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May 2021 1 SSP Code of Conduct
May 2021
1
SSP Code of Conduct
May 2021
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Contents
SSP Group Values 2
What is a Code of Conduct? 2
Who does the Code Apply to? 2
Duties of Supervisors and Managers 2
What about different laws in different countries? 3
Who can you talk to? 3
Helpline 3
Specific Provisions
Health and Safety 5
Environment 6
Harassment Free Work Environment 7
Personal Information 8
Protection and Proper Use of SSP Property 9
Use of SSP Information Technology 10
SSP Company Information 11
Brand/Business Partner Information 12
Accurate Reporting 13
Giving and Receiving Gifts and Entertainment 14
Working with Suppliers 17
Conflicts of Interest 19
Money Laundering 21
Bribery and Corruption 22
Facilitation Payments 25
Political Activity 26
Competition 27
Prevention of the Criminal Facilitation of Tax Evasion 28
Modern Slavery & Forced Labour 30
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SSP Group Values
SSP enjoys an excellent reputation with customers, suppliers, brand partners and local
governing bodies which has been built up by consistently delivering high standards of
service and adhering to key SSP Group values.
The cornerstone of these principles is that SSP will conduct its affairs and manage the
business in compliance with all applicable laws and regulations whilst ensuring that
high standards of integrity, ethics and business practices are adhered to.
What is a code of conduct?
The SSP Code of Conduct is a summary of the principles and standards that are
expected of all employees regardless of where they work.
It provides guidance on how to identify and deal with important ethical issues together
with instructions about where to find more detailed information or who to approach to
ask for advice.
It does not describe every law or situation that you will be faced with. At times you
may be faced with a situation that you are not sure how to resolve, in these
circumstances the code should be used as reference to help you get an idea of where to
find additional help or advice.
The code does not replace your individual responsibility to use common sense and to
exercise good judgement to ensure that your conduct does not damage the reputation of
SSP.
Who does the code of conduct apply to?
The code applies to everyone in SSP including employees, officers and directors.
The code is compulsory and shall be followed regardless of where in the world you
operate or are located.
Each Employee should read and become familiar with this code. A copy of this code
can be found on Connections and in each building where there are SSP employees.
Failure to comply with the code is taken very seriously and may result in disciplinary
action being taken against you.
Duties of supervisors and managers
Those who supervise or manage other employees also have additional responsibilities
under the code which include:
• Ensuring that the code is understood by those who report to them
• Providing guidance as to how to meet the code’s requirements
• Promoting compliance with the code by setting a strong personal example
• Monitoring the compliance and ethics of the people they supervise
• Enforcing the code consistently
• Supporting employees who raise questions or concerns
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What about laws in different countries?
SSP operates in numerous locations around the world which results in our employees
being subject to the local laws and regulations of many different countries. SSP is fully
committed to following and obeying the different laws in each of these countries.
Each individual is responsible for understanding and following the local laws in their
country. In situations where the local law is lower than the standard set out in the code
you must always follow the higher standard set out in the code. If you are in any doubt
seek guidance from your Manager.
Who can you talk to?
If you become aware of any situation, have information or knowledge regarding an
incident that you believe is a breach of the code you must report this to your Manager.
If you do come across an issue that you are not sure about or that just seems wrong to
you please raise it. It is important that you do not turn a blind eye and choose to ignore
the situation.
Ask yourself some basic key questions:
• Does it sound right?
• Does it comply with the code?
• Would you feel embarrassed if you explained the situation to your colleagues,
family or friends?
• What would you think if you read about it in a newspaper?
• Does it expose SSP to any unacceptable risk?
• Is it legal?
You can always discuss a situation and obtain further advice from:
• HR
• SSP Legal
• Whistleblowing/Speak Up Helpline
Whistleblowing/Speak Up Helpline
A helpline is available if you feel unsure about where best to seek advice or if you are
uncomfortable about speaking about a matter to one of the people identified in the code.
The helpline is independently operated with all calls being dealt with in the strictest of
confidence by specially trained operators. Calls can be made anonymously, but if you
are happy to give your name it may help to speed up the investigation of any concerns.
The freephone helpline operates 24 hours a day, 7 days a week (except 25 December)
and is available to all employees, regardless of their location or role within SSP.
The helpline can be used to:
• obtain further advice on ethical issues
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• discuss any concerns you may have in relation to compliance with the code
• discuss specific instances where you believe that our ethical standards or
possibly even the law may have been broken
If you wish to call the helpline the contact telephone numbers are set out below. If you
have any difficulties with contacting the helpline (or your country is not listed below)
you should refer to your country’s HR department for contact details.
SSP operates a strict policy against any retaliation aimed at an individual who raises a
concern in good faith. All allegations of retaliation will be thoroughly investigated and
may result in disciplinary action being taken.
May 2021
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SSP WHISTLEBLOWING HELPLINE
You can report an incident by calling the relevant number below or online at
www.sspgroup.ethicspoint.com
Please note that colleagues in Finland and Qatar are only able to report online at present.
Country: Telephone Number: Country: Telephone Number:
Austria 0800 068792 Hong Kong 800 906 570
Belgium 0800 75 973 Hungary (80) 088 414
Brazil 08005917317 Israel 1-809-399-883
Canada (833) 646-0064 Luxembourg 800 24 602
China 400 120 0201 Netherlands 0800 3510049
Cyprus 80 077008 Spain 900 999 456
Egypt 0800 006 0184 Sweden 020- 12 70 17
Estonia 8000 100 861 Switzerland 0800 223 029
France 0 800 99 07 62 Taiwan 00801-49-1615
Germany 0800 1817635 Thailand 1800014586
Greece 800 848 1585 United States (833) 646-0064
The below countries require 2 stage dialling. Follow these steps to report an incident:
1. Dial the phone number for your country.
2. When prompted, enter the call number 833 646 0064.
3. You will then be transferred to one of our communication specialists to handle
your report.
