Introduction
Our values are CLEARR
Where to get support
Our committment to one another
Code
of
conduct
Begin
At Grant Thornton UK, we do what’s right, ahead of what’s easy for our people, our clients and our firm. This sets us apart and guides all our decision-making, even when it’s difficult.
Our Code of Conduct sets out what we expect from everyone who works at Grant Thornton. It’s all about maintaining high standards of integrity, objectivity, competence, confidentiality and professionalism. It also sets out our expectations for creating a culture of everyday inclusion, where everyone feels valued, included and respected.
We encourage you to review the Code of Conduct frequently and make sure you understand what it means. It’s not just a set of rules – it’s a guide to help you feel confident in making choices and decisions that align with the firm’s values.
Remember, we all have a responsibility to act professionally and with good judgement, both as individuals and as a team.
Malcolm
Gomersall
CEO
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Introduction
Our values are CLEARR
Where to get support
Our committment to one another
Our values are
CLEARR
We expect our people to behave in a way that is professional, honest and trustworthy, complying with all applicable ethical and professional standards and legal and regulatory requirements, both in the UK and overseas when relevant. We do what is lawful, what is right and do not allow bias, self-interest or the undue influence of others to affect our professional judgement.
Our CLEARR values (Collaboration, Leadership, Excellence, Agility, Responsibility and Respect) underpin our culture and how we do business – they are embedded throughout our firm and set the parameters of how we expect our people to behave with their colleagues, clients and the world at large. Our clients and our people tell us that there are five ways that they experience this: we care about people and relationships, we’re agile, we value different perspectives, we show the way and we keep a sharp focus on quality.
We have invested in dedicated teams to drive quality, ethics and independence and good risk management across our firm; prevent financial crime; and provide clear policies and efficient processes. Please collaborate and consult with them – they will help you to make the right choices when you’re faced with difficult or complex circumstances. Remember, it’s all of our responsibility to deliver high-quality work, in compliance with our ethical and legal requirements and manage our risks.
Care about people and relationships
Be agile
Value different perspectives
Show the way
Keep a sharp focus on quality
We encourage and embrace the value that different perspectives bring and appreciate everyone’s contribution to the firm’s success. We collaborate and share our ideas, knowledge and expertise to create rich and valuable solutions for our clients and each other.
We understand that Environmental, Social and Governance risks and opportunities are increasingly important to our decision making and that of our clients in helping all of us better understand and positively impact the environment and society.
We invest in one another’s development and learn from experience so that we become stronger individually and as a firm. As part of this, we trust each other to offer open and honest feedback and work together to resolve differences promptly and professionally.
We respect people’s right to have different beliefs and to express these. However, beliefs must be expressed lawfully, respectfully and with positive intent. Behaviours that intentionally exclude others, are unreasonable or offensive, are intolerant of difference or make people feel unwelcome or threatened are a violation of this Code of Conduct, may violate other policies (including our Bullying and Harassment, Inclusion and Social Media policies) and will not be tolerated. Together, we ensure a safe, flexible and healthy working environment that is free from discrimination or harassment and enables our people to be their true selves at work.
We will each contribute towards creating a culture that is inclusive and sustainability-led; one where we treat each other with respect and trust and support each other to make the right choices.
Our firm is built around our clients and our success depends on their success. We go beyond for them, delivering fresh perspectives, tailored and practical solutions and consistently high quality through a more personal, agile and proactive approach.
We must always listen to our clients and demonstrate genuine care and attention to their needs; ensure they understand and agree to the scope and terms of our services before we start work; offer only those services for which we have the necessary skills and expertise and are permitted to carry out by law or regulation; be honest, objective and open in our dealings with clients; professionally challenge, even where it might be difficult or unwelcome; be prepared to confront difficult or unwelcome situations; treat clients fairly and provide them with clear information and advice that is suited to their needs; and ensure engagements are properly managed, supervised and carried out in accordance with all applicable standards and to the highest quality possible
We are driven by a total commitment to excellence and aim to deliver the highest quality of service to our clients, whilst meeting the expectations of our regulators and wider stakeholders.
These ethical behaviours are core to how we conduct ourselves personally, as a firm, within the profession and in our dealings with our clients. Behaving ethically and independently is crucial to public confidence in our firm, the outcomes of our work and our profession. We will not compromise our professional or business judgement or independence for commercial or personal gain.
We will not work with clients whose standards are incompatible with our own, jeopardise our ability to meet the obligations we have to our professional bodies or expose us to unacceptable risks. We are prepared to withdraw from working with any client that puts our people under undue pressure, threatens our ability to carry out our professional duties or does not demonstrate integrity.
We will always put the principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour first.
