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The BT WayOur ethics codeJanuary 2019

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Our ethics code 3

Playing your part 4

We follow the law 5

We respect human rights and each other 6

We don’t tolerate bribery and corruption 10

We avoid conflicts of interest 11

We register gifts and hospitality 12

We’re honest about our finances 13

We compete fairly 14

We protect information and keep BT assets safe 16

We act responsibly when we use social media 19

We care about health, safety and wellbeing 20

We look after the environment 21

Contents

A note about this document This document contains some links to internal BT systems and are intended for people working for, on behalf of or with BT.

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Our ethics code

It’s all about how we do things in BT, our business ethics.

So everyone knows how to behave and what’s expected of them. We act with integrity. We follow the rules. And we know where to get help if we’re facing a difficult decision.

Our ethics code helps us to make the right decisions, whether we work for, with or on behalf of BT.

It aligns with our culture and values: Personal. Simple. Brilliant.

And our purpose To use the power of communications to make a better world.

Everyone who works in BT plays a part. And our values, purpose and ethics code define who we are and what we stand for, together.

Need help? If you need help please talk to your line manager or use our Ask a Question service.

If you’re a supplier you can also send information at Selling2BT about how some of the policies in our code apply to you directly.

Speak Up Speak Up is an independent, free and confidential hotline that anyone who works for, with, or on behalf of BT can call, whatever country they work in. You can also raise your concern online and anonymously if you prefer, subject to local law.

Using Speak Up is often the best and safest way to raise a sensitive ethical issue with someone who isn’t connected to your team.

We know it can take courage to speak up. We’ll do whatever we can to support and protect you. And we won’t let anyone retaliate against you for reporting your concerns. If someone tries to deter you from speaking up that’s a disciplinary offence in itself and we’ll deal with it seriously.

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• be familiar with our ethics code and apply it every day

• follow our ethics code, even if it goes against a local custom

• live the BT values

• know where to go for help

• call out wrongdoing

• keep your mandatory training up-to-date

What happens if I don’t follow our ethics code?

Sometimes we all need to make difficult decisions.

What you need to do:

If you’re a people manager, you also need to:

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If in doubt, ask yourself:

• Is it in line with our ethics code?

• Is it legal?

• Would I be happy reading about it in the newspapers or on social media?

• Am I comfortable with this decision?

• Could I explain my decision to my colleagues or to my family?

If you’re not sure, speak to BT Legal.• be a Connected Leader and set an example

for your team

• create an open culture where people can raise concerns without fear of retaliation

• trust your people to make decisions – but verify their approach and understanding

• regularly discuss our ethics code with your team, including the consequences of not following our code

• recognise people in your team who do the right thing.

The consequences can be very serious. You could damage our reputation. We could face significant fines and penalties. We could lose our ISO certifications, which will stop us from winning new business. If you don’t follow our code, we’ll investigate fully. We could take appropriate disciplinary action, up to and including dismissal. There could even be criminal liability for you, your manager and BT as a company.

Playing your part

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You must comply with all the laws that apply to your work.

For people in the UK and for teams in contact with UK customers, this includes all of our regulatory obligations to Ofcom. We’ve given Ofcom and the industry a set of commitments on how Openreach will operate as an independent entity, how we’ll make sure customers are treated equally and reinforcing rules about sharing information.

There are also laws which apply internationally like the UK Bribery Act and US Foreign and Corrupt Practices Act.

In many countries we operate under licence conditions or other regulations that may impose obligations, restrict what we can do or mean we have to tell a government what we’re doing. You need to be aware of – and comply with – any regulation that applies to your work. As a global company, we need to be careful about where we trade and who we trade with.

This includes complying with embargoes and sanctions which have been imposed on certain countries, groups of countries, or individuals.

If you break the law while doing your job, both you and BT could be help responsible. And it could lead to civil and criminal penalties.

If you need more help, contact BT Legal.

We follow the law

The local laws in my country contradict what it says in The BT Way – our ethics code. What should I do?