Country: Dial phone number: Enter Call
number:
Australia 1-800-551-155 (Optus) or 1-800-881-011
(Telstra)
(833) 646-0064
Bahrain 800-00-001 or 800-000-05 (Cellular) (833) 646-0064
Denmark 800-100-10 (833) 646-0064
India 000-117 (833) 646-0064
Ireland 00-800-222-55288 (UIFN) or 1-800-550-000 (833) 646-0064
Malaysia 1-800-80-0011 (833) 646-0064
Norway 800-190-11 (833) 646-0064
Philippines 1010-5511-00 (PLDT) or 105-11 (Globe,
Philcom, Digitel, Smart)
(833) 646-0064
Singapore 800-001-0001 (StarHub) or 800-011-1111
(Singtel)
(833) 646-0064
United Arab
Emirates
8000-021 or 8000-555-66 (du) or 8000-061
(cellular)
(833) 646-0064
United Kingdom 0-800-89-0011 (833) 646-0064
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Health and Safety
SSP is committed to ensuring that all employees are able to work in a safe and secure
environment.
It is the responsibility of every employee to ensure that the work environment that we
operate in is safe, secure and healthy. This means that every employee should:
• Comply with the requirements of the Health and Safety policy at your work
location
• Make sure you know what to do in the event of an emergency at your location
• Intervene immediately if someone is putting themselves or others at risk
• Stop any work that becomes unsafe
• Promptly report any safety risks to your Manager or appropriate Health and
Safety representative
• Help ensure that any contractors or third parties who work with you act
consistently with the Health and Safety requirements of that location
Q&A
Q: I have not been told what to do in the case of a fire at work. What should I do?
A: Ask your Manager or Health and Safety representative to fully explain the procedure
that needs to be followed in the event of an emergency
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Environment
SSP recognises that the operation of any business no matter how large or small can have
an impact on the surrounding environment.
SSP is committed to minimising any negative effects that its business may have on the
environment and wherever possible preventing environmental damage. This is achieved
by efficiently managing the use of resources whilst seeking to minimise the production
of waste.
SSP together with all employees will seek to minimise the impact that its business
operations have on the environment by:
• Promoting a policy of recycling both internally and to third party suppliers,
business partners and customers
• Reducing the consumption of resources and improving the efficient use of those
resources, for example by transport planning or turning off computers/electrical
equipment when not in use
• Reducing the impact of disposing of waste materials and ensuring that disposal
methods are as efficient as possible
• As a minimum complying with and where possible exceeding all environmental
legislation that relates to the company
• Ensuring that environmental considerations and relevant criteria are taken into
account in the procurement of goods and services
• Continuously seeking to improve environmental policy and practice within the
company to ensure that procedures remain relevant
• Encouraging third party suppliers, contractors and business partners to follow
SSP in adopting high levels of environmental compliance and best practice
SSP will also work with employees to educate them on environmental issues with a
view to helping employees conduct their everyday activities within the company in an
environmentally responsible manner.
If you become aware of any actions or damage that may cause an adverse impact on the
environment you should discuss this with your Manager.
Q&A
Q: SSP is a large company. How can I make a difference to the impact that its business
operations have on the environment?
A: If we all as individuals conduct our everyday work activities at SSP in an
environmentally responsible way (for example by avoiding unnecessary business travel
and recycling whenever possible), our collective actions will help to minimise any
negative affects the business may have on the environment.
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Harassment Free Work Environment
Every employee has the right to be fairly treated and receive courtesy from others in
the workplace. No employee should have to suffer abuse or harassment of any nature
in the workplace.
This is an issue that SSP takes very seriously and will not under any circumstances
tolerate:
• Any form of sexual harassment (i.e. unwelcome sexual advances, repeated
sexual suggestions or physical contact)
• Any other form of harassment that creates an intimidating workplace
environment (i.e. bullying or pressurising others to engage in practices to fit in)
• The making of religious, racial, ethnic, age related or sexual jokes/insults
• Any action that is degrading or results in the humiliation of another person
• Any action that injures another person
• The distribution of any offensive material
This list is not exhaustive, but a number of examples. Should you feel that somebody
is acting in an abusive, inappropriate or harassing manner it should be raised with your
Manager.
Q&A
Q: The culture in my department is very aggressive with one colleague being constantly
picked on by other members of the department. After trying to raise this issue I was told
to ignore it or otherwise I could become the next target. Who should I contact?
A: You should be concerned about this type of behaviour and you should speak with
your Manager to resolve the issue. If this is not successful you should seek advice from
your HR department.
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Personal Information
SSP is committed to respecting the confidentiality of all employees’ personal
information and ensuring that when such data is handled it is done so in accordance
with all applicable local data protection laws and regulations.
Confidentiality is achieved and maintained by:
• Restricting access to personal data to only employees with both appropriate
authorisation and a legitimate business need
• Ensuring those employees who have access to personal data only use it for
legitimate business purposes and adhere to strict standards of confidentiality
No employee should try to gain access to personal data if they do not have both the
appropriate authorisation and a legitimate reason for seeking access.
Personal data should never be supplied to anyone inside or outside of SSP without the
proper authorisation being first obtained.
