United Kingdom Code Of Conduct And Ethics Clause Catalogue
Clause name | Purpose | Most relevant organisation type | Typical importance | Drafting considerations |
|---|---|---|---|---|
Governance and accountability | ||||
Purpose And Ethical Principles | Explains the organisationu0027s values and expected ethical standards. | All organisations | High | Link values to practical behaviours, not slogans. |
Scope And Who The Code Applies To | Defines who must follow the code. | All organisations | High | Cover employees, directors, contractors, agency workers and suppliers where relevant. |
Leadership Responsibilities | Makes leaders responsible for modelling and enforcing ethical conduct. | All organisations | High | Specify board, senior management and line manager duties. |
Individual Accountability | Confirms each person is responsible for their conduct and decisions. | All organisations | High | Avoid language that removes employer duties or statutory rights. |
Ethical Decision-Making And Escalation | Gives a process for handling ethical uncertainty. | All organisations | Medium | Include decision tests, approval routes and record-keeping expectations. |
Legal and regulatory compliance | ||||
Compliance With Applicable Laws | Requires compliance with UK law and applicable overseas laws. | All organisations, International businesses | High | State how to handle conflicts between local law and company standards. |
Business integrity | ||||
Conflicts Of Interest | Prevents personal interests from improperly influencing business decisions. | All organisations | High | Define examples, declaration process, registers and approval authority. |
Outside Employment And Business Interests | Manages second jobs, directorships and business interests that may conflict. | Companies with employees | Medium | Balance legitimate outside work with confidentiality, working time and conflicts. |
Workplace behaviour | ||||
Family And Personal Relationships At Work | Reduces bias, favouritism and unmanaged reporting conflicts. | Companies with employees | Medium | Focus on disclosure and management, not intrusive personal monitoring. |
Legal and regulatory compliance | ||||
Anti-Bribery And Corruption | Prohibits bribes, facilitation payments and corrupt advantages. | All organisations, International businesses, Supplier-heavy businesses | High | Align with Bribery Act procedures, risk assessment and approvals. |
Business integrity | ||||
Gifts And Hospitality | Controls offers that could influence or appear to influence decisions. | All organisations, Supplier-heavy businesses | High | Set thresholds, registers, approval rules and prohibited categories. |
Legal and regulatory compliance | ||||
Facilitation Payments | Bans unofficial payments to speed routine actions. | International businesses | High | Include safety exception handling, reporting and accounting controls. |
Business integrity | ||||
Political Donations And Lobbying | Controls political activity and protects lawful transparency. | Public-facing businesses, Regulated businesses | Medium | Check company authority, donation controls and lobbying registration issues. |
Charitable Donations And Sponsorships | Prevents donations being used as disguised bribes or improper influence. | Public-facing businesses, International businesses | Medium | Require due diligence, approval and transparent recording. |
Legal and regulatory compliance | ||||
Fraud And Dishonesty | Prohibits deception, false accounting and dishonest gain. | All organisations | High | Coordinate with expenses, finance controls and investigation procedures. |
Anti-Money Laundering | Prevents involvement in laundering criminal property or terrorist financing. | Regulated businesses, International businesses | High | Adapt for regulated sector status, customer due diligence and suspicious activity reporting. |
Sanctions Compliance | Prevents dealings with sanctioned persons, entities or restricted activities. | International businesses, Regulated businesses | High | Specify screening, escalation, asset freezes and record keeping. |
Prevention Of Tax Evasion Facilitation | Prohibits helping others evade UK or foreign tax. | All organisations, International businesses | High | Refer to reasonable prevention procedures and associated persons. |
Competition Law And Fair Competition | Prevents anti-competitive agreements, bid rigging and market sharing. | All organisations, Regulated businesses | High | Include trade association, competitor contact and pricing information rules. |
Business integrity | ||||
