The highest ethical standards from employees and other personnel in carrying out its business.
Code of conduct
Doing the right thing
Wolseley UK expects the highest ethical standards from employees and other personnel in carrying out its business.
The purpose of this Code
- It describes the principles by which Wolseley expects to conduct its business
- It provides employees with guidance on the standards expected when conducting business on behalf of Wolseley
- It applies to all the businesses and functions in the Wolseley group of companies.
It is essential that everyone in Wolseley maintains its reputation for integrity. Everyone should act honestly, fairly and with transparency, and should be loyal to Wolseley in the conduct of their work. They should not act in a manner which could discredit themselves, or Wolseley, or put themselves in a position which may result in a conflict of interest.
Wolseley respects the rule of law and requires all employees to conduct its business in a way that ensures compliance with the rules that apply to Wolseley.
A number of the principles in this Code are supported by more detailed policies to guide employees. For example, the Gifts and Hospitality principle is supported by the Anti-Bribery & Corruption Policy. All employees are required to comply with Wolseley Group Policies & Procedures.
This Code applies to all Wolseley employees, temporary personnel, agents and contractors. We also expect our suppliers to adhere to this Code or adopt similar ethical standards.
Breach of this Code
Any breach of this Code may be considered to be a disciplinary matter and could result in disciplinary action up to and including dismissal. It is therefore of critical importance that you read and understand this Code.
Health and safety
Wolseley will provide a safe and healthy working environment and does not compromise the health or safety of any individual.
Compliance with the law
Wolseley’s businesses, employees and others to whom this Code applies must observe both the spirit and letter of the laws and regulations.
Bribery and corruption
Wolseley does not permit the bribery of any person involved in Wolseley UK business or any customer, supplier or business partner of Wolseley UK. No Wolseley UK employee or family member should accept or solicit or give (directly or indirectly) any improper gift or hospitality.
Wolseley does not tolerate fraud.
Wolseley’s information is a valuable asset, and it must be kept confidential and protected appropriately.
Conflicts of interest
Wolseley’s employees and other personnel must avoid situations where personal interests could conflict, or appear to conflict, with Wolseley interests.
Customers and suppliers
Wolseley treats its customers and suppliers fairly. We expect the same standards of them as we expect from our employees.
Wolseley’s businesses and employees must comply with the UK Competition Act.
Shareholders and other stakeholders
Wolseley is committed to high standards of corporate governance, transparency and responsibility.
Wolseley will run efficient operations that minimise waste and reduce any negative effect of its business activities on the environment. We will promote sustainable development. We have set challenging targets in the key areas of waste, energy, water and timber.
Wolseley values its employees and their diversity. We will develop our people and reward them fairly.
Modern Slavery & Human Rights
All Wolseley businesses, employees and suppliers must comply with our modern slavery and human rights policy which incorporates the principles of the UN Global Compact and UN Declaration of Human Rights. The greatest risk is in our supply chain, and we have incorporated this into our supply chain management processes.
Responsible, Ethical & Sustainable Sourcing
All suppliers must register on our portal which requires them to sign up to our Product Integrity Policy which codifies our modern slavery and human rights policy along with safety and environmental requirements of products.
Many business decisions may involve ethical dilemmas. This Code cannot address every possible situation, so it is important that employees recognise when they are in a difficult ethical situation and that they seek assistance as appropriate.
The principles in this Code are intended to help guide you in the normal course of your work but they are no substitute for common sense and proper internal consultation.
If you find yourself in a situation where you are unsure of the right course of action to take, you may find it helpful to ask yourself the following questions:
- Is it legal?
- Is it ethical?
- Is it consistent with Wolseley policies and this Code of Conduct?
- Can I explain it to my family and friends?
- Would I feel comfortable if it appeared in a newspaper?
How to ask a question or raise a concern
If you still find that you do not know the right course of action to take, if you suspect someone else of acting contrary to this Code, or if you do not understand something in this Code, please speak with one of the following:
- Your line manager in the first instance
- Human Resources department
- Legal department
- Use the SpeakUp! service
If, for any reason, you are not comfortable speaking with someone within Wolseley, you can call the Speak Up! Helpline or use the Speak Up! secure website, which are operated by an independent company, and are available 24 hours a day, every day of the year.