Integrity
Objectivity
Professional competence
and due care
Confidentiality
Professional
behaviour
To support you in doing this, we will help you manage risk by only recruiting individuals who share our commitment to quality and provide you with support, development and training opportunities to enable you to fulfil your commitments.
We are committed to doing what’s right, ahead of what’s easy. And we recognise that no one client is more important than our need to maintain public confidence, our people’s trust and to protect our highly regarded reputation. We take steps to safeguard our people and keep our assets safe by maintaining up-to-date business continuity plans to support all our people and business-critical functions should there be an unplanned event. Together, we secure and protect our information systems, data and confidential and personal information from unauthorised access, theft and data corruption and will not use or disclose it for our own personal advantage or for the benefit of others.
We will share responsibility for protecting the firm’s reputation and put quality at the heart of everything we do. We will always strive to deliver work to the expected internal and external standards.
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Introduction
Our values are CLEARR
Where to get support
Our committment to one another
For advice on quality, ethical independence or compliance matters or to raise concerns, speak to your people manager, engagement lead, practice leader, quality teams or people and culture teams. Support is also available for both work and personal matters by raising a request or query via the Support Portal and selecting Quality and Reputation.
If you would like to speak up in absolute confidence regarding awareness or concerns of fraud, theft or other misconduct including injustice, harassment, bullying or other inappropriate behaviours, contact the confidential whistleblowing hotline (0808 196 5793). You can also log your concern anonymously on EthicsPoint if you feel that a violation of our policies or standards has occurred. For more information, visit the firm’s core manual page.
Where to get
support
Next
Please speak up. It is better to ask and/or to report a suspected issue than risk the consequences of a wrong decision.
Support Portal
EthicsPoint
Core Manual
Introduction
Our values are CLEARR
Where to get support
Our committment to one another
Inclusion policy
Bullying and Harassment Policy
It takes all of us, following the firm’s policies and procedures and living these behaviours all of the time to create the kind of environment where we can all thrive. Here are some things we all need to do, all of the time, to ensure we are protecting our firm, our clients and each other:
Our commitment to
one another
When you complete your Annual Declarations, you will be confirming that you have read and understood your responsibilities in relation to this Code of Conduct.
• Speak up if you are asked to do something that feels wrong
• Challenge others if you think their actions could expose the firm to
unnecessary risk
• Have the courage to tell someone if you make a mistake, and have
confidence that you will have the firm’s support to rectify it
Speak up
• Consider whether your attitude or behaviours could have a negative
impact on others
• Value everyone’s ideas and contributions
• If a colleague seems to be struggling – try and support them
Be inclusive
• Look for opportunities to collaborate with others (ask for help and give
help) and challenge exclusion when you see it
• Bring together the firm’s specialist knowledge, expertise and insight to
provide the best ideas to our clients (to help our clients meet their
environmental goals, we have invested in expertise in each of our
service lines to address their needs for compliance reporting and
advisory services)
• Consult fully when faced with a challenging situation
Consult others
• Continually look for new and improved ways of working
• Offer, seek and accept open, constructive and honest feedback;
praise positive behaviour and actively challenge poor behaviour so
that we can be the best we can be
• Critically review your work and the work of others to ensure it meets
our high-quality standards
• Actively invest time in your own development and the development of
others, and encourage others to do the same; ensure you have the
knowledge and skills to provide your clients with the best business
insight to meet their needs
Seek continuous improvement
• Understand your responsibilities for following key risk management
policies and procedures, completing mandatory compliance training
as well as the consequences of failing to do the right thing
• Take personal accountability for complying with the Financial Crime
Risk Policy and associated policies and guidance. Engage fully with
due diligence procedures for clients and third parties
• Follow the firm’s policies and guidance to comply with ethics and
independence standards and regulatory requirements. When in
doubt, seek advice and support
• Never accept or offer bribes or facilitate tax evasion
Take ownership and responsibility
• Seek advice and assistance from the Money Laundering Reporting
Officer and their team where necessary, and report knowledge and
suspicion of financial crime to the Nominated Officer
• Update your relevant relationships, financial interests; and gifts,
hospitality and favours in the firm’s monitoring systems
• Take care to maintain confidentiality and avoid careless or
inappropriate comments or views that might damage the reputation
of the firm, your colleagues or our clients, particularly when using
social media
• Know what to do in the event of an emergency
• Challenge others if you think their actions could expose the firm to
unnecessary risk
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Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd (GTIL). GTIL and the member firms are not a worldwide partnership. Services are delivered by the member firms. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another’s acts or omissions. Please see grantthornton.co.uk for further details. For internal use only.
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Introduction
Our values are CLEARR
Where to get support
Our committment to one another