(including Whistleblowing) Code of Responsible Business Conduct update Date: 9 July 2013

21 September Code of Responsible Business Conduct (CoRBC) Updated April 2013 – Section 5b Gifts and Entertainment (G & E) –Clearer guidance on both giving and receiving G&E –For major sporting and other similar Corporate Events the presumption is now no attendance case to be made by exception with Director/Chief Officer and ratified by Conduct Compliance Officer –Tighter line on Conflict of Interest –Charity events are still encouraged - in individual’s own time and expense – so: Meal and moderate ‘refreshment’ is acceptable (normally within the notional £50 UK Bribery Act guideline) Transport – acceptable if shared (e.g. minibus) and preferably with other organisations too (not just SL personnel). Sole use transport not normally acceptable Accommodation – not acceptable – individual personal expense –Please don’t offer what we can’t accept –Speak with Conduct Compliance Officer to agree what is OK beforehand

Whistleblowing In CoRBC (Section 6) Available to anyone working on SL’s behalf: –SL, ASW, CSW, T2…Tn contractors and sub contractors –Various routes: Preference is via own organisation unless that is conflicted Can come to SC Ombudsman, CCO, or outside to (e.g. Regulators, Safecall) Certain specific matters - protected disclosure applies Anonymity – is allowed; prefer to have name in confidence –Discussion aids proper understanding and investigation