Q&A
Q: I have received a phone call from a stranger who has asked me to help them make
contact with an employee who works at SSP. They have asked me to provide the address
of the employee so that they can surprise them by sending a birthday card. Should I
provide them with this information?
A: No, you should never provide personal information under these circumstances. You
should refer the caller on to the HR department.
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Protection and Proper Use of SSP Property
All employees are responsible for ensuring that the SSP property that they use or come
into contact with whilst carrying out their duties at work is not damaged, misused or
wasted.
Employees can achieve this by:
• Only using equipment for its correct purpose
• Ensuring that equipment is regularly maintained and serviced
• Safely securing the equipment when it is not in use
• Promptly reporting any abuse of equipment by others
Any personal use of SSP equipment must be occasional and insignificant in terms of
both cost and time. It should not interfere with the business requirements of SSP.
Any act by an employee that involves theft, fraud or misappropriation of any SSP
company property is prohibited and will lead to disciplinary action being taken against
you.
Q&A
Q: A friend has asked me if I could use the facilities in the office to design and print
invitations to a party. They will need approximately 200 invitations; I will work on this
only during my lunch breaks. Am I allowed to do this?
A: No, excessive personal use of SSP property is not allowed. Despite the fact that you
intend to use your lunch breaks to undertake this task it will still be a misuse of SSP
property and equipment.
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Use of SSP Information Technology
IT equipment is intended to be used by employees for work and business functions only.
The equipment may also be used for occasional, limited personal use provided that such
use does not interfere with your productivity whilst at work or the business
requirements of SSP.
Examples of acceptable personal use of the IT facilities are:
• Accessing news or weather sites on the internet
• Accessing personal banking sites on the internet
Employees should never use the IT facilities to deliberately access, send, publish or
store:
• Any material that promotes terrorism, hatred, intolerance or violence towards
others
• Any material that is pornographic or sexually explicit
• Any material that is obscene or abusive
• Any other material that could damage the reputation of SSP
Inappropriate use of the IT facilities can expose the IT systems to security risks that
could have a dramatic impact on the business operations of SSP. To ensure that these
security risks are minimised employees should:
• Never use SSP’s IT facilities to visit inappropriate internet sites
• Never install unauthorised software onto any SSP IT facility
• Never copy or use software without the appropriate software licence being
obtained
In the event that you receive inappropriate material (e.g. by receiving email spam) from
an external sender please delete the email. If the problem persists and you continue to
receive spam email please contact your IT department for further assistance.
SSP may monitor the use of both its IT and communication facilities by employees to
ensure compliance with company policies. If any prohibited material is found or
identified on IT facilities it may lead to disciplinary action being taken against you.
Q&A
Q: To access a website required for work I need to install some additional software that
I can download from the internet. Am I allowed to download this software?
A: No, you should never personally install software onto the company network or a
company computer. There may also be issues in relation to the license required to
download and use this software, you should contact your IT department for further
assistance.
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SSP Information Security
At SSP we create information that is valuable to the business on a daily basis. This
information may be classed as confidential information and it is important that every
employee ensures that this information is protected from individuals or organisations
not authorised to access or use it.
Examples of the information that must be protected include:
• Trademarks or copyrights (or any other form of intellectual property)
• Research and customer insight surveys
• Marketing strategies
• Business development activities
• New product development
• Supplier cost prices
• Sales databases
• Financial performance statements
• Personal information relating to customers and employees.
To protect this information all employees should ensure that they:
• Never disclose any confidential information to any third party without first
obtaining their Manager’s approval
• Only disclose information to third parties outside of the company on a need to
know basis. This information should be disclosed as part of an established
confidential relationship or under a specific confidentiality agreement that
governs the use of the information
• Do not send commercially sensitive data via unsecure applications and/or
networks, e.g. using personal email accounts over public Wifi.
• Secure electronic devices, e.g. laptops, tablets, smartphones through the use of
strong passwords or PINs.
• Do not work with or leave unattended any confidential information in a location
that is not secure or where it may be viewed by others (e.g. whilst on a train)
• Do not discuss any confidential information in a public location where the
conversation could be overheard by others
• Operate a clear desk policy, ensuring that at the end of the day all office papers
are put in desk drawers or filing cabinets
• Alert IT Support if it is suspected that confidential data has been obtained or
accessed without authorisation.
Q&A
Q: A former employee who has recently left SSP has contacted me to ask if I could
send across copies of some documents that we worked on together whilst they were
working at SSP. What should I do, is it ok to send these documents to them?
A: No, these documents are likely to contain confidential information that belongs to
SSP. This information should be protected from use by third parties even if that person
previously used to work for SSP.
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Brand/Business Partner Information
Due to the nature of the business that we operate it is likely that employees will handle
confidential information belonging to brand and/or business partners.
SSP recognises that any improper or unauthorised use of a brand or business partner’s
confidential information could damage the reputation, operational or financial
performance of that brand/business partner.
Each employee has a responsibility to:
• Treat any brand or business partner’s confidential information with the same
level of care as they would with any of SSP’s own confidential information
• Not to show or discuss the confidential information with anyone unless you are
certain that they have the appropriate authority to receive the information
• Not to work with or leave unattended any confidential information in a location
that is not secure and where it may be viewed by others
• Not to discuss any confidential information in a public location where the
conversation could be overheard by others
The unauthorised use of a brand or business partner’s confidential information or
intellectual property could be very damaging to the reputation of SSP and may result in
legal action being taken against the company.
To guard against this, employees should never use or copy or disclose information that
is owned by any other party unless they have obtained the express permission of that
other party to do so.
