit-for-purpose safety systems which actively support and innovate
our clean-up mission and other business activities.
• B
e firm in our beliefs, seek to understand alternative views, but stand our
ground when necessary to agree optimum solutions.
• Earn and maintain the respect and trust of people who work with us, the
public and other stakeholders.
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B
Issue 2
Environment
Together we work hard to minimise the environmental impact of our operations
across all areas of on-site activity. We engage with our stakeholders and
seek the widest possible approval of how we manage our environmental
responsibilities, including the application of our Integrated Waste Strategy.
It is our goal to continually improve global environmental performance by:
• Eliminating accidents and incidents.
• Minimising waste and the use of natural resources.
• Ensuring that all wastes are managed safely and with care for the
environment.
• Sharing and using best practice.
• Meeting or exceeding current standards of environment, health and safety
performance.
Environmental Policy
Health and Safety Policy
Nuclear Safety Policy
C
Health
The health and safety of employees and everybody that works with us is vitally
important. We will take a proactive stance to continuously improve our health
and safety performance across the business. We aim to maintain a fit and
healthy workforce by:
• Eliminating ill-health at work.
• Maintaining radiation doses at As Low As Reasonably Practicable (ALARP).
• Encouraging our employees to have a balanced lifestyle and maintaining a
healthy work/life balance.
• Learning lessons from events, implementing corrective actions and seeking
out and using good practice.
D
Quality
Our customers demand high standards from us and we strive to enhance their
satisfaction through continuous improvement, operational excellence and
delivery of high quality products and services.
Quality Policy
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Talking Point
1. I have only been with Sellafield Ltd a short time but I have worked
on other sites. The safety rules at Sellafield seem to be tougher
than where I have worked before. Surely if I know what I am doing
and I know it is safe then I do not need to follow all the guidance for
Sellafield?
STOP:
You must follow all Sellafield Ltd Safety processes. Sellafield Ltd is proud
of its safety culture and record. We strive to be world class and to achieve
this we need to focus on safety in all that we do. However, if you believe
that there are ways of improving systems or processes then speak with
your supervisor or manager. There is always scope to learn and continuous
improvement is critical to achieving our goals.
2. When at work I know I have a duty to promote safe working and to
challenge inappropriate/unsafe behaviours. However I am concerned
that if I make comments to my colleagues this could come across as
interfering or even worse as harassing them. What is the right thing
to do?
TAKE CARE:
The way you challenge behaviours is important. Do so in a constructive,
sensitive and helpful way and we expect your colleagues to respond
in kind. Peer observation is a great way to improve safety culture and
awareness. Challenging unsafe behaviours will prevent accidents and can
even save lives. Where serious safety breaches are observed we have a
duty to report these for the benefit of all.
3. I work in a controlled area and I am pregnant. I want to tell someone
at work as I am a little worried about the possible health affects of
not saying anything, even though I have only just found out about the
pregnancy; however I do not want anyone else to know just yet. What
should I do?
PROCEED:
It is in the interests of you and your unborn child to inform the company
as soon as possible so that we can take the appropriate measures to
control your working conditions. You can contact the Occupational Health
Department in confidence and the medical team will provide further advice
and support.
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3
Responsible personal
conduct
As an individual we have a responsibility to know what
is required of us in conducting business in a professional
manner
SLM 3.05.01
A
Issue 2
Use of Information Technology
Everyone should be very careful when using IT systems including creating
email, voicemail, instant or text messages. Disciplined use of IT is required
to prevent disclosure, loss, theft, damage, careless or unauthorised use of
physical assets and information.
• A
ll information and data inputted onto company systems becomes company
property.
• E
ngage only in limited personal use of company systems and only if
that use is not contrary to the Sellafield Ltd Business Information and
Technology policy and guidance.
• D
o not violate copyright or trademark rights, using unlicensed software,
making unauthorised copies, or making defamatory or discriminatory
statements while using Sellafield Ltd information systems and technology.
• Internet usage must be reasonable and in line with company guidelines.
The use of gambling sites is strictly prohibited.