Your concern will be investigated promptly and impartially. You can also contact the General Counsel & Company Secretary directly if you wish.
Wolseley will take the appropriate steps to protect the confidentiality of anyone who raises a concern, so never hesitate to ask questions or seek the guidance you need. Any employee who raises a concern in good faith will be protected from retaliation in any form.
Wolseley would prefer to learn of a potential ethical situation from its employees in advance, rather than subsequently, when there may be little that can be done to preserve the Company’s reputation.
Health and Safety
- Wolseley is committed to continual improvement in health and safety performance throughout our operations
- Wolseley will provide the necessary resources, including appropriate PPE, to allow for the safe performance of day-to-day activities
- Every Wolseley UK employee has a legal duty to look after their own health, safety and welfare and that of those around them
Compliance with the Law
- The laws and regulations that apply to Wolseley’s business are numerous and often complex
- If you have any doubt whether your conduct – or the conduct of a colleague or your business area – complies with the law, guidance should be sought from your line manager, the Human Resources department or the Legal department
- You should immediately bring to your manager’s attention any request that you think may be illegal or in violation of this Code.
Bribery and Corruption
You must not, directly or indirectly, authorise, offer, promise, pay or give a:
A bribe is a reward, advantage or benefit made in order to influence and/or secure an improper advantage. The amount of the bribe offered or paid is irrelevant and it need not actually be paid.
A kickback (e.g. the payment or receipt of a payment in return for securing a contract) is a form of bribe.
A facilitating payment is a relatively small payment or gift to an official or government employee made to expedite routine services or administrative actions to which the company would already be entitled. Such payments should not be made in any circumstances.
You should also observe the following guidance when giving or receiving gifts and hospitality which, if excessive, may also be regarded as a form of bribery:
- Accepting hospitality from, or providing entertainment to, third parties is acceptable if it is reasonably related to a clear business purpose and is modest
- You should be mindful that the donation or receipt of gifts, hospitality or favours may give rise to embarrassing situations and may be seen as improper inducement to give some concession in return to the donor
- The following principles should be observed:
- The giving or receiving of gifts or hospitality should remain appropriate to the business and should be modest - it is almost always inappropriate at the initial stages of a relationship
- Employees must obtain the consent of their manager before giving or accepting gifts or hospitality in accordance with the rules set out in the Anti-Bribery & Corruption Policy
- Gifts, favours or hospitality should never be solicited
- Gifts of money should never be offered or accepted
- When being offered a gift or entertainment, a good test as to whether it is acceptable is whether or not you would be able to, or would feel obliged to, reciprocate.
For the purposes of this Code, hospitality and gifts can include travel, accommodation, social or sporting events or other benefits received or given.
All employees have a responsibility to be alert to the signs of fraud and to report suspected fraud. Wolseley defines fraud as any intentional act committed to secure an unfair or unlawful gain. This includes:
- Fraudulent financial reporting (such as manipulation of vendor rebates, false sales, delaying or avoiding expenses)
- Misappropriation of assets (examples include fraudulent expense claims, burglary and property damage, misuse of customer accounts or customer data)
- Concealing a conflict of interest
Wolseley is committed to the prevention, detection and proper investigation of fraud. The Company will respond to all incidents of fraud, seeking to recover loss, taking action against those who perpetrate fraud and reporting incidents to the authorities as appropriate. This may lead to prosecution or to disciplinary sanctions up to and including dismissal.
Wolseley will implement a fraud risk management framework that is appropriate for the size and complexity of the fraud risks that are faced. We expect our business partners to uphold similar principles for fraud risk management.
Operating processes and controls
You must operate the core business processes in the way they are intended and not circumvent any controls. This includes obtaining the appropriate approval to enter into agreements or transactions.
- Confidential information should not be used for personal gain
- You should treat email with the same confidentiality as other forms of communication
- Dissemination and disclosure of commercial information must be dealt with in accordance with the Information Governance Policy
- The obligation of confidentiality extends to periods after you cease to work for Wolseley and includes the disclosure of information to others
- You must only collect and retain personal data for legitimate commercial purposes
- You must respect the privacy of personal data relating to employees, customers and suppliers
- Wolseley must ensure that its data and information systems comply with data protection laws
- Wolseley’s information takes many forms e.g. reports, spreadsheets, quotes, etc.