Our high standards and ethics code applies everywhere we do business. But we also have to comply with local law. Occasionally there can be a conflict between the local law and our ethics code. Get help by speaking with your line manager and to BT Legal.

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Talk about it

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No-one should be deprived of their identity papers, nor have to pay to work with us.

We only want to work with people who choose to work freely, with rights to equal opportunity, freedom of association and collective bargaining.

If you need more help, contact BT Legal.

We respect human rights and each other

We must respect the International Bill of Human Rights when we do business. We believe our communications services have a positive impact on society and empower people to exercise their rights and freedoms.

But we also recognise that we could negatively impact human rights either ourselves, or through our wider business relationships. So we think particularly carefully about the rights of our employees, workers in our supply chain, our

Human rights recognise everyone’s inherent dignity and equality, no matter who they are or where they live.

customers and the wider communities where we operate. As a communications company, we could potentially impact the rights to privacy and free expression most of all. Our human rights policy sets out how we work to mitigate the risks. Modern slavery is an increasing global issue. It includes human trafficking, slavery, servitude and forced or compulsory labour. No form of modern slavery is acceptable in our operations, or in those of companies who work with us or on our behalf. And neither is child labour.

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I think one of the sub-contractors working for our supplier might be employing migrant labour without checking if they’re entitled to work or paying them the local rates. Should I do anything?

Yes. Even if the sub-contractor isn’t a direct supplier to us, they’re still working in our supply chain. You should get in touch with the Procurement Governance & Assurance team for advice. If the sub-contractor is made to stop employing them, they could be put in a worse position so we need to work with the businesses to establish legal and fair ways of working.

Talk about itOur commitment We joined the United Nations Global Compact when it was first established in 2000. It encourages companies to do business responsibly and in line with ten principles on human rights, labour, environment and anti-corruption.

We’re also implementing the United Nations Guiding Principles on Business and Human Rights. They say that companies must avoid infringing people’s rights and address negative impacts which they could be linked to through their business relationships.

Every year we report on the steps we take to make sure there’s no modern slavery in our own business or supply chains.

We expect our people and business partners to treat people fairly, respecting the rights and dignity of everyone they deal with or who may be affected when they do business.

If you’re not sure about the right thing to do, contact our Human Rights team. Or you can contact Speak Up. In the UK, anyone at any time can report concerns about modern slavery to the Modern Slavery Helpline and Resource Centre on 0800 0121 700 or online at http://www.modernslaveryhelpline.org

Watch our film on Modern Slavery.

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We value and welcome diversity. We won’t treat anyone differently to anyone else because of their race, sex, religion/beliefs, disability, marital or civil partnership status, age, maternity or paternity status, sexual orientation, gender identity, gender expression, caring responsibilities, or any characteristic.

We want BT to be a place where everyone feels free to make their own unique contribution. We’ve worked hard to create a culture that’s fair and inclusive, and we’ll continue to do so.

It’s not just about respecting each other, but also our customers, suppliers and partners. We expect our managers to lead by example and root out prejudice wherever they find it.

Fairness and equality in the treatment of others. We work to make sure that this is a fair and equal workplace for everyone. We work within a clear legal framework prohibiting discrimination. But more than that, we’re committed to eliminating any bias that might exist in the way we do things - wherever we work.

We won’t put people at a disadvantage either, by making conditions or requirements we can’t justify. In working together we must all show sensitivity and respect for others’ feelings, cultures and differences.

We respect each other and make BT a place where we’re proud to work. We want everyone who works here to feel able to be themselves.

What can I do personally to encourage diversity in BT?

We all have a role to play in ensuring the inclusion of others in our diverse population through avoiding assumptions and understanding colleagues’ diverse set of skills and experience. It’s about every person in BT thinking about how they can work with others who might not be like them, and about every leader in BT ensuring that we are treating our teams equally and fairly.

No-one at BT should face a barrier because of who they are. We enjoy working in a diverse organisation and benefit from looking at things in different ways. We treat everyone equally and do not tolerate any kind of harassment or prejudice.

