Corporate Social Responsibility

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Business Conduct Policy

The high level principles that Bradford & Bingley sets as a basis for business conduct are as follows:

Integrity
We will always be honest and open in all business dealings both inside and outside the organisation.

Compliance with the Law
It is Bradford & Bingley's policy to be in compliance with all laws and regulations applying to its business operations. One example is the area of money laundering which is the disguising of funds derived from criminal activity to give them legal respectability. Bradford & Bingley is obliged under existing anti-money laundering and anti-terrorist legislation to ensure that all employees understand and comply with their obligations in respect of money laundering prevention and detection. We have put in place policies, procedures and controls that cover:

• Internal communication
• Internal controls
• Identification procedures
• Record keeping
• Recognition and reporting of suspicious procedures
• Staff training. All customer facing staff take part in money laundering training on at least an annual basis
• Our Group Fraud Management Department provides assistance and support to the National Criminal Intelligence Services

Ethics
We will ensure that all employees conduct themselves in an ethical manner in all dealings on the Group's behalf. We expect honesty, fairness and courtesy both in dealing with each other and with our external contacts, as well as encouraging the contribution from others and respecting different viewpoints.

Ethical Investment Products
We have introduced an increasing range of ethical investment products to our customers. As Independent Financial Advisers, we are able to search the market to find the best products for our customers.

Confidentiality
All employees are expressly forbidden from revealing or communicating to any third party, confidential information that is entrusted or becomes known to them whilst carrying out their duties for the Group.

Conflicts of Interest
All employees must avoid involvement in outside activities that could (or potentially could) conflict with the employee's loyalty; or might adversely affect the employee's judgement and objectivity or time spent on Group business; or might reasonably be construed by others as such.

Business Gifts and Corporate Hospitality
It is the Group's policy to:

• Not accept business gifts, other than items of very small intrinsic value, such as business diaries or calendars
• Not accept hospitality which might be deemed by others to have influenced a purchasing decision
• Record and report any gifts received or offers of hospitality made

Purchasing Code of Conduct
All employees must adhere to the Bradford & Bingley Purchasing Code of Conduct.

Any purchasing related questions to should be directed to:

Group Purchasing
PO Box 88
Croft Road
Crossflatts
Bingley
West Yorkshire BD16 2UA
Tel: +44 (0) 1274 555 555
Fax: +44 (0) 1274 554 565
Email: sandy.duncan@bbg.co.uk - Director of Group Purchasing

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