Fair Dealing With Customers And Suppliers | Promotes honest, fair and transparent business relationships. | Public-facing businesses, Supplier-heavy businesses | Medium | Tailor for consumer, B2B, public sector or regulated customers. |
Legal and regulatory compliance | ||||
Consumer Protection And Fair Trading | Requires truthful sales practices and fair treatment of consumers. | Public-facing businesses | High | Address advertising claims, pricing, returns, complaints and vulnerable consumers. |
Business integrity | ||||
Advertising And Marketing Integrity | Ensures marketing is legal, decent, honest and truthful. | Public-facing businesses | Medium | Add approval controls for claims, endorsements, promotions and green claims. |
Legal and regulatory compliance | ||||
Product And Service Safety | Requires safe products and services and prompt safety escalation. | Public-facing businesses | High | Include incident reporting, recalls, traceability and technical standards. |
Business integrity | ||||
Quality And Professional Standards | Requires work to meet agreed quality, care and competence standards. | All organisations | Medium | Align with sector standards, professional duties and customer commitments. |
Workplace behaviour | ||||
Equality, Diversity And Inclusion | Promotes equal opportunity and prohibits unlawful discrimination. | Companies with employees | High | Cover protected characteristics, recruitment, promotion, pay and treatment. |
Bullying, Harassment And Victimisation | Prohibits intimidating, degrading or offensive workplace behaviour. | Companies with employees | High | Include sexual harassment duties, examples and reporting routes. |
Respectful Workplace Conduct | Sets expectations for courtesy, professionalism and collaboration. | Companies with employees | High | Avoid vague rules that are hard to enforce consistently. |
Legal and regulatory compliance | ||||
Health, Safety And Wellbeing | Requires safe working practices and reporting of hazards. | Companies with employees | High | Reflect workplace risks, training, PPE, remote work and incident reporting. |
Workplace behaviour | ||||
Alcohol, Drugs And Fitness For Work | Prevents impairment that creates safety or performance risks. | Companies with employees, Regulated businesses | Medium | Testing rules need lawful basis, proportionality and clear consent process. |
Legal and regulatory compliance | ||||
Safeguarding And Protection Of Vulnerable People | Protects children and vulnerable adults from harm. | Public-facing businesses, Regulated businesses | High | Include DBS checks, reporting, training and sector safeguarding duties. |
Business integrity | ||||
Human Rights And Dignity | Commits the organisation to respecting human rights and dignity. | International businesses, Supplier-heavy businesses | Medium | Consider supply chain, security, labour and community impacts. |
Legal and regulatory compliance | ||||
Modern Slavery And Human Trafficking | Prevents forced labour and trafficking in operations and supply chains. | Supplier-heavy businesses, International businesses | High | Address statement duties, supplier due diligence and worker reporting channels. |
Business integrity | ||||
Responsible Sourcing And Supplier Standards | Requires suppliers to meet ethical, labour and compliance standards. | Supplier-heavy businesses | High | Use supplier codes, audit rights, termination rights and remediation processes. |
Procurement Integrity | Promotes fair, transparent and value-based purchasing decisions. | Supplier-heavy businesses, Public-facing businesses | Medium | Address conflicts, gifts, tender confidentiality and supplier evaluation records. |
Information and assets | ||||
Data Protection And Privacy | Requires lawful, fair and secure handling of personal data. | All organisations | High | Align with UK GDPR roles, lawful bases, rights and breach reporting. |
Confidential Information | Protects confidential business, customer and employee information. | All organisations | High | Do not restrict protected disclosures or lawful whistleblowing. |
Information Security | Protects systems, accounts and information from unauthorised access. | All organisations | High | Cover passwords, MFA, phishing, devices, access controls and incident reporting. |
Reporting and enforcement | ||||
Cyber Incident Reporting | Requires prompt reporting of suspected cyber security incidents. | All organisations, Regulated businesses | High | Coordinate with data breach, IT, legal and regulator notification processes. |
Information and assets | ||||
Acceptable Use Of IT Systems | Sets rules for using company devices, networks and software. | Companies with employees | High | Address monitoring notices, personal use and remote working. |