• C
ompany systems must not be used to download or otherwise view
sexually explicit or otherwise offensive content. This is strictly prohibited.
Information Management Policy
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Talking Point
1. I have an account with a social networking site and I use it to keep in
touch with my friends and colleagues. While I am at work I regularly
check my account and update it with details of what I am doing or
what is going on in the business.
STOP:
You must not use company IT systems or company time for social
networking and you must not use social networking sites to post
unauthorised details of the company or its activities online. You may not
think that what you are saying is sensitive but it could be, or could be
misunderstood, leading to inadvertent damage to the company reputation.
Be aware that email from a company account may be construed as the
official position of the company.
2. I have agreed with HR that I can operate a small business in my own
time that is nothing to do with the company. In order to do this I
sometimes need to access the internet; make calls or send emails
during office hours. Can I use company IT systems to do this?
STOP:
Although you may have permission to operate your business in your own
time, this does not entitle you to use company resources, even outside
working hours, to support your business.
3. Sometimes, whilst at work, I will use the internet to browse the web.
This is mostly in my lunch break and my manager does not object.
Am I doing anything wrong?
So long as your manager has approved it; your use is reasonable and does
not interfere with your work, and you do not access inappropriate websites
then this is acceptable.
PROCEED:
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B
Issue 2
Avoid conflict of interest
Conflicts of interest can occur in a wide range of common business situations.
You need to think carefully about your actions and assess whether a potential
conflict exists. If you are concerned that your actions could be viewed as
creating a conflict between your personal interests and the company then, you
should check with a member of management or Human Resources. Some
examples are shown below.
Outside employment
You may not, without company consent, work as an employee, consultant
or in any other capacity, with any other business or organisation (including
volunteer activities).
Use of company resources
You may not, without company consent, use the name, logo, proprietary
information, office space, facilities, staff, vehicles, telephones, computers,
supplies or any other resources or equipment operated by Sellafield Ltd in
connection with outside employment, business activities or for personal gain.
Financial interests
You may not, without company consent, either directly or through an
immediate family member, have a financial interest in any other business,
organisation or activity that may be affected by your actions and decisions
whilst working at Sellafield Ltd.
Personal relationships at work
Your close personal relationships should never improperly influence your
decisions at work. You should not be working in a position where you
could influence the salary or performance review decisions about a family
member or a romantic partner. Also, if you have a close personal relationship
with another person, you should not be able to assign, review, approve or
somehow affect the work of that person. If your circumstances change and
you find yourself in a position where you gain a close personal relationship
with another person then you must notify Human Resources and/or your line
manager immediately. You should never informally share company information
with relatives or friends who work in the supply chain or with our customer.
C
Prohibited payments
All payments must be made in accordance with the Delegated Powers of
Financial Authority. You may not take or approve any action that will require
payment from corporate funds if such expenditure is not authorised or
reimbursable under company processes.
Finance Policy
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Issue 2
Talking Point
1. I have recently started a new relationship with an individual within
my department who reports to me. They are very competent and
deserving of a promotion. Am I okay to promote them?
STOP:
There is potential for a perceived conflict of interest. This does not mean
the individual should not be promoted but the decision ought to be made
by an independent manager. You should also discuss with HR whether it is
appropriate to continue to act as line manager for this individual.
2. My husband holds a position with a supplier where he will gain a
bonus from his employer in relation to additional business being
awarded to them by Sellafield Ltd. Although I have no say in who we
order from, the department does use the product. Do I need to tell
anyone?
TAKE CARE:
Although you may feel that you are not directly influencing the business
that could be awarded to the supplier, if your husband secures his bonus
based on increased sales then it could be said you have a direct financial
interest. Sellafield Ltd is unlikely to object to your husband supplying to
our sites in these circumstances but if you declare your interest you can be
confident that the company is aware of, and consents to, this in the event
that any questions are ever asked. It is also important for the company
and your manager to know so there is no possibility you could fall within a
position where you make, recommend, or in any way influence the decision
whether to award work to your spouses’ employer.