Talk about it

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General behaviour You must treat your colleagues with respect and encourage others to do so. Obstructive behaviour, fighting, harassment of any kind and abusive language are unacceptable; as is deliberately performing work below the required standard.

We don’t tolerate any form of bullying or harassment against our people. That includes using social media in ways that harass or bully our people.

Someone I work with is being harassed by someone more senior. I feel like I should report it, but I don’t want to get into trouble. What should I do?

Don’t ignore it. We need to root out this kind of behaviour. Tell your line manager. Or if you’re not comfortable doing that, tell your HR business partner. Don’t worry, they’ll keep it confidential. You won’t get into trouble for doing what you genuinely believe is best.

Talk about itIf you need more help, visit the HR portal. Or you can talk to your line manager. If you don’t want to talk to your line manager then Ask HR by raising a case on the HR Home portal. You can also use our Ask a Question service.

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We don’t tolerate bribery and corruption

Our anti-bribery and corruption policy applies worldwide. As someone who works for, with or on behalf of BT, it’s your responsibility to read, understand and comply with this. If you break anti-bribery and corruption laws, you could bring criminal or civil penalties on yourself, BT or our partners. If you suspect that someone who works for, with or on behalf of BT might be taking part in bribery or corruption, however small, you must raise an issue using our Ask a Question service or via the confidential Speak Up hotline. You can also speak to your line manager. Corruption can take many forms and we can’t list them all.

But watch out for:

• unusual cash payments

• lavish gifts being given or received

• large or unusual payments to agents or other third parties

• unexpected or illogical decisions in accepting projects or contracts

• bypassing normal tendering, contracting or payment procedures

• company procedures, financial controls or guidelines not being followed.

If you need more help please talk to your line manager or use our Ask a Question service. You can also raise any concerns or suspected wrongdoing to the Speak Up helpline.

If you make, authorise, look for or accept any kind of offer, gift kickback or payment to get or keep an unfair advantage, that’s bribery. It doesn’t have to involve money.

I’ve got all the right papers in order, but customs are holding things up. I think a small tip would help speed things up. Is that OK?

No, that’s a bribe. Although some countries allow so called ‘facilitation payments’, we don’t. They’re illegal under the UK Bribery Act which applies to BT all over the world.

Talk about it

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A conflict of interest is any situation where your loyalties might appear to be at odds with your duties to BT. Conflicts of interest can be financial, like having a significant shareholding in a competitor company, working for a competitor or supplier, or having another job which causes your BT work to suffer. They can be nothing to do with money too - like a conflict arising out of close family or other personal relationships.

We expect everyone who works for, with or on behalf of BT to be open and upfront, whatever part or level of our organisation you work in. You must not use your position (or any inside information) for your personal gain, or in a way that could damage our business – or even give people reason to believe that you might.

Where to go for help

We have a Register of Interests where you must let us know about your financial and personal or family interests that might affect your job.

By declaring our interests we can make sure we’re transparent in our business dealings. Group Ethics and Compliance reviews each registration and provides advice and guidance, so that you can avoid any potential problems, or just reassure you that you’ve done the right thing. If you don’t feel that you can approach anyone directly and want to speak in confidence, contact our Speak Up helpline.

My partner runs a small printing firm, and I’m sure they could make our leaflets for a lot less. Can I give them the contract?

No. Imagine how it would look if people realised you had given the contract to your partner. If your partner plans to bid for BT work, you must declare your relationship right away and someone else must oversee the procurement process.

Talk about it

See our short animation on conflicts of interest.

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We avoid conflicts of interest

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Different cultures have different attitudes to what’s acceptable. As an international business, we need to respect these differences, while staying true to our ethics code.

We have a gifts and hospitality policy to help you work out what is or isn’t okay. If you ever give or receive a gift or hospitality of any kind, you must follow the policy. You mustn’t give or accept a gift or hospitality if it’s intended to influence you or the person receiving it and you must not give or accept lavish or extravagant gifts and hospitality, whatever the situation.

You must register and get approval for any gifts and hospitality.

