Ethical business practices

Anti-bribery and corruption

We have a zero-tolerance approach to bribery and corruption. We train employees on our policies including those relating to anti-corruption, anti-money laundering and competition law and require all regional businesses and key departments to provide written confirmation of compliance annually and to complete our gifts and hospitality register. We expect the same standards from our suppliers and anti-corruption provisions are included in our supplier contracts.

Whistleblowing

Our Board of Directors maintains responsibility for the Company’s Whistleblowing Policy which is communicated to employees including on our sites. It provides a clear procedure for employees to report concerns either to their line manager or through a third-party whistleblowing hotline. The Hotline is also available for use by suppliers, subcontractors, customers and members of the public, for reporting any matters of concern to the Company.

All whistleblowing cases are investigated by the Head of Internal Audit, Group HR Director and/or the Group General Counsel and Company Secretary depending on the nature of the concern, and (where appropriate) the Head of HSE. The Board receives half-yearly updates which set out any whistleblowing issues raised during the period and interim updates on significant matters. The updates are anonymous and summarise the result of any investigation.

Compliance with planning requirements

We aim to work constructively with planning authorities to agree the details of our planning obligations for each development, including affordable housing, local infrastructure, and facilities. Applications integrate a development plan, enabling planning authorities to monitor progress.

Once planning permission is granted, our technical teams monitor compliance with planning agreements and obligations. We also track build rates to make sure that each scheme is being managed efficiently and new homes are delivered on time. This is overseen by the Managing Director in each regional business.

Responsible marketing

We aim for all our marketing and advertising to be honest and accurate. We use a roster of advertising and marketing agencies which are required to follow the guidelines established by the Advertising Standards Authority, Committee of Advertising Practice, Institute of Practitioners in Advertising, and Construction Products Regulation as well as the New Homes Quality Code. 

Our agencies have quality assurance and sign off processes for work. Many agencies and their staff who work on our marketing are members of professional bodies such as the Institute of Practitioners in Advertising and Chartered Institute of Public Relations and are bound by their Codes of Conduct. 

We conduct a regular compliance review and require our agencies to confirm that: staff receive training on the principles of responsible marketing including avoiding misleading claims; they have put internal control procedures in place to review marketing and advertising work and ensure its compliance with regulation and our standards; any environmental claims are supported by evidence and comply with the Green Claims Code guidance issued by the UK’s Competition and Markets Authority (CMA). We plan to update our standard agency contract to include these requirements and train our marketing teams on the Green Claims Code. 

During 2023, there were no complaints made to the Advertising Standards Authority about our advertising.