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D
Issue 2
Drugs and alcohol at work
We all need to be alert and fit for work if we are to deliver the demanding
standards of safety which Sellafield Ltd requires. The use of alcohol or any
other drugs, including prescription medicines, must not impair our ability to
work safely and make sound judgements. Attending work when unfit due to
drugs or alcohol can have serious consequences for ourselves, our colleagues
or our community so we must take care to ensure that any consumption, even
outside working hours, does not affect our ability to do our jobs competently
and safely. This means all employees and contractors must comply with and
enforce a strict policy on the misuse of alcohol and drugs. We recognise that
this policy is supported by the random and “for cause” testing programme for
drugs and alcohol.
Some medicines contain alcohol or can impair our ability to do our jobs. You
should carefully check the advice leaflets provided by the manufacturers of
their products. If you are still in doubt seek guidance and approval from the
Occupational Health Department prior to use or before reporting for work
having taken them.
You must not bring illegal drugs or alcoholic beverages onto any of the
Company’s sites, including satellite sites. Sellafield Ltd will not tolerate the
possession or use of prohibited substances, which includes the possession or
consumption of alcoholic beverages and illegal drugs in the workplace and will
conduct searches of company premises if we have reason to believe that such
substances are present on the premises. Any substances found as a result of
a search will be confiscated and disciplinary action will be considered.
Substance Abuse Policy
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Issue 2
Talking Point
1. Sometimes my colleagues and I go out for a meal at lunchtimes to
celebrate a special occasion or to socialise. Is it okay to have a pint
of beer or a glass of wine with lunch?
STOP:
You should not drink alcohol if you are returning to work. You should bear
in mind that random and for cause testing is carried out on our sites.
2. Sometimes I travel with work either for training or meetings off site.
On occasion we stay overnight. When I do I often drink alcohol in the
evenings either with my meal or at the bar. Is this acceptable?
TAKE CARE:
Moderate alcohol taken with a meal is reasonable. If you are travelling
with work you are expected to behave appropriately at all times.
Excessive drinking during the evening whilst representing the company
on a residential training course, conference or business dinners is not
acceptable behaviour.
3. I often go out into my local town at weekends and I have seen some
of the people I work with on the site also in town. Although I am not
sure I think that they may be using drugs. I am worried because
although they do not seem to be under the influence when on site
they do work with heavy machinery. Should I say anything?
PROCEED:
Yes you should, this is a genuine concern and should be reported. You can
do this in confidence if you wish, for example, through Safecall. It is better
to raise your concern even if you are incorrect as the abuse of drugs can
have serious consequences both to the individuals concerned and others
on and off the site.
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E
Issue 2
Keeping personal information safe
Sellafield Ltd keeps certain personal records for every employee including
HR and medical information. These records must be kept strictly confidential
and Sellafield Ltd is committed to ensuring this. Personal information will only
be disclosed for legitimate, need-to-know, business purposes or as required
by law. If we have access to any information that may be of a sensitive or
confidential nature, we must treat the information as our own and safeguard
its confidentiality.
Information Management Policy
F
Personal security
We all need to feel that Sellafield Ltd sites are safe and secure places to work.
To prevent losses, secure personal and company valuables at all times. Do
not leave bags or equipment unattended in an unsecured location. Always
place valuables out of sight. You should also take special care when travelling
offsite.
Violent behaviour and or any sort of offensive weapons even if related to
sports activities, are prohibited on our premises.
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G
Issue 2
Security and safeguards on our sites
Sellafield Ltd is committed to the physical security of its sites, the nuclear
materials and the information contained on or about them. We all have a duty
to:• M
anage security issues responsibly. This will help prevent a terrorist act or
theft of nuclear material.
• P
rotect the sensitive information contained in documents and the
knowledge that we hold.
• B
e careful about where documents or electronic devices eg. approved USB
sticks, BlackBerry’s are left.
• Avoid conversations about work in public.
• A
lways wear and display our company pass while on site. This must be
removed when you are no longer on site.
• A
lways lock your computer when away from your desk for any length of
time – you have access to data which others should not have access to.