We don’t support or make donations (in cash or kind) to any political party, to the campaign of any candidate for elected office, or in support of any elected official. Although we respect the right of our people to personally support political activities, as long as they’re not related to BT.

If you need more help, contact Register gifts and hospitality.

Gifts and hospitality can be a normal and healthy part of building business relationships. But we never offer or accept gifts, payments or hospitality to encourage or reward a decision.

A business partner has invited me to a dinner that would be considered lavish in some countries – but it’s perfectly normal here. What do I do?

The best thing to do is use the Ask a Question service. Appearances count, even if you’re sure there’s no hidden agenda. Gifts and hospitality should be transparent and reasonable. If in doubt, politely decline. Remember to register and get approval in advance for the gift or hospitality if it is above the registration threshold.

Talk about it

We register gifts and hospitality

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We’re honest about our finances

We define fraud as theft, personal gain or advantage involving false representation, failure to disclose information, abuse of position or the distortion, suppression or falsification or records.

The facilitation of tax evasion and the failure to take reasonable steps to prevent the facilitation of tax evasion are criminal offences. They happen when a corporation fails to take reasonable steps to prevent an associated party facilitating tax evasion for a taxpayer under existing UK or overseas law.

The consequences of not following the rules on fraud or any other type of financial misconduct are serious and could result in large lines or prison sentences.

Insider dealing Insider dealing is a crime. BT people who hold shares in the company need to be particularly careful not to use any confidential information to influence them in buying or selling shares (or recommending to others that they do so).

Some senior managers need to get permission before they can buy and sell shares and may not be able to do so at certain times of year (e.g. around the annual results).

We don’t tolerate any type of financial misconduct including fraud, tax evasion and the facilitation of tax evasion or money laundering.

It is not public knowledge yet, but I know from my work that now would be a good time to buy BT shares. Can I tell my family and friends?

No, that’s insider dealing and the penalty for doing so could be serious.

Talk about it

If you’d like to report fraud or any other financial misconduct you can contact our Security Control Centre: In UK by calling 0800 321999 and outside UK by calling +44 1908 641100.

Or you can use our Ask a Question service.

To raise a matter anonymously in most countries, contact Speak Up.

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We compete fairly

In the UK and where people working overseas are in contact with UK customers, we must comply with all regulatory obligations which are enforceable by Ofcom in addition to our voluntary ‘Commitments’ where Openreach must treat communication providers equally. There are rules about disclosing customer confidential and commercial information to other parts of BT. And we have strict processes about how we engage with Openreach so they can operate independently of the rest of the company.

We believe in free markets. That means we respect the rights of our competitors to carry on their business, and we don’t pressure or coerce our customers into choosing us over our competitors. We can only make public statements about other companies as long as they’re accurate, up-to-date and relevant, and we comply with our regulatory obligations and the law in terms of where we get our information. But we’d rather talk about our own strengths than talk about our competitors.

We compete vigorously but fairly, being honest, respectful and trustworthy in all our dealings. We care about our customers, especially those who may be vulnerable.

There’s nothing wrong with using every resource we have to gain a legitimate competitive edge: our people, our knowledge, our experience. But we must act ethically in line with our values, policies, the law and our regulatory obligations.

Customers can be vulnerable in many different ways including financial, mental well-being, health, or a physical or mental disability. And vulnerability can be transient or permanent.

One of our suppliers is also a customer and a competitor. Are there any limits on how we can work together?

In theory, no. Collaboration is part of the telecommunications business. Some companies are our customers, suppliers and our competitors. We also need to work together with them on certain projects. That’s not necessarily a problem, but these relationships need to be handled carefully. For example, one part of the relationship shouldn’t depend on another.

You also need to take extra care over what information you share with (or gather about) companies who are our competitors – especially on pricing and costs.

Talk about it

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Although competition and fair trading laws vary from country to country, many have (or are bringing in) laws to prevent anti-competitive agreements, to stop one competitor undermining or sabotaging another, or to prevent powerful companies exploiting their customers. Always follow our ethics code – unless the local law requires a higher standard. If you’re not sure, speak to BT Legal.