Workplace behaviour | ||||
Social Media And Online Conduct | Protects reputation and sets rules for online work-related conduct. | Public-facing businesses, Companies with employees | Medium | Balance reputation, free expression, confidentiality and disciplinary fairness. |
Information and assets | ||||
Use And Protection Of Company Assets | Prevents misuse, loss or theft of physical and digital assets. | All organisations | High | Include personal use, return of property and asset reporting. |
Intellectual Property And Inventions | Protects company IP and respects third-party IP rights. | All organisations | Medium | Align with employment contracts, copyright, patents and open-source use. |
Business integrity | ||||
Accurate Books, Records And Reporting | Requires complete, truthful and timely business records. | All organisations | High | Cover expenses, invoices, approvals, retention and audit cooperation. |
Expenses And Reimbursements | Prevents false, excessive or undocumented expense claims. | Companies with employees | Medium | Set receipt, approval, travel, subsistence and tax treatment rules. |
Governance and accountability | ||||
Financial Controls And Authority Limits | Ensures spending, commitments and payments are properly authorised. | All organisations | High | Cross-reference delegations, procurement policy and fraud controls. |
Reporting and enforcement | ||||
Whistleblowing And Protected Disclosures | Encourages reporting of wrongdoing and protects eligible whistleblowers. | All organisations, Companies with employees | High | Explain protected disclosures, prescribed persons, confidentiality and no retaliation. |
Speak-Up Channels And Reporting Concerns | Provides routes for reporting concerns, questions and misconduct. | All organisations | High | Offer manager, HR, compliance and anonymous options where appropriate. |
Non-Retaliation | Prohibits victimisation for raising concerns in good faith. | All organisations | High | Do not require legal proof before protection applies. |
Internal Investigations And Cooperation | Explains how concerns may be investigated and cooperation expected. | Companies with employees | High | Preserve fairness, confidentiality, evidence integrity and employment rights. |
Breach Of Code And Disciplinary Action | Explains consequences of breaching the code. | Companies with employees, All organisations | High | Cross-reference disciplinary procedure and avoid automatic dismissal wording. |
Grievances And Workplace Complaints | Directs staff to the proper process for employment complaints. | Companies with employees | Medium | Distinguish grievances from whistleblowing and compliance reports. |
Governance and accountability | ||||
Training And Certification | Ensures staff understand the code and certify compliance where needed. | All organisations, Regulated businesses | Medium | Use risk-based frequency and records for higher-risk roles. |
Policy Ownership, Review And Updates | Assigns responsibility for maintaining and updating the code. | All organisations | Medium | State owner, approval body, review cycle and version control. |
Legal and regulatory compliance | ||||
Regulatory Cooperation And Notifications | Requires cooperation with regulators and timely escalation of notifiable matters. | Regulated businesses | High | Adapt to FCA, PRA, ICO, HSE, charity or sector regulator duties. |
Financial Services Conduct Rules | Requires regulated staff to meet FCA or PRA conduct standards. | Regulated businesses | High | Include individual conduct rules, senior manager duties and breach reporting. |
Insider Dealing And Market Abuse | Prevents misuse of inside information and market manipulation. | Regulated businesses, Public-facing businesses | High | Add dealing windows, restricted lists and disclosure controls if listed. |
Preventing Economic Crime | Reduces risk of fraud, false accounting and other economic crime. | Regulated businesses, All organisations | High | Consider failure to prevent fraud exposure for large organisations. |
Environmental Responsibility | Requires lawful and responsible environmental practices. | All organisations | Medium | Tailor to waste, emissions, permits, supply chain and premises risks. |
Business integrity | ||||
Green Claims And Sustainability Communications | Prevents misleading environmental and sustainability claims. | Public-facing businesses | Medium | Require evidence, lifecycle context and legal review for public claims. |
Workplace behaviour | ||||