• Manage documents in accordance with their security marking.
• Promote an effective security culture.
• F
ollow company and local security arrangements in respect of keys,
workplace (eg. desks, filing cabinets) security.
Security Policy
Safeguards Policy
Talking Point
1. I have been contacted by a trade journal who informed me that
they like to send promotional material to senior managers in the
business. They told me that if I provided some names, addresses
and job descriptions to them they would reimburse me for my time
and that this could be a few hundred pounds. Can I take the money
even if I donate it to a local charity?
STOP:
You must never provide personal details or even role descriptions if you
are not authorised to do so and certainly not in return for personal gain.
Report this caller immediately to HR and/or Security.
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H
Issue 2
Fraud or theft from the company
We all have a responsibility to detect and prevent fraud or theft from the
company. Whether there are concerns about our colleagues or our suppliers,
we must act to prevent corrupt and unlawful practices. Examples of theft or
fraud are diverse but should all be taken seriously.
They include:
• T
aking of company equipment (tools, stationery, software) for personal use
or resale.
• F
alsifying accounts or records to divert funds for personal use or to achieve
personal gain.
• Assisting suppliers to divert goods intended for our sites.
• H
aving personal work done or making personal purchases on the company
account.
It is also critically important that you:
• D
o not allow or facilitate the creation of undisclosed or unrecorded funds for
any purpose.
• Never place any company funds in any personal or non-corporate account.
• N
ever attempt to influence, coerce, mislead or interfere with the auditing of
company financial systems or processes.
Immediately report concerns or violations regarding accounting, internal
controls or auditing matters.
Sellafield Fraud/Anti-Bribery/Corruption Policy
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Issue 2
Talking Point
1. I am in a management role and as part of my duties I am required to
sign off the expenses and timesheets of my team. I believe some
of the hours and amounts claimed are excessive but I did not really
know how to resolve these so just approved everything. Nobody has
ever questioned me about it though.
STOP:
If you have any suspicions that this type of activity is taking place then you
must not approve the records and you should seek for the advice. It is
your duty to report any such activity you believe may be fraudulent under
the Fraud Prevention Policy so that an appropriate investigation can be
undertaken.
2. From time to time I take work home with me and sometimes I will take
some stationery items with me. I have pens, pads of paper, files and
other items. Can I get into trouble for this?
TAKE CARE:
Taking stationery items home with you in moderation is acceptable where
it is supporting you in carrying out your work. However, it is important
not to abuse this trust and to act with honesty and integrity at all times in
relation to all company property. Any taking for purely personal reasons is
unacceptable.
3. I work for a supplier to the Sellafield site. I have recently noticed
that a number of items are being ordered where there is not a high
demand for them to be used on site. More of these items are being
ordered but it is not clear where they are going but the costs are
being charged to Sellafield Ltd. What can I do?
TAKE CARE:
You have a duty to report fraud, either criminal behaviour and violations of
the code that you reasonable suspect. This example suggest just such a
reasonable suspicion. We value your honesty and integrity and encourage
you to contact us by calling the Office of the Managing Director at Sellafield
Ltd and asking to be put through to the Compliance Officer.
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I
Issue 2
Managing information and accounts
Always prepare business documents and records honestly and accurately.
Documents and records should be retained in a way that allows efficient
retrieval whenever necessary. Please read and follow our Records Retention
Schedule.
You should:
• Never make a false or misleading entry in a company report or record.
• Never tamper with, manipulate, alter, remove or destroy original records
before the end of the applicable retention period.
• Never knowingly alter, destroy, or conceal any record or document, or
attempt to do so, in order to impair the record’s integrity or availability for
use in an official proceeding.
• Never sell, transfer or dispose of company assets without proper
documentation and authorization.
• Always consider the value of documents before destroying them.
We maintain company accounts with the highest degree of accuracy and
integrity protecting trade secrets, intellectual property and confidential
information. We must protect all confidential information including processes,
software and methodologies developed by the company or entrusted to
the company by others. Information not generally available to the public is
confidential. All such confidential information must be safeguarded.