If you need more help you can use our Ask a Question service.

You can also raise concerns confidentially via our Speak Up hotline. See our Commitments code of practice for BT and Openreach.

One of our competitors suggested we agree to avoid each other’s customers and territories. Is that OK?

No. It’s illegal in most countries and even discussing it is unethical and could be illegal. Report the conversation to your line manager right away or our Speak Up service. If you don’t, you and BT could end up facing fines or even criminal charges. Line managers can contact their compliance or competition teams for help.

Talk about it

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We protect information and keep BT assets safe

Customers, businesses and public sector organisations trust us to handle their personal data safely and securely. We have a set of binding rules which people working for, with and on behalf of BT need to comply with. These rules are summarised in our Privacy Principles. Everyone in BT has a responsibility to make sure that we handle data in line with these rules, our customer contracts and data privacy laws.

Never discuss or disclose data to colleagues (or people claiming to be colleagues) unless there’s a business need to do so.

Information about people Information about people is also known as personal data – this can be, for example someone’s name, address, telephone number, personal email address, account number, bank account or billing information. It includes data held on our systems, in paper documents, emails, call recordings, mobiles or other storage media.

There are extra rules about what’s known as ‘special categories of personal data’. Examples include information about someone’s health, race, religious beliefs, political opinions, trade union membership, biometric and genetic data or sexuality.

How we work If your job means that you handle special categories of personal data, you should understand how to do this compliantly.

If necessary, ask the data privacy team for advice before doing so. Legally we have to formally report data incidents to Data Protection Regulators.

So even if you’re not sure, always report any suspected data breach immediately to BT Security.

We protect the confidential and private details of our company, people and customers. We often need to use information to do our job. You should always treat such data like it was your own. Keep it safe and secure and think about how you would want things to be done if it were information about you.

What about when we’re using third party suppliers, we don’t need to worry about the Privacy Principles then, do we? Surely that’s for the third party to worry about?

We need to make sure that any third parties that handle personal data on our behalf take the right steps to protect it. This means more than simply having the correct data protection clauses in the contract.

Third parties must be open and transparent about how they handle our personal data and we must carry out the proper data due diligence before we do business with them. Remember, privacy is a brand impacting issue and we still remain primarily accountable for the personal data we hold. Speak to the Data Privacy team if you’d like help around third-party data-protection issues.

Talk about it

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Other information We also have to protect other information which isn’t about people. It might be about plans for a new product, it could be sales figures, details of how to configure some hardware, a risk register, information that could affect our share price, or even some information a customer wants to give us.

And to look after it securely we must first classify it and then handle it according to the classification.

If you need more help, contact BT Security.

I am having performance issues with some new software and want to share my configuration with the supplier, can I just email it to them?

No. You must first check the classification and what data the configuration contains, there may be information which is not appropriate for the supplier to see such as account and password details, IP addresses etc. There may also be requirements to securely send the data so we can be sure no-one else can see the information. Find out more in our policy and the data handling specifications.

Talk about itWatch our short film on Privacy by Design.

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My personal computer is much faster than my work computer, can I bring that in and use it instead?

People should normally use their BT-supplied machine for work because that’s been set up in a secure way. For example the hard drive is already encrypted, and when it’s connected to our networks it’s updated with the latest anti-virus and security software.

Your own device won’t be set up in the same way. So you mustn’t physically connect it to our networks, or download or save any of our information or that of our customers on your own device.

That’s so we can keep our data and that of our customers safe.

Talk about it

We must protect our physical, financial, intellectual and online assets. We’re all personally responsible for protecting our assets – whether it’s our buildings, vehicles, equipment, IT systems, property, information or knowledge and ideas. So we have a set of security policies which are the rules we must all follow.

If you need more help, contact BT Security.

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We’re using social media more these days so it’s important to understand what the implications of sharing information on social media are, both internally and externally. And how we can prevent risk to you and our brand reputation.

When using social media you must be mindful of how you represent yourself. You never know who’s looking at your posts; you may well be connected to colleagues, our customers, partners and suppliers. Even if you think it might be private, it might not be.