Remote And Hybrid Working Conduct | Applies conduct, security and availability standards to remote work. | Companies with employees | Medium | Cover confidentiality, equipment, health and safety and monitoring notices. |
Business integrity | ||||
Customer Complaints Handling | Ensures complaints are handled fairly, promptly and consistently. | Public-facing businesses, Regulated businesses | Medium | Regulated firms may need ombudsman and prescribed response requirements. |
Treatment Of Vulnerable Customers | Promotes fair, sensitive treatment of customers with vulnerability. | Public-facing businesses, Regulated businesses | Medium | Define vulnerability indicators, staff training and escalation processes. |
Client And Customer Conflicts | Prevents unmanaged conflicts affecting customers or clients. | Regulated businesses, Public-facing businesses | High | Include identification, disclosure, mitigation and refusal where needed. |
Workplace behaviour | ||||
Fair Recruitment And Promotion | Requires fair, merit-based and non-discriminatory hiring and promotion. | Companies with employees | High | Cover reasonable adjustments, interview records and objective criteria. |
Pay, Benefits And Reward Integrity | Promotes fair, lawful and transparent reward decisions. | Companies with employees | Medium | Consider equal pay, bonuses, incentives and conflicts in remuneration. |
Legal and regulatory compliance | ||||
Working Time And Rest | Supports lawful working hours, breaks and fatigue management. | Companies with employees | Medium | Reflect opt-outs, on-call work, travel time and safety-critical roles. |
Right To Work And Immigration Compliance | Requires lawful employment and right-to-work checks. | Companies with employees | High | Avoid discriminatory checks apply right-to-work process consistently. |
Business integrity | ||||
Dealings With Public Officials | Controls higher-risk interactions with officials and state bodies. | International businesses, Supplier-heavy businesses | High | Define officials broadly and require pre-approval for benefits or payments. |
Third-Party Due Diligence | Assesses integrity risks before appointing agents, suppliers or partners. | Supplier-heavy businesses, International businesses, Regulated businesses | High | Use risk-based checks for bribery, sanctions, AML and modern slavery. |
Agents, Intermediaries And Representatives | Controls conduct of third parties acting for the organisation. | International businesses, Supplier-heavy businesses | High | Require written contracts, audit rights, training and termination rights. |
Legal and regulatory compliance | ||||
Export Controls And Trade Restrictions | Prevents unlawful export of controlled goods, software or technology. | International businesses | Medium | Assess products, destinations, end users, licences and technical transfers. |
Information and assets | ||||
Document Retention And Legal Holds | Ensures records are kept, deleted or preserved appropriately. | All organisations | Medium | Balance limitation periods, regulatory retention and data minimisation. |
Business integrity | ||||
Media And Public Communications | Controls who may speak publicly for the organisation. | Public-facing businesses | Medium | Include press, investors, regulators, crisis communications and social media. |
Information and assets | ||||
Responsible Use Of Artificial Intelligence | Sets ethical and secure rules for using AI tools. | All organisations | Medium | Cover confidential inputs, accuracy checks, bias, IP and human oversight. |
Legal and regulatory compliance | ||||
Personal Account Dealing | Controls employee trading that may create conflicts or market abuse risk. | Regulated businesses | Medium | Specify pre-clearance, restricted securities, holding periods and reporting. |
Business integrity | ||||
Sales Incentives And Conduct Risk | Prevents incentives encouraging unsuitable or unfair customer outcomes. | Regulated businesses, Public-facing businesses | Medium | Review commission, targets, complaints, cancellations and customer harm indicators. |
Tax Integrity And Transparent Dealings | Promotes honest tax reporting and rejection of abusive tax practices. | All organisations, International businesses | Medium | Align with finance controls, advisers, associated persons and tax strategy. |
Fundraising Ethics | Ensures fundraising is lawful, honest and respectful. | Public-facing businesses | Low | Relevant mainly to charities, sponsors and cause-marketing campaigns. |
Workplace behaviour | ||||
Conduct Outside Work Affecting The Organisation | Addresses outside conduct that damages trust, safety or reputation. | Companies with employees, Public-facing businesses | Medium | Require a genuine connection to work and fair disciplinary assessment. |