Information Management Policy
Finance Policy
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Issue 2
4
Working together
As we work with colleagues we have a responsibility
to know what is required of us in conducting
business in a professional manner
SLM 3.05.01
A
Issue 2
We promote equal opportunity and diversity
Sellafield Ltd is committed to making all employment decisions based only
on merit to ensure we have the best people working alongside us. When
involved in selection, promotion or transfer we must ensure employment
decisions are not based upon personal attributes such as race, colour, gender,
religion, national origin, disability, age, sexual orientation, gender identity or
marital status.
B
We demand a workplace that is free of any form of
harassment or bullying
Everyone has a right to be treated with dignity and respect. We will not
tolerate harassment or bullying in any aspect of company business.
The Dignity at Work policy provides guidance on what is unacceptable and
what to do if you are affected by bullying and harassment. Unacceptable
behaviours include: making derogatory or obscene remarks, jokes or
innuendo; unwelcome sexual attention; humiliating or ridiculing someone or
being offensive, abusive or insulting.
C
Training and development
We recognise that an ongoing programme of education and training is the
cornerstone of a sustainable business. We should all ensure that we have
considered our development goals and that we achieve and support others in
achieving our full potential. We should remember to utilise all elements of the
PMA process, which is designed to help address these issues including equal
opportunities, special needs and harassment.
Training Policy
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Issue 2
Talking Point
1. I work in a plant environment and have recently noticed that when I
come into the work area people start talking amongst themselves and
they do not speak to me. I am sure they are saying things about me.
I do not know why but when I ask people they just say that I am being
too sensitive and should not worry about it. I feel as if I am being left
out. When they go to lunch they do not invite me and occasionally
I have heard some comments about people who are no fun. I think
they mean me.
STOP:
Even though nothing has been said directly to you if this indirect behaviour
is causing you to feel intimidated it ought to be resolved. You should
report this in line with the equal opportunities policy. Options that you might
consider for further help and support could include contacting Safecall or
speaking in confidence to your HR Business Partner. If you feel that the
matter has still not been resolved, speak to your manager to make it clear
that behaviour of this type, if it amounts to bullying or harassment, will not
be tolerated and must stop.
2. Whilst at work I have witnessed a supervisor making remarks about
the sexual orientation of another member of the team, sometimes
directly to them. I think that this is being said lightly, but it
sometimes seems to me that there is a more concerning undertone.
Should I do something?
TAKE CARE:
Responsible behaviour does mean checking on the welfare of others
and unlawful discrimination will not be tolerated. You could ask your
team member whether they are uncomfortable with the remarks. Other
options that you might consider for further help and support could include
contacting Safecall or speaking in confidence to your HR Business Partner.
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Issue 2
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5
Working with our customers,
the community, regulators
and contractors etc
As we work with others we have a responsibility to
know what is required of us in conducting business
in a professional manner
SLM 3.05.01
A
Issue 2
Bribes or illegal payments
We strive to deliver our business objectives fairly and honestly. We never
give or accept bribes, illegal payments or other improper means to influence
anyone’s judgement about our business. Improper means can include gifts or
entertainment, including to third parties, not just cash payments so extreme
caution is required in the conduct of all business dealings.
Employees involved in procurement have a special responsibility to adhere
to principles of fair competition in the purchase of products and services by
selecting suppliers based exclusively on normal commercial considerations
such as quality, cost, availability, service and reputation and not on the receipt
of special favours.
We will not act on information we receive about companies with whom we do
business. Buying or selling shares in a company based on inside knowledge
is illegal.
We must comply with anti-corruption laws including the UK Bribery Act, the
U.S. Foreign Corrupt Practices Act and the EU Directive on Anti-Bribery.
These laws prohibit improper payments to any government official, political
party or candidate to obtain or retain business to facilitate an action, or other
improper advantage.
Sellafield Ltd will not tolerate bribes or illegal payments. The company will
ensure that it has in place adequate procedures to prevent bribery and other
corrupt practices.