Q&A
Q: Whilst waiting for the train I bumped into a member of my department who is
working on the same marketing plans for a current franchise partner as me. They began
to discuss a confidential document that we received from the franchise partner over the
weekend. There were not many people around was this ok?
A: No, you should not be discussing this information in a public place. Even if you
think you are being discrete you could still be overheard. Such conversations should
take place in a suitable location in the office.
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Accurate Reporting
As a global publicly listed company, to ensure that SSP operates efficiently it is
important that information (both financial and non-financial) is reported in a manner
that is:
• Prompt
• Accurate, objective and honest
• In accordance with local requirements and procedures
It is the responsibility of every employee to ensure that all transactions, hours worked,
expenses claimed or any other aspect of the business is recorded in a manner that
accurately reflects the transaction or events.
Failure to accurately record information may:
• Damage SSP’s reputation
• Expose both the company and individual concerned to legal action
Employees should never:
• Deliberately make any false or misleading entry in any report, record or claim
• Commit SSP to any contractual obligations which are beyond the scope of your
authority
• Sell, transfer or dispose of assets without first obtaining the proper authorisation
and completing supporting documentation
Q&A
Q: It is the last week of our annual reporting period and my boss has asked me to ignore
processing some very significant invoices so that we achieve our figures for the year.
Should I do this?
A: No, you should accurately record the information for the correct period. It is wrong
to deliberately manipulate the performance of the company and could seriously harm
the reputation of SSP.
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Giving and Receiving Entertainment or Gifts
During the cultivation of new business relationships or to build goodwill in an existing
relationship the exchange of entertainment or gifts can take place and is usually a
legitimate contribution to building good business relationships. However, in some
circumstances this could be disproportionate and be seen to create a level of improper
influence, or in extreme cases be seen as a bribe.
This could have a huge impact on SSP’s reputation for operating with the highest
standards of honesty and integrity and may even result in local laws being broken.
The scope of entertainment and gifts is incredibly broad and can include:
• Tickets to events
• Meals at restaurants
• Baskets of food or alcohol
• Gift vouchers
• Holidays/use of vacation facilities
The giving and receiving of entertainment and gifts fall into three basic categories:
1. Entertainment and/or gifts that are never acceptable under any circumstances
2. Entertainment and/or gifts that are acceptable under a self approval test
3. Entertainment and/or gifts that may be acceptable but will require prior
approval
1. Gifts and entertainment that are never acceptable
Some gifts or entertainment should never be given or accepted under any
circumstances.
Some examples include:
• Cash or any cash equivalent (e.g. shares or share options)
• Any gift or entertainment that would be illegal
• Any gift or entertainment that requires or creates a sense of obligation for
something to be given or done in return (especially the award of a contract or
business)
• Any entertainment that is indecent or sexually orientated
• Any entertainment that could adversely affect SSP’s reputation
• Actively seeking gifts and entertainment
• Offering gifts or entertainment to any foreign public official or any member of
their family
2. Gifts and entertainment that may be acceptable using the self approval test
Low value, modest gifts or entertainment can usually be accepted without the need for
prior approval by using a self approval test.
The self approval test applies basic common sense to test whether a gift or entertainment
is suitable for you to give or accept. The individual should ask themselves the following
questions:
• Would you give this gift or entertainment?
• Is the gift or entertainment occasional or is it a common event/occurrence?
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• What is the context or purpose of the gift or entertainment?
• Does it place any obligation on you?
• How would you feel if your colleagues knew that you had received the gift or
entertainment?
• Is the recipient of your gift or entertainment allowed to receive the gift or
entertainment under the relevant local law?
• Is the recipient of your gift or entertainment a government or public official?
If there is any doubt as to whether approval is required, it most likely means that you
should not be self approving the gift or entertainment, speak up and ask for advice from
your Manager.
Examples of self approved gift/entertainment:
• Occasional tickets to an event (e.g. a football match)
• Occasional meals with business partners and/or advisors
• Low value gifts such as promotional items (e.g. diaries and stationery)
3. Gifts and entertainment that may be acceptable with prior approval
It is not always the case that all gifts and entertainment will fall into either of the first
two categories and if this is the case the gift and/or entertainment will need to be
approved by your Manager.
Approval will always be required for
• Any Gift that has a value above £100 (or any lower local limit)
• Any form of Entertainment that has a value above £100 (or any lower local
limit)
• An extravagant meal that has a value above £100 (or any lower local limit)
• Any special event (e.g. tickets to the world cup final) that has a value above
£100 (or any lower local limit)
• Travel or overnight accommodation
In some departments there may be more restrictive rules relating to the giving/receiving
of gifts and entertainment. Each employee should be familiar with their department’s
rules on this topic.
What should you do if you receive a gift that is not allowed?
In the event that a gift is sent to an SSP employee and refusing or returning it would
cause offence, the gift should be promptly reported to your Manager and may where
possible:
• Be entered into a general staff pool and raffled at a later date
• Be given to charity
• Be retained by the recipient (where specific authorisation from your Manager
has been obtained)
Under no circumstances should cash or a cash equivalent (cheques etc) ever be accepted
from a third party.
Gifts and Hospitality Registers
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Each country maintains a Gifts and Hospitality Register which records applicable gifts
and hospitality given or received by SSP employees and contractors to non-SSP
employees. All employees must ensure that they provide details of any gifts and
hospitality offered (even if not accepted), given or received for inclusion on the register.
The administration of the registers is carried out at country level (including the
reporting thresholds) and if you are unsure of the process you need to follow if you
have been offered or been offered any gifts or hospitality please contact your Manager.
