Ethics Code

Message from Chief Executive Officer

At Clece Care Services Ltd, we take great pride in the way we conduct our business and our contributions to the communities in which we live and work. We also take great pride in our culture of integrity and high ethical standards which are central to how we do business. We employ more than 7,500 staff across the UK.

Our Code of ethics explains the core standards and policies under which we operate. It describes how we should conduct ourselves in the workplace and marketplace and recognises our commitment to the environment and communities in which we operate. It also describes how each of us should handle various legal and ethical matters.

Our suppliers and contractors are also required to comply with key elements of the Code through our Supplier Charter.

Please take the time to read this Code, understand it and use it to guide you in your work. This will help us ensure all our actions are in the best interests of our organisation and our customers. If you have any questions about the Code and its application, you should speak to your line manager who may in turn refer this to the Head of Quality & Compliance or the Head of Legal.

I also urge you to raise concerns and report any situations where you believe the Code may have been breached. Retaliation against anyone who speaks up will not be tolerated.

Our behaviour defines our reputation. I am confident that together we will ensure we continue to meet the high standards expected of a leading company with the care community.

Our business values

We are committed to achieving our business goals in an open, honest, ethical and principled way. Doing business with integrity is embedded in our culture and we strive to do the right thing. We:

seek to support the United Nations Global Compact, a voluntary corporate responsibility initiative intended to protect human rights, encourage fair and non-discriminatory employment practices, promote the care of the environment and eliminate corruption, wherever possible; and
strive to do business with customers, suppliers and stakeholders who operate ethically and align with our values of inclusion and diversity.

We are committed to complying with all applicable laws and regulations.

Our commitments

We will

hold everyone to the same standards of behaviour, regardless of their position within the organisation;
provide policies, training and resources to guide the organisation and our staff;
enable a culture where people feel comfortable to ask questions, speak up and report concerns;
listen to concerns that may be raised and act on them in a fair and timely manner; and
ensure there is no retaliation for raising concerns.

Our Code of ethics

This Code of ethics aims to help you understand and follow the basic ethics and compliance rules that apply to your role. It also provides guidance on when and how to raise questions or concerns. It applies to every member of staff working for any of our businesses.

The Code reflects our commitment to act ethically and legally. It does not describe every law and policy that might apply to every situation and you must follow any additional business/compliance policies that apply to you.

You are responsible for reading and complying with the Code and performing your work ethically. If you breach the Code or other policies, you may be subject to disciplinary action, including summary dismissal. We also may refer serious matters to public authorities for possible prosecution.

You should raise questions about the Code with your line manager who may in turn refer this to the Head of Quality & Compliance or the Head of Legal. It is usually best to raise questions about specific situations as they arise and before taking action that potentially might breach any applicable law, this Code or another company policy.

This Code is non-contractual and does not form part of your employment contract. We reserve the right to vary and revise it at any time. The Directors are responsible for the final interpretation of the Code.

Your responsibilities

You must:

read this Code of ethics and understand how it applies to your role;
follow the compliance and ethics rules described in the Code;
be aware of and follow additional policies and laws that apply to your specific business, location or role;
ask questions if you are not sure how the Code applies to a particular situation or decision that you are facing; and
report any breaches or suspected breaches you believe may have occurred.

By reading and following the Code, raising questions and reporting any illegal or unethical conduct, you are helping us to abide by our high ethical standards and our commitment to comply with the law.

If you are a people manager, you must also:

demonstrate ethical behaviour and decision-making;
make sure the people you manage are aware of the existence of this Code and understand their responsibilities under it;
exercise proper oversight of business activities;
ensure your team members complete all required ethics and compliance training;
be approachable and open to team members and colleagues reporting concerns;
listen to and act promptly on reports of concerns; and
never retaliate against someone for reporting a concern.

Reporting concerns

We investigate suspected breaches of the Code promptly and take appropriate remedial actions when breaches are discovered. This is important to protect staff, preserve our reputation, and avoid legal exposure.

If you know or suspect anyone has breached the Code or otherwise acted unethically or illegally, it is important that you report your concerns promptly via our whistleblowing or grievance policy (as appropriate). You also may report breaches through our confidential line as set out in our Whistleblwoing Policy.

It is important to report breaches regardless of the identity or position of the person involved.

We prefer you to identify yourself if you report a suspected breach. However, we recognise that in some cases you may feel it necessary to remain anonymous and our reporting system allows you to report concerns anonymously. We will not disclose the identity of anyone who reports a suspected breach or who participates in a related investigation unless:

the person submitting the report authorises disclosure;
disclosure is required by law; or
disclosure is necessary to properly investigate the matter.

Retaliation in any form against an individual who genuinely believes a breach of the Code or law may have occurred and reports it, even if the report is mistaken, or who assists in the investigation of a reported breach, is itself a breach of the Code. Any member of staff responsible for any such retaliation will be subject to disciplinary action, including termination.