It’s a great way to promote our company and you’re allowed to use it from work for business and occasional personal use under our security policy.

But in some areas where employees are looking at sensitive information while at work, like our contact centres, you won’t be able to go online or use social media. Inappropriate behaviour involving social media will be dealt with under our disciplinary procedure and serious cases could be viewed as gross misconduct, which may result in dismissal. Stick to our social media guidelines to protect yourself, your colleagues and BT.

If you are concerned about any communications then speak to your line manager or Group Corporate Affairs. If you’d like to speak to someone in confidence, contact our Speak Up hotline.

I sometimes chat to work colleagues on social media about projects I’m working on at BT. That’s OK, isn’t it?

No. You shouldn’t use external social media to talk about work, this includes group or individual conversations. This is because we don’t have control over the data, as this sits with the company who runs the platform. If you’re sharing work information on social media, you could be leaking sensitive information or might end up becoming the victim of a social engineering attack. Both of these have serious consequences. Unless it’s been approved for use in BT, you would be in breach of security policies and the social media guidelines.

At work, make use of our internal social media tools, as they’re a great way to collaborate on projects. But even in work, make sure you’re not sharing anything sensitive or that could breach our regulatory obligations to Ofcom.

Talk about it

We act responsibly when we use social media

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We care about health,safety and wellbeing

Wherever we do business around the world, we do our very best to make sure it doesn’t injure or cause damage to anyone.

This includes checking that our people are protected at work. And that they have the information, training and equipment they need to do their job safely.

Work has proven benefits on health. Our way of working promotes this and we provide information and support allowing informed choices about the adoption of health-promoting behaviour.

We have a legal obligation to protect the health and safety of anyone who might be affected by our business. We also recognise that the better we care for our people, the more engaged and motivated they are to do their job to the best of their ability.

Keeping our people safe and well is a priority at us. We want our people to be happy and healthy. And we recognise that health is closely linked to business effectiveness. Keeping our people safe and healthy is a win-win situation for the company and for individuals whether at work or elsewhere.

Where to go for help. The Health and Safety handbook and the Health and Wellbeing pages on the intranet gives guidance to BT people. In the first instance, talk to your line manager if you have a health and safety concern.

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We look after the environment

We recognise that in our day-to-day operations we have an impact on the environment. As well as preventing pollution, we’re committed to minimising potentially harmful effects wherever and whenever possible; and making a positive contribution to the environment.

We expect everyone to follow the environmental laws and regulations that apply to them and our business, as well as following our environmental standards and commitments. Many of the commitments in our environmental policy affect our everyday working lives.

We want to:

• consume less

• reuse whenever we can

• recycle when we can’t reuse

• use more recycled materials in our products

• design new products, services and equipment to use less energy and natural resources

• manage energy and natural resources wisely in every part of our business.

Our environmental management system, which is certified to ISO 14001 standard, is designed to make sure we live up to these commitments day to day.

Our Designing Our Tomorrow toolkit helps us create products and services that include sustainability criteria in their design. It’s not just about looking after the health and safety of our people and customers, it’s about sustaining the environment that we, the economy and society depend on.

We’re committed to cutting pollution and minimising the impact on the environment of our operations around the world.

I rarely travel to meetings and use conferencing tools when possible. Does this mean that I’m doing everything I can?

Great news that you’re helping us meet our targets on carbon emissions, waste, transport, fuel consumption and emissions. We still need to be aware of any negative impact we have and reduce it – especially when it comes to our own travel and transport, fuel-use emissions and waste.

Talk about it

If you need more help you can use our Ask a Question service. You can also contact Speak Up.

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Offices Worldwide

The services described in this publication are subject to availability and may be modified from time to time. Services and equipment are provided subject to British Telecommunications plc’s respective standard conditions of contract. Nothing in this publication forms any part of any contract.

© British Telecommunications plc 2019. Registered office: 81 Newgate Street, London EC1A 7AJ. Registered in England No. 1800000.

April 2020