Q&A
Q: One of our suppliers has offered me two tickets to the World Cup Final. She can’t
accompany me, so he has told me to take a friend. Can I accept the tickets without
approval as this is the first time I have been offered tickets by this supplier?
A: Although you have not received tickets from this supplier before you should seek
prior approval before accepting this offer. This event is a special one off event and the
tickets may well have a value above that of a normal football match.
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Working with Suppliers
SSP is committed to the highest standards of product quality and business integrity in
it’s dealings with Suppliers and ensuring that working conditions in our supply chain
are safe, that employees are treated with respect and dignity, and that manufacturing
processes are environmentally and socially responsible.
SSP will only appoint and work with suppliers that operate to the same high standards
of honesty and integrity that SSP strives to achieve.
Care must be taken when appointing a supplier. Each appointment should be based on
merit and not because you find yourself in a position of conflict of interest or because
you have received or been offered a lavish or inappropriate gift or entertainment.
Employees should help suppliers to understand SSP’s code of conduct and the standards
that we expect suppliers to achieve.
Suppliers in all their activities must operate in full compliance with all applicable laws,
rules and regulations of the countries within which they operate and go beyond legal
compliance, drawing upon internationally recognised standards, in order to advance
social and environmental responsibility when providing goods and services to SSP, this
includes:
• Supplying employees with working conditions that are in compliance with all
relevant health and safety requirements
• Not discriminating against any employees due to any characteristic or condition
• Complying with all applicable environmental laws
This list is not exhaustive. If you believe that a supplier is operating in a manner that
contradicts the following principles you should raise this issue with your Manager.
Labour
Suppliers should recognise and be committed to upholding the human rights of
employees, and to treat them with dignity and respect as understood by the international
community.
Health and Safety
Suppliers should recognise that the quality of products and services, consistency of
production, and employees’ morale are enhanced by a safe and healthy work
environment.
Environmental
Suppliers should recognise that environmental responsibility is integral to producing
world class products. In manufacturing operations, adverse effects on the environment
and natural resources are to be minimised while safeguarding the health and safety of
the public.
Management System
Suppliers must adopt or establish a management system whose scope is to ensure (a)
compliance with applicable laws and regulations; (b) conformance with this code; and
(c) identification and mitigation of operational risks related to this code. It should also
facilitate continual improvement.
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Ethics
To meet social responsibilities and to achieve success in the marketplace, Suppliers and
their agents are to uphold the highest standards of ethics.
Q&A
Q: I have read a report in a local newspaper that a supplier we use has been found guilty
of illegally employing foreign workers. Should I be concerned with this article?
A: Yes, you should tell your Manager about this incident and show them the article that
you read. You can also seek advice from the SSP Group Commercial Director. It is
important to evaluate the relationships with suppliers to make sure that their activities
do not indicate a bigger problem in the way that they might operate.
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Conflicts of interest
What is a conflict of interest?
A conflict of interest occurs when an employee’s private interests (whether these be
financial, political, social or personal) interferes or appears to interfere with the interests
of SSP.
No employee must use or ever attempt to use their position within SSP to obtain any
improper personal benefit for themselves, for their family or for any other person.
All conflicts or potential conflicts of interest must be avoided or carefully managed.
They should never simply be left unresolved.
Who could find themselves in a position of conflict?
The actions of family members or close relatives may also create (or appear to create)
a conflict of interest. If you discover that a close relative works or performs services for
a competitor, customer or supplier, you must promptly notify your Manager.
A close relative is generally taken to be a spouse, partner, parent, step-parent, child,
step-child, sibling, step-sibling, nephew, niece, aunt, uncle, grandparent, grandchild and
corresponding in-laws.
The code does not cover all situations that could generate a conflict of interest. There
may be a situation that involves a different relationship, possibly between people who
are not related, that gives rise to a conflict of interest.
Examples of conflicts of interest
A conflict of interest can occur in many ways, some common examples are:
• Holding financial interests in suppliers or competitors
• Serving as a director of another company that is operated for profit
• Having a second job
• Employing a close relative
What to do if you believe a conflict of interest applies to you?
Ask yourself the question: “is there a relationship, activity or association that could
place me in a situation or make it appear that I am in a situation where two or more
interests compete and impair my ability to make an objective decision?”
If you think that you may have a conflict of interest or that it could appear that you have
a conflict of interest you must disclose this to your Manager as soon as you become
aware of it.
Failure to disclose a conflict of interest may lead to disciplinary action being taken
against you.
Serving as a director
During the time that you work at SSP you might be asked to serve on the board of
directors of another company or organisation. In some cases this could potentially give
rise to a conflict of interest. Prior to accepting any position to serve as a director of
another company (including not for profit organisations) you should always obtain
written approval of the SSP Group Finance Director.
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Q&A
Q: My partner works for a supplier who is bidding for a contract that my team is
working on. Should I let my Manager know?
A: Yes, you should let your Manager know so that they can decide how best to proceed.
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Money Laundering
What is money laundering?
Money Laundering is the process by which individuals or companies attempt to conceal
the true origin and ownership of the proceeds of illicit funds.
SSP’s position on money laundering
SSP will not assist or support money laundering activity.