Respect For Lawful Beliefs And Opinions | Promotes respectful debate while preventing discrimination or harassment. | Companies with employees | Medium | Balance belief protection, expression, dignity and harassment risks. |
Accessibility And Reasonable Adjustments | Supports disabled staff, customers and applicants through reasonable adjustments. | Companies with employees, Public-facing businesses | High | Include request routes, confidentiality and customer-facing adjustments. |
Business integrity | ||||
Climate And Sustainability Reporting Integrity | Ensures sustainability data and reports are accurate and evidence-based. | Public-facing businesses, Regulated businesses | Medium | Check quoted companies, large companies and financial reporting duties. |
Reporting and enforcement | ||||
Supply Chain Concern Escalation | Provides a route to report supplier labour, ethics or safety concerns. | Supplier-heavy businesses, International businesses | Medium | Define escalation, remediation, suspension and termination criteria. |
Governance and accountability | ||||
Ethics Monitoring And Board Reporting | Ensures ethics risks and incidents are reviewed at senior level. | All organisations, Regulated businesses | Medium | Use metrics on reports, training, breaches, investigations and culture. |
Business integrity | ||||
Supplier Gifts, Rebates And Kickbacks | Prevents procurement decisions being influenced by hidden benefits. | Supplier-heavy businesses | High | Require disclosure of rebates, commissions, discounts and personal benefits. |
Reporting and enforcement | ||||
Confidentiality In Reports And Investigations | Protects sensitive information during reports and investigations. | All organisations | Medium | Avoid absolute confidentiality promises that cannot lawfully be guaranteed. |
Anonymous Reporting | Allows concerns to be raised without naming the reporter where available. | All organisations, Regulated businesses | Medium | Explain limits on investigation, feedback and anonymity protection. |
Governance and accountability | ||||
Code Acknowledgement And Annual Declarations | Records that people have read the code and declared conflicts. | All organisations, Regulated businesses | Medium | Use for higher-risk roles and keep audit-ready records. |
What Should A UK Code Of Conduct And Ethics Policy Include?
A strong UK code of conduct and ethics policy usually needs more than general values statements. The highest-priority clauses commonly cover leadership accountability, conflicts of interest, bribery prevention, gifts and hospitality, workplace harassment, discrimination, whistleblowing, data protection, confidential information, health and safety, fraud, competition law and disciplinary consequences.
Which Clauses Are Most Legally Sensitive In The UK?
Clauses linked to bribery, equality, whistleblowing, data protection, health and safety, modern slavery, competition law, financial crime and sanctions should be drafted with particular care because they connect directly to UK statutory duties or regulatory expectations. Relevant sources include the Bribery Act 2010, Equality Act 2010, Public Interest Disclosure Act 1998, Data Protection Act 2018 and Health and Safety at Work etc. Act 1974.
How Should The Policy Be Adapted For Different Organisations?
- Regulated businesses should add sector-specific clauses on fitness and propriety, market conduct, client money, financial promotions, vulnerable customers and regulatory reporting.
- International businesses should strengthen anti-bribery, sanctions, export controls, human rights, tax integrity and local law escalation clauses.
- Supplier-heavy businesses should include modern slavery, responsible sourcing, supplier gifts, procurement conflicts and third-party due diligence clauses.
- Companies with employees should prioritise equality, harassment, bullying, grievances, health and safety, whistleblowing and disciplinary procedures.
- Public-facing businesses should address customer treatment, social media, safeguarding, product safety, complaints handling and reputation risks.
What Drafting Choices Matter Most?
The policy should say who it applies to, how conflicts are declared, when gifts need approval, where whistleblowing reports go, what conduct may lead to disciplinary action, and how the policy interacts with employment contracts, staff handbooks and supplier terms. UK organisations should avoid copying a generic international code without adapting it to UK employment law, data protection law and sector regulation.

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