The Prudential plc Board requires the highest possible standards of professional and ethical
conduct of itself and from all employees. This Code of Conduct sets out the basic ethical
standards that are required across the Group. Equivalent standards of conduct are expected
from all agents and other persons acting on behalf of the Group. All employees and other
persons acting on behalf of the Group are expected to treat compliance with this Code of
Conduct as an important element of their relationship with the Group.
Each business should operate with policies and procedures which are consistent with the values
and the standards set out in this Code and the requirements of the Group Governance manual,
details of which can be found on the Group's intranet. The following standards of conduct apply
to all employees and other persons acting on behalf of the Group. In particular, the Group's
senior management has a special responsibility to lead according to these standards.
| 1. |
All Dealings
|
| 1.1 |
Engage in honest and ethical conduct, including the ethical handling of actual or apparent
conflicts of interest between personal and professional relationships.
|
| 1.2 |
Maintain effective procedures to prevent confidential information being misused and make
it clear that the use of confidential information for personal and corporate gain will not be
tolerated.
|
| 1.3 |
Advance the legitimate interests of the Group, having regard to our values and standards,
as set out in this Code and the Group Governance manual.
|
| 1.4 |
Comply with all applicable laws, rules and regulations in every country in which we
operate.
|
| 1.5 |
Comply with anti-money laundering and counter-terrorist financing practice, law and
legislation in all countries and territories in which we operate.
|
| 1.6 |
Forbid corruption and the paying or receipt of bribes.
|
| 2. |
Dealings with Customers
|
| 2.1 |
Treat customers fairly, openly and honestly.
|
| 2.2 |
Provide high standards of service.
|
| 2.3 |
Operate effective complaints processes to deal with situations where these standards are
challenged.
|
| 2.4 |
Aim to provide and promote a range of products and services that meet customer needs
and are readily understandable.
|
| 2.5 |
Maintain the confidentiality of customer information, save where the law requires or
permits disclosure, or the customer has given prior written consent.
|
| 3. |
Dealings with shareholders, the companies in which we invest and the public
|
| 3.1 |
Maximise shareholder value over time, recognising that wealth generated also benefits
customers and employees as well as the communities within which we operate.
|
| 3.2 |
Keep accounting records which accurately disclose the financial position of the business
and issue financial statements to ensure transparency of information on the Group's
financial performance.
|
| 3.3 |
Communicate business policies, achievements and prospects honestly.
|
| 3.4 |
Where appropriate communicate with companies in which we invest as part of the normal
investment management process and debate any departures from our values and
standards.
|
| 3.5 |
Provide full, fair, accurate, timely and understandable disclosure in reports and documents
that the Group publicly releases and/or files or submits to appropriate authorities and
comply with all laws and regulations such as the UK Listing Rules and the US Sarbanes-
Oxley Act.
|
| 4. |
Dealings with Employees
|
| 4.1 |
Maintain a working environment that provides appropriate remuneration.
|
| 4.2 |
Maintain a working environment that provides training and opportunities for personal
development.
|
| 4.3 |
Be intolerant of discrimination, harassment or victimisation. Recognise diversity in
recruitment and dealings with employees. Create a favourable employee relations
environment in which the involvement of all employees is encouraged.
|
| 4.4 |
Support employees who become aware of and are willing to report business malpractice
and have in place procedures to enable people who have a substantial reason to believe
that malpractice is occurring, has occurred or is likely to occur within the business to raise
issues internally without fear or recrimination.
|
| 4.5 |
Provide a clean, healthy and safe work environment, stressing the obligation on all
employees to take every reasonable precaution to avoid injury to colleagues and
members of the public.
|
| 4.6 |
Prohibit the illegal use of drugs on our premises and encourage any member of the Group
with an alcohol or drug dependency to seek help.
|
| 4.7 |
Prohibit the use of forced or child labour.
|
| 5. |
Dealings with suppliers of goods and services
|
| 5.1 |
Maintain the highest possible standards of integrity in business relationships with
suppliers.
|
| 5.2 |
Encourage the use of those suppliers who operate with values and standards equivalent
to ours.
|
| 5.3 |
Work together with suppliers to improve all aspects of performance.
|
| 5.4 |
Agree terms of payment when orders for goods and services are placed and pay in
accordance with those terms.
|
| 6. |
Dealings with communities
|
| 6.1 |
Contribute to the social and economic well being of those communities where we are an
employer.
|
| 6.2 |
Encourage employees to participate in projects and initiatives to strengthen those
communities.
|
| 6.3 |
Work to minimise adverse environmental impact of our business operations and to
achieve group environmental policy targets.
|
| 6.4 |
Ensure that we conduct our activities, so far as possible, in a manner sensitive to the
cultural and social traditions of communities with which we come into contact.
|
| 7. |
Dealing with Competitors
|
| 7.1 |
Conduct business in accordance with our Code of Conduct and compete vigorously but
honestly.
|
| 7.2 |
Avoid disclosing proprietary or confidential information in any contact with competitors.
|
| 8. |
Dealing with governments and regulators
|
| 8.1 |
Maintain a constructive and open relationship with governments and regulators to foster
mutual trust, respect and understanding.
|
| 9. |
Compliance with this Code of Conduct
|
| 9.1 |
Businesses will explain to employees our values, the standards required under this Code
and any associated responsibilities.
|
| 9.2 |
Businesses must be able to demonstrate that procedures are in place to ensure
compliance with all requirements under this Code and periodic audit will be undertaken by
internal audit.
|
| 9.3 |
Failure to comply with this Code or the Group Governance manual may lead to
disciplinary action and, where breaches of the law take place, may lead to criminal
proceedings against the individual or individuals concerned. |
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