Anti-bribery

The Phoenix Group is committed to countering bribery and corruption with suitable policies and procedures. We have an anti-bribery programme in place designed to prevent the occurrence of bribery. This includes, for example:

• An Anti-Bribery Policy at Group level.
• A Code of Ethics for ethical behaviour and general standards.
• A Group Stewardship Policy which details our stewardship approach.
• Mandatory training for our employees covering compliance with the Bribery Act.

Our anti-bribery programme prohibits the offering, promising, receiving or giving of a financial or other advantage to another individual in exchange for improperly performing a relevant function or activity. This applies to any bribe offered, promised or received whether by The Phoenix Group or by third parties with whom we deal. This prohibition includes our joint venture entities, agents, introducers, brokers and distributors as well as contractors, consultants and suppliers.”

Our key principles are:

1. All Bribery, both direct and indirect, is forbidden.
2. Policies and Procedures. These set out standards for ethical behaviour including the acceptance or offering of corporate hospitality and gifts. Corporate hospitality must be reasonable and proportionate and any gifts given or received must not conflict with our duties to Customers. We expect the same standards from our third parties.
3. Top-down Commitment. Our Senior Management is committed to preventing bribery and acting with the highest standards of business integrity.
4. Financial Controls. Our authorisation procedures are clear so that all payments are documented and understood. Payments are not to be used as a subterfuge for bribery. We have similar expectations of our third parties.
5. Due diligence procedures on third parties, both in the UK and internationally. These require a clear understanding of who we are doing business with and why. We expect similar standards from our third parties.
6. Communication. The Phoenix Group has a zero tolerance towards bribery which is firmly embedded into its culture. All employees and third parties will be aware that bribery and corruption, in any form and any jurisdiction, will never be acceptable to the Phoenix Group.

We expect all our employees and third parties to comply with the letter and spirit of the Bribery Act 2010, as enshrined in our key principles above, in the performance of their services for the Phoenix Group.