Behaving ethically is an essential part of working for our Group, fundamental to how we do business and vitally important to the reputation and success of our Group. Our Code of Conduct applies to all employees and sets out our commitment to:

1

Behave ethically

2

Comply with relevant laws and regulations

3

Do the right thing

Our Code of Conduct also confirms that we respect and uphold internationally proclaimed human rights principles as specified in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work (‘ILO Convention’) and the United Nations’ Universal Declaration of Human Rights.

In addition, we have an Anti-Slavery and Human Trafficking Policy for suppliers and a separate one for employees.

Training is provided to all employees on issues of modern slavery in conjunction with the Code of Conduct e-learning module. We have a zero-tolerance approach to modern slavery, are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We also have Anti-Bribery and Corruption, Competition Law and Whistleblowing Policies that incorporate the Group’s key principles and standards, governing business conduct towards our key stakeholder groups.

We believe we should treat all of these groups with honesty and integrity. Our Anti-Bribery Policy is supported by clear guidelines and processes for giving and accepting gifts and hospitality from third parties.

Our Whistleblowing Policy is supported by an external, confidential reporting hotline which enables employees of the Group to raise concerns in confidence. Any reported issues are reported to the Audit Committee and, where appropriate, remedial actions taken.

Our Group is guided by our vision to help every household make the most of its money. We believe that our business makes a valuable contribution to UK society and we are proud to have helped our customers save money, by finding a better deal on their household bills, insurance and banking products.

Alongside this, we want to make our contribution to the communities that our customers live in by paying the right amount of tax, at the right time. In 2022, we once again paid over £50m in UK taxes. This does not include taxes collected on behalf of individuals in the form of PAYE and employees’ NI.

We are committed to acting with integrity and transparency in all tax matters. We will not support proposals to reduce our tax cost through implementing artificial structures, but we will seek to structure commercial transactions in an efficient and legitimate way.

A copy of our tax strategy is available here.