Identifying money laundering
Money laundering can be very subtle and hard to spot. But by being alert to the
following areas you may help detect potential money laundering activity:
• Customers who appear to lack integrity in the manner that they do business
• Payments made in currencies other than as set out in the invoice
• Attempts to make large payments in cash
• Payments made from an account that is not normally used in the business
relationship
• Requests to make an overpayment
• Payments made by someone who is not a party to the contract (unless they have
been approved prior to the payment)
Getting to know your customers and business partners
To ensure that we only do business with third parties that operate to the high standards
of integrity that SSP expects, employees should:
• Be aware of customers’ business practices
• Discuss with customers the levels of ethical compliance that SSP expects from
them
• Not do business with any customer or business partner suspected of any
wrongdoing relating to legal compliance unless the suspicions are investigated
and resolved by SSP
These are only guidelines; you should also use your common sense when assessing the
integrity of the business practices of customers and business partners. If you have a
reason to feel uncomfortable raise your concerns with your Manager.
Q&A
Q: A customer who has overpaid has requested a refund in cash to a different bank
account made out to a different name. What should I do?
A: You should promptly seek advice from SSP legal. They will be able to give timely
legal advice to ensure that the transaction is dealt with correctly.
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Bribery and Corruption
What is Bribery?
Bribery is the offering, promising, soliciting, giving or receiving of something of
value that is intended to influence the behaviour or induce actions of an official or
other person to obtain an unfair advantage. The official or other person may be part of
a government, a public body or working within a public or private business.
SSP has conducted a thorough bribery risk assessment of all aspects of its business
and operations and has identified the following areas as vulnerable to allegations of
bribery:
• Corporate hospitality (see page 14)
• Facilitation payments (see page 25)
• Kickbacks
• Dealings with associates
• Sponsorship and charitable donations
• Political donations
This list is not exhaustive and all staff should be mindful of the general anti-bribery
principles underpinning this policy in all of their conduct and dealings on behalf of
SSP. This risk assessment will be repeated periodically and this section of the policy
will be updated accordingly in the light of any change of circumstances.
Anti-bribery laws
Bribery and corruption is against the law and many countries are actively increasing
the laws that they have to deal with it. It is now common for bribery to be illegal in a
country even if the actual act is committed in a different country.
Breaking any laws or rules that govern this area is a serious matter. If found guilty the
penalties that can be imposed can be extremely severe for both SSP as a company and
for the individuals concerned. Companies could face unlimited fines and individuals
could be sent to prison.
SSP’s position on bribery and corruption
SSP operates a strict, zero tolerance policy for all forms of bribery and corruption
within its business and expects all officers, employees and, where appropriate,
business partners to conduct themselves in accordance with this policy. It does not
matter who the recipient is, bribery at any level will not be tolerated. Even the
appearance of a breach of any anti-bribery or anti-corruption laws could have a
dramatic impact on the reputation of SSP.
In line with this strict policy SSP will:
• Never offer or make any improper payment (whether this be cash, gifts or
services) to any local or foreign public official or employee of a public body,
or to any related person or entity
• Never allow a third party to make an improper payment to be made on its
behalf
• Never offer or receive money, gifts, kickbacks (see below) or commission, in
relation to obtaining business or awarding a contract to a party
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• Never induce or attempt to induce a local or foreign public official or
employee of a public body to do something illegal
• Never “look the other way” or fail to report an improper payment
• Actively investigate all alleged offences of bribery and, if appropriate invoke
disciplinary measures and contractual sanctions against any employee or
business partner found to be involved in bribery.
SSP will periodically review the implementation of this policy in respect of its
suitability, adequacy and effectiveness and is committed to making improvements as
appropriate.
Full details of SSP’s policy on bribery and corruption is set out in the SSP Anti-
Bribery and Anti-Corruption Policy, a copy of which can be found on Connections.
Kickbacks
SSP has a zero tolerance of kickbacks. A kickback is the 'return' of an undue favour or
service rendered, an illegal secret payment made as a return for a favour. A kickback
is a bribe and the offer or receipt of any kickback is a criminal offence. A contractual
rebate, discount or refund for bulk purchasing would not normally fall within the
definition of a kickback.
SSP is committed to the highest standards of business integrity and will operate
transparently and fairly in its business dealings. A payment should never be made to a
commercial counterparty to win business or influence a business decision in SSP's
favour. Kickbacks, secret commissions and similar payments made in the course of
SSP's business are strictly prohibited.
Charitable contributions and sponsorships
Charitable contributions should not be made by or on behalf of SSP if the contribution
is or may in any way be interpreted as a means of buying influence in relation to any
situation which may have an impact on SSP's business. For example, this may be the
case if a charity is supported by a high profile individual who is, or where the charity
is, lobbying for a particular outcome which is relevant to SSP's business.
Political Donations
None of SSP or its employees shall make any form of political donation or
contribution where that donation or contribution is made as a way of obtaining an
advantage for SSP in business transactions, for example, it is linked in any way to a
tender for a government contract, the obtaining of a permit or licence, or it is designed
to influence the content or timing of legislation which could impact on the business of
SSP. A political contribution for these purposes would include any payment or
donation to a political party or organisation, either in the UK or overseas or to any
lobbyist or lobbying group or to any candidate for election to public office in the UK
or overseas.
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Raising concerns
Employees are encouraged to raise concerns or questions at the earliest possible stage
about:
• the scope and application of SSP's position on bribery and corruption
• whether any particular payment or other act may be construed as a bribe or
may be in breach of this policy
• any instance or suspicion of malpractice or any action which could be
construed as a bribe or may be a breach of this policy
Such concerns will be treated in the utmost confidence and should be raised with your
Manager in the first instance. No employee will suffer demotion, penalty or other
adverse consequences for refusing to pay bribes or refusing to participate in other
corrupt practices even if this may result in SSP losing business.
Q&A
Q: Whilst leaving a meeting with a potential new client they made a joke that they
usually decide who to give a new contract to by deciding who would give them the
biggest kickback. To make sure we win the business should I offer them a kickback?