Sellafield Fraud/Anti-Bribery/Corruption Policy
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Issue 2
Talking Point
1. I am part of an internal process evaluating tenders submitted to the
company. I certainly would never accept any payment or gift from a
tenderer, but I do campaign strongly for a local charity that does a lot
of good work in Cumbria. One of the tenderers told me privately that
they would be making a significant donation to the charity.
STOP:
Bribery and corruption can include payments to third parties not just to you
or the company. If this payment is being made to influence your decision
then it is illegal and must be reported in accordance with our Code and
policy.
2. I am a Contract Officer managing a framework contract on the
Sellafield site. There are several suppliers under the framework. One
of the suppliers is undertaking work and has submitted requests for
payment on an hourly rate basis that exceed the current budget. They
have offered to complete the work and waive these additional costs.
However there is a large package of work that they are aware of that
is still to be awarded that I know they want. How should I proceed?
TAKE CARE:
It is appropriate to seek best value and good time management from a
contractor and where possible hold them to agreed costs. However if
the payment appears genuine you must be absolutely certain of their
motivation for the waiver of those costs. If they are expecting; demanding
or even intimating there could be further work in return for the waiver then
this may amount to an illegal offer and should be reported in accordance
with this Code. If it is a genuine saving without any obligations e.g. to
promote good business practices then it should not be of concern.
3. Sellafield Ltd often entertains UK and international officials at its sites
to increase awareness of the company and the issues we face. Is this
still acceptable?
PROCEED:
Sellafield Ltd is not seeking to influence decision making in return for
payments, merely to explain the issues and challenges we face. Providing
we act in accordance with our Code and the law then such visits are
perfectly acceptable. You should consult with the legal services or
Compliance Officer for a determination of acceptability.
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SLM 3.05.01
B
Issue 2
Gifts and entertainment
Gifts with a nominal value and appropriate entertainment can help build
business relationships. However, whether given or received, gifts and
entertainment should never improperly influence any business decisions and
should never be accepted where they could, or could be seen to, influence a
business decision e.g. during a procurement process.
Gifts or entertainment must only ever be accepted where doing so would
support the business interests of Sellafield Ltd and will not damage the
reputation of the company, its owners or customers.
Gift and entertainment guidelines:
• You may accept or give inexpensive gifts of a promotional nature e.g. diaries,
pens, calendars etc or gifts with a nominal value e.g. chocolates or flowers.
• It is not permissible to accept or provide any other gifts above a nominal
value. All such gifts, whether given or received, must be declared to the
company through the Conduct Compliance Officer.
• Meals or drinks received in the normal course of business are acceptable
provided that they are reasonable and up to a value of £50 per person
per event providing there is a genuine business benefit and no conflict of
interest.
• Meals or drinks given in the normal course of business, including with the
NDA, are acceptable provided that they are reasonable and up to a value
of £50 per person per event providing there is a genuine business benefit.
Any expenditure above this sum, or any formal entertainment, must be
approved in advance by the relevant business area Director. There is no
sub-delegation of this authority.
• Gifts of cash or cash equivalents (such as gift certificates, loans, shares etc.)
are expressly prohibited under all circumstances.
• Any offer of value to attend a social function or sporting event requires the
express prior consent of the company. Initially, consent is by the accountable
Senior Manager. Should Senior Manager consent be given, this will
subsequently be reviewed by the Conduct Compliance Officer (see below).
• For attendance at major sporting events, other corporate social events,
and supply chain non-charity social events the presumption should be that
attendance is not appropriate except where an over-riding business need is
identified and that is approved by the relevant Board Director or the Sellafield
Ltd Managing Director).
• Immediate family members may not give a gift, nor accept a gift connected
with your work.
• Understand and respect the gifts and entertainment policies of our business
partners, suppliers and vendors and do not create situations that may violate
those policies.
• No gifts or entertainment must ever be given to government employees or
elected officials without prior approval. In all such cases this approval is
jointly by the Director, Stakeholder Relations in conjunction with the Conduct
Compliance Officer.
cont.