- Information and devices that hold information e.g. laptops and phones should always be stored securely and protected
- You should lock your computer screen when away from your desk
- You should use passwords for files which contain sensitive data
- Information should only be held for the period required.
- You may use social media for work purposes (e.g., LinkedIn) or for personal use (e.g., social networking sites such as Facebook and YouTube or discussion forums). Any social media use should be respectful to Wolseley, its employees and associated companies. Usage should be relevant, protective of Wolseley’s reputation and should follow the letter and spirit of the law
- When using social media you must not disclose confidential information or share personal information. You should also be mindful of protecting yourself and your own privacy
Conflicts of Interest
- Conflicts of interest arise where a person’s position or responsibilities within their business unit present an opportunity for personal gain above the normal rewards of employment
- They can also arise where personal interests are inconsistent with those of their employer or create conflicting loyalties in respect of transactions between their employer and a third party
- You must not be involved with an activity for personal gain which is in conflict with Wolseley’s business interests
- Any of your personal interests or the interests of a member of your immediate family in relation to Wolseley’s business must be disclosed to your manager immediately
- You must not work simultaneously for any of Wolseley’s competitors, customers or suppliers
- If you are unsure as to whether a conflict of interest exists, please seek advice from your line manager, Human Resources department or Legal department
Customers and Suppliers
Wolseley’s reputation and the loyalty of our customers depends upon the quality and value of our products and the service we deliver. The integrity of our dealings with customers and suppliers is therefore critical to the long-term success of Wolseley UK.
We will pay our suppliers, contractors and agents in accordance with agreed terms.
We expect our suppliers, contractors and agents to adhere to this Code or adopt similar ethical standards.
- Wolseley welcomes and encourages free and open competition in the marketplace
- Wolseley businesses will compete vigorously but fairly and legally
- Each business unit should have a formal process of educating its management on the competition and laws of the UK with regular reviews to ensure that management teams keep their knowledge up to date. This is supported by training where appropriate
Shareholders and other Stakeholders
Wolseley engages actively and constructively with all who are interested in the success of its business. We have regular and open dialogue with our customers, suppliers, employees, shareholder, governmental and regulatory agencies, non-governmental organisations, trade associations and groups promoting improvement in society and the environment, as well as educational organisations.
Wolseley UK will not contribute to party political organisations.
All Wolseley’s businesses and employees must comply with our environmental policy. The biggest impact we have on the environment is from the use of the products and services we supply to our customers. We are committed to supporting our customers to improve their environmental performance and will play a leading role in the transition to the zero-carbon economy in the markets we serve. Wolseley will also continue to improve its own environmental performance.
- Achieve net zero carbon emissions by 2030 by increasing the quantities of zero carbon heating products and reducing the emissions from our fleet and property operations.
- Reduce waste, packaging, use of plastic and water consumption
- Work with our suppliers to improve the environmental performance of products
- Maintain our ISO14001 environmental management systems and certification for the use of sustainable timber
- To meet our goals, we want to be an employer of choice. We can achieve this through the maintenance of a positive, responsible, open and welcoming working environment
- Wolseley will treat its people fairly and impartially, without prejudice and never tolerate harassment or bullying in any form, and will work to ensure the human rights of all our people are upheld
- Employees are expected to be open, honest, courteous and to treat each other with dignity
- Wolseley will provide employees with opportunities to enhance their skills and capabilities, helping them to develop fulfilling careers and to maximise their contribution to our business
- Wolseley has formal grievance procedures that clarify what happens if an employee has a concern that cannot be resolved satisfactorily with their line manager
- Wolseley is committed to honouring the terms and conditions of employment of employees and requires all employees to do the same
- We are committed to providing fair pay, benefits and terms and conditions of employment and, where required, to seeking agreement for changing these when necessary to meet business objectives
- A failure to treat employees properly can breach employment laws and may also be a disciplinary offence