A: No, this is a bribe and SSP does not bribe anyone in order to win business. You
should discuss this with your Manager and consider if you should be doing business
with a third party who is willing to accept bribes.
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Facilitation Payments
What is a facilitation payment?
A facilitation payment is a payment or a gift that is made (often to a governmental
official) to secure or speed up a procedure or governmental action.
An example of a situation where a facilitation payment might be suggested would be to
ensure that a license or permit is granted or to speed up the timing that it would take for
a permit to be issued.
The payment of fees that are required to be made by law (e.g. application or filing fees)
are not classed as facilitation payments.
SSP’s position on facilitation payments
SSP has a strict policy relating to facilitation payments and will:
• not make any facilitation payments
• not allow any facilitation payments to be made on its behalf by a third party
Previously, whilst working for other organisations you may have been allowed to make
facilitation payments. This is not the case at SSP; under no circumstances does SSP
allow any form of facilitation payments to be made. You should report any request for
a facilitation payment to your Manager.
Full details of SSP’s policy on facilitation payments and how to deal with any requests
for them is set out in the SSP Anti-Bribery and Anti-Corruption Policy, a copy of which
can be found on Connections.
Employee safety
In extreme situations SSP acknowledges in some countries an employee’s personal
safety could be at risk if a facilitation payment is not made. Should such a situation
arise you should not put your wellbeing at risk. Make the facilitation payment and
extract yourself from the situation. You should then immediately report the incident to
your Manager.
Action will not be taken against an employee who makes a facilitation payment because
they will be in danger if it is not made.
Q&A
Q: I was told that I could hire a local consultant to help obtain a licence that is required
from a foreign government. The consultant has asked for an upfront payment of £15,000
to ‘help move the process along’. As I have no idea what the money will be used for or
where it would be going do I need to worry about it?
A: Yes, you do need to worry about this. SSP are responsible for the actions of any
third party that is working on our behalf. You must know where the money is going and
for what purpose it is being used and you must be certain that it will not be used as a
bribe.
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Political Activity
SSP does not participate in party political activity in any country that we do business.
Lobbying
SSP does not directly participate in party politics but will engage in policy debate (by
processes such as lobbying) on subjects that concern the company and its employees.
Lobbying is a normal and acceptable practice in many countries and it can be an
important part of the legislative process. However, SSP recognises that it is important
for any lobbying to be conducted in compliance with all legal requirements. SSP are
fully committed to adhering to all lobbying laws and regulations in all regions that it
operates.
An employee who lobbies on behalf of SSP must:
• comply with all local laws and regulations that govern lobbying
• contact your Manager before any contact is made with government officials or
employees
Employee Political activity
SSP acknowledges that some of its employees may in their personal capacity make
political donations or be involved in political activities.
It is important that personal political activity is not mistaken for activities of SSP. To
achieve this all employees that are engaged in personal political activity must:
• make it clear that your views and actions are your own and not SSP’s and that
you are in no way representing SSP in the political process
• ensure that the activity does not interfere with your productivity whilst at work
or the business requirements of SSP
• ensure that the activity does not use up any company property or equipment
• speak to your Manager if you are planning to run for a position in public office
Q&A
Q: I am thinking of running for a local government office. Can I do this?
A: Generally speaking yes, SSP recognises that individuals are entitled to participate in
politics, but you must be sure that the role will not affect your ability to carry out your
duties at work. It is also important to make sure that the political role will not place you
in a position of conflict of interest.
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Competition
As SSP operates in locations around the world there is a large amount of “competition”
or “antitrust” laws that must be followed in each region. As with all other laws, SSP is
committed to ensuring that the competition laws in each region are complied with and
fully adhered to.
Being found guilty of breaking competition laws or even appearing to be connected to
anti-competitive behaviour could have a considerable impact on the reputation of SSP.
What are competition/antitrust laws?
Competition laws are intended to prevent any anti-competitive behaviour from taking
place. Anti-competitive behaviour can cover a wide range of activities but some
common examples are agreements between competitors that seek to fix prices or divide
a market. These agreements could be formal, informal, written or verbal.
All employees should be vigilant of competition issues and should never enter into
discussions with competitors about the possibility of:
• Fixing prices or terms related to prices – this also includes agreeing minimum
or maximum prices or setting pricing formulas that will be followed
• Dividing or segmenting markets, customers or territories
Breaking any competition law is a serious matter and could result in legal action being
taken against both the company and the individual employees concerned. Any
employee who is found to have engaged in any anti-competitive behaviour will face
disciplinary action being taken against them by the company and may also face criminal
investigation.
If you believe that a competitor is suggesting that you should collude with them to
implement anti-competitive behaviour you should raise this with your Manager
immediately.
Q&A
Q: A representative of another travel food operator called me and invited me to their
office in China to discuss the pricing of key products we both supply. Should I attend
this meeting?
A: No, this meeting could be considered to be an attempt to fix prices between
competitors and may result in competition laws being broken.
Prevention of the Criminal Facilitation of Tax Evasion
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All employees, associates and business partners are expected to act in a professional,
courteous and timely manner with government, local and tax authorities. In relation to
tax authorities in particular, all relevant employees are expected to:
• be open and transparent with tax authorities about the group’s tax affairs and
provide all relevant information that is reasonably necessary for those
authorities to review possible tax risks;
• work collaboratively with tax authorities to achieve early agreement on
disputed issues and certainty on a real-time basis, wherever possible;
• fully disclose any significant mistakes or issues to the relevant tax authority as
soon as practical after the issue is identified.