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Issue 2
• The Company supports charity events and employees may accept invitations
up to a nominal value of £50, as above. Employees are reminded that they
attend as private individuals and that charitable donations, refreshments
above those provided by the inviting organisation, transport, overnight
accommodation, and any other incidental expenses etc. are personal and
are not to be claimed back from Sellafield Ltd.
Managerial approval, together with details of the gift/event/entertainment
offered or taken, must be communicated to the Conduct Compliance Officer
for review.
The Conduct Compliance Officer can be contacted via email: Responsible
Business [email protected], or by telephone on +44 (0)19467
81738.
The Conduct Compliance Officer has absolute discretion to approve or reject
any requests for gifts or entertainment and, in line with the requirements of
the UK Bribery Act 2010 and our own Sellafield Ltd Conduct and Compliance
Policy, shall retain a log of all such requests which can be audited and if
necessary used as evidence.
Talking Point
1. I have been invited to a dinner by one of our suppliers. The dinner is in
London and they have offered to pay for the meal, my travel expenses
and an overnight stay. I do a lot of work with the supplier and I believe
that spending some time with them at a social occasion will enhance
our working relationship and promote effective partnering. I believe
that the event will add value and I propose to attend.
STOP:
Attendance at this event is not acceptable on these terms. Sellafield Ltd
will determine what events are in our interests for employees to attend.
Normally you will be requested to attend by Sellafield Ltd if it is in our
interests. Any other invitations and an estimate of costs should be lodged
with the Conduct Compliance Officer for a decision.
2. I have been engaging with the NDA on a particular transaction and
during the course of our discussions off site we have occasionally
paid for lunches. Sometimes I pay on behalf of Sellafield Ltd,
sometimes the NDA pays. I had not really thought about this before
but now wonder whether it is appropriate to buy NDA representatives
lunch.
TAKE CARE:
Generally this is acceptable. We have a close working relationship with the
NDA and from time to time we will take meals or drinks together. Providing
there is a business interest and it is ultimately paid by NDA (either directly
or as a reimbursment under the M&O contract), and the value is both
reasonable and less than £50 per occasion then there is no requirement
to seek specific consent. You should give some thought to ensuring that
overall the balance of costs is neutral between NDA and SLC. Exercise
caution if there is any suggestion of additional work or funding for the
business that could result in enhanced fee income etc. However, do not
forget that, should the engagement be with elected officials (including local
or national government employees) this must be approved in advance as
already set out above.
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SLM 3.05.01
C
Issue 2
Political contributions
Sellafield Ltd does not lobby or make political contributions and no contributions
should be made in its name. We recognise that employees may engage in
political activity in their own time, but company time, assets and facilities may
not be used for employee political activity.
D
Social and environmental responsibility
Sellafield Ltd shall wherever possible promote sustainable development and
the responsible use of resources including encouraging the supply chain to
participate in socio-economic development and targeting improvements to
programme delivery particularly where local benefits are derived from the supply
chain.
We shall actively encourage responsible citizenship and we are encouraged
to volunteer our time to legitimate community, educational, charitable, civic or
other non-profit organisations, however this work must not interfere with our job
responsibilities, conflict with the company’s interests, or reflect negatively upon
the company’s reputation.
Any request to join the board of a company, or where there may be a conflict of
interest must be disclosed to the company.
When in work we should all consider the environmental impact of the actions
we take. Whilst in many cases in our business this may involve a radiological
hazard or risk to the environment we also have a responsibility to consider the
way in which we use energy and natural resources.
Socio Economic Policy
Supply Chain Management Policy
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SLM 3.05.01
E
Issue 2
Stakeholder relations
From time to time we may be contacted whilst in work by the media. Sellafield
Ltd has a dedicated team to respond to such inquiries and we should not
interact with the media without the prior approval of this team. If we are
contacted, we should refer the request to our media relations team.
Be aware that attendance at conferences or other events can bring attention
to the company, NMP and NDA, and consideration should be given to advising
the media relations team of such events. The Sellafield Ltd, NMP and NDA
corporate identities are important assets and along with other information
about the company requires control to ensure that we do not damage their
reputations. Advice on corporate identity and information going outside the
company can be sought from Stakeholder Relations and Security.
Brand Management Policy
Supply Chain Management Policy
Stakeholder Engagement Policy
Socio Economic Policy
Talking Point
1. I am very interested in local politics. During the local elections
I canvass on behalf of my party. I am very keen to support my
community and to have a say in local politics. My concern though
is that lots of people in my area know that I work at Sellafield for the
company.
PROCEED:
Even though people know where you work, providing you are clear that your
views are not those of the company, and providing you do not bring your
campaigning activities onto our sites or do so during work time or with work
resources, then you can continue.
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Issue 2
6
Reporting concerns
•Be accountable
•Be responsible and act on matters of concern
•Expect others to be accountable for their actions
SLM 3.05.01
A
Issue 2
Reporting concerns
If you know of or suspect an unsafe or unethical practice; a breach of the
law; a breach of our Code or our policies you are responsible for reporting it
immediately. Your report should be made in “good faith” meaning that you
are providing all the information you have and that you believe it is true. Your
reporting obligation also applies to situations involving non-employees, such
as the supply chain, agents, vendors, independent contractors and wherever
else you may have a concern that impacts the company.
Generally, the first place to raise concerns should be with management;
however we recognise that you may not feel comfortable discussing concerns,
particularly serious concerns with your direct line manager so if the disclosure
is extremely serious or in any way involves your management you can report
it directly to your trade union representative, Legal Services or a member of
the Board or Executive team. Do bear in mind that different concerns you may
have may be best dealt with by specialists, for example safety concerns can
be raised with Safety Representatives or local Safety Advisers. If you wish to
report matters outside the company you should use the dedicated confidential
reporting facility set up specifically for this purpose. The facility, known as
Safecall, is an external service manned by independent advisers who treat
reports confidentially.
The Safecall number is 0800 915 1571 or email [email protected]. A
link can be found on the homepage of the intranet.
For further information you can refer to the Reporting of Concerns at Work
policy, which provides information on reporting concerns and on how the law
and company will support you.
• F
ailure to report breaches is never appropriate and is itself a breach of our
Code. Also, any delay in reporting could substantially increase the risk of
safety, legal and/or financial exposure.
• Y
ou can make reports anonymously. Maintaining anonymity may limit our
ability to investigate an incident. In all cases, reports will be treated as
confidentially as possible.
Sellafield Ltd will not tolerate victimisation or retaliation against anyone for
reporting in good faith, breaches of the law, company policy or our Code.
Any acts of retaliation or victimisation against employees raising good faith
concerns will be subject to disciplinary action. If you believe that you have
experienced any form of retaliation as a result of raising a good faith concern,
you should report it to a supervisor, a Human Resources representative or the
Head of Legal Services.
Reporting of Concerns (Whistleblowing) Policy
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Issue 2
Code Of Responsible Business Conduct
List of policies referred to in this code:
SLCP 2.11.01
Environment
SLCP 2.04.01
Health and Safety
SLCP 2.01.01
Nuclear Safety
SLCP 2.15.01
Quality
SLCP 2.01.01
Security
SLCP 2.12.01
Safeguards
SLCP 4.02.01
Training
SLCP 4.04.01
Finance
SLCP 4.04.02
Fraud Prevention, Anti-Bribery and Corruption
SLCP 4.06.01
Supply Chain Management
SLCP 4.08.01
Brand Management
SLCP 4.08.03
Stakeholder Engagement
SLCP 4.08.05
Socio Economic
SLCP 4.09.02
Information Management
SLCP 14
Reporting Concerns (Whistleblowing)
SLCP 4.03.01
Substance Abuse
Remember - always check the Sellafield Ltd Management System on the
Intranet for the current versions of these (and other) policy documents
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Issue 2
A Nuclear Management Partners company operated under contract to the NDA
Sellafield Site, Seascale, Cumbria, CA20 1PG UK
www.sellafieldsites.com