What is tax evasion and the facilitation of tax evasion?
Tax evasion is an offence that is committed when a person knowingly takes steps to
fraudulently reduce the amount of tax that they would otherwise have paid.
The facilitation of tax evasion is an offence that is committed when a person is
deliberately and dishonestly concerned in, or take steps with a view to, assisting another
person to evade tax.
The key element of these two offences is that the person’s or the facilitator’s actions
are dishonest, deliberate or fraudulent. You cannot commit either of these offences by
making a genuine mistake, for example if a person accidently or unknowingly evades,
or assists someone else in evading, tax. However, a person who deliberately facilitates
tax evasion is as guilty of a criminal offence as the person who evades the tax, and both
individuals will have committed criminal offences.
Failure to prevent the facilitation of tax evasion
A company is criminally liable where it fails to prevent those who act for them or on
their behalf from facilitating tax evasion. Any SSP company could be prosecuted if it
fails to have in place procedures to prevent the facilitation of tax evasion. The only
defence from prosecution is to prove that adequate procedures were in place to
prevent this crime. Therefore, as part of our procedures it is mandatory to carry
out due diligence on our key associates.
Examples of tax evasion
To help you know what to look for here are some examples of tax evasion:
• Requesting that invoices are falsified with the deliberate intention of reclaiming
VAT or other sales tax from the tax or government authority to which the person
is not genuinely entitled to
• Requesting that invoices are paid into an offshore bank account in a deliberate
attempt to evade paying tax
• Requesting to be paid by a certain company in a certain jurisdiction in a
deliberate attempt to evade certain employment taxes
• Deliberately and dishonestly failing to declare salaries or bonuses which are
paid in cash
• Deliberately failing to account for the tax due on a benefit in kind (such as the
private use of company vehicles)
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This list is not exhaustive and all staff should be mindful of the general anti-tax evasion
principles underpinning this Policy in all of their conduct and dealings on behalf of
SSP. For example, aggressive tax planning could be viewed as tax evasion in certain
circumstances.
Tax evasion laws
Tax evasion and the facilitation of tax evasion is against the law and many countries
are actively increasing the level of regulation that they have to deal with it. It is now
common for tax evasion and the facilitation of tax evasion to be illegal in a country
even if the actual act is committed in a different country.
Breaking any laws or rules that govern this area is a serious matter. If found guilty the
penalties that can be imposed can be extremely severe for both SSP as a company and
for the individuals concerned. Companies could face unlimited fines and individuals
could be sent to prison.
SSP’s policy
SSP operates a strict, zero tolerance policy for all forms of tax evasion and the
facilitation of tax evasion and expects all officers, employees and, where appropriate,
associates and business partners to conduct themselves in accordance with the SSP
Prevention of the Facilitation of Tax Evasion Policy and this Code of Conduct. It does
not matter who the recipient is, tax evasion or facilitating tax evasion at any level will
not be tolerated.
In line with this strict policy SSP will:
• carry out due diligence on its key associates;
• not engage in any activity that might lead to a breach of this section of the
Code of Conduct or the SSP Prevention of the Facilitation of Tax Evasion
Policy;
• not “look the other way” or fail to report improper behaviour; and
• actively investigate all alleged offences of tax evasion or facilitations of tax
evasion and, if appropriate invoke disciplinary measures and contractual
sanctions against any employee or business partner found to be involved.
SSP will periodically review the implementation of this Policy in respect of its
suitability, adequacy and effectiveness and is committed to making improvements as
appropriate.
Raising concerns
Employees are encouraged to raise concerns or questions at the earliest possible stage
about:
• the scope and application of the SSP Prevention of the Facilitation of Tax
Evasion Policy;
• whether any particular request or other act may be tax evasion or may be in
breach of this Policy; or
• any instance or suspicion of malpractice or any action which could be
construed as tax evasion, criminal facilitation of tax evasion or may be a
breach of the SSP policy.
Such concerns will be treated in the utmost confidence and should be raised with your
Manager in the first instance. No employee will suffer demotion, penalty or other
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adverse consequences for refusing to pay bribes or refusing to participate in other
corrupt practices even if this may result in SSP losing business.
Full details of SSP’s policy on preventing the facilitation of tax evasion are set out in
the SSP Prevention of the Facilitation of Tax Evasion Policy.
Modern Slavery & Forced Labour
As a company, we are committed to ensuring full respect for the human rights of
anyone working for us in any capacity and we take a zero tolerance approach to
modern slavery or forced labour in our business operations and supply chains.
Our Ethical Trade Code of Conduct & Human Rights Policy outlines the standards
we expect our suppliers to work towards. Our over-arching objective is that the people
who work within our business and supply chain are treated fairly and with respect.
As a company, we have a responsibility to look out for any signs of forced labour or
modern slavery, within our own colleagues, in the temporary workers we employ and
in suppliers of products but also of services like cleaning or construction.
There are a number of warning signs, which could indicate that someone is subject to
modern slavery or human trafficking. These include:
• Workers not having possession of their legal documents/no contract
• Workers sharing a home with lots of other people/not knowing their address
• Workers being transported to work at unusual times or in groups
• Workers having limited contact with their families/non-work friends
• Workers not having their own bank account
• Workers having other people speak for them
• Workers providing inconsistent information
• Workers displaying a fear of authorities
If you have any concerns about a colleague or someone employed by a
contractor or supplier being subject to forced labour, or if you have any
concerns about your personal situation, please speak to your line manager, or,
if you prefer, call the confidential employee hotline.
