Tullett Prebon plc Annual Report 2010
Corporate social responsibility
Throughout the reporting period the Company continued to provide support for the efﬁcient operation of the global capital markets, which helped to ensure that its clients were able to continue to prosper and to achieve their own business objectives, and to meet expectations of their own shareholders and their other stakeholders. In this way Tullett Prebon found continued expression for its positive contribution to society more widely. By successfully providing a critical component of the global capital markets infrastructure Tullett Prebon is best able to maximise returns to shareholders over the medium to long term. As a publicly listed company Tullett Prebon continues to enjoy a positive record in creating value for both institutional and individual investors. In turn this allows the Company to make a signiﬁcant contribution to society through social transfer payments in the form of tax remittances. The Company intends that its high standards of governance and business ethics contribute to the wider social good through the example it sets and the high standards it maintains, both in the United Kingdom and in all other geographies where the Company is present, complying with all laws and regulations, trading fairly, and only participating in legitimate trading activities permitted by its various licences. Governance Responsibility for social, ethical and environmental matters rests with the Board, and is included in its terms of reference. The Chief Executive Ofﬁcer is the Board member responsible for Corporate and Social Responsibility (‘CSR’). The Company’s CSR Governance Committee, which was established in 2009 in recognition of the increasing importance of the CSR agenda and which comprises all members of the Company’s Executive Committee, oversaw and helped reﬁne the CSR activities of the Company in 2010. This Committee and its members in their executive roles will continue to oversee and guide the CSR activities of the Company, reﬂecting the continued importance the Company places on this broad and increasingly visible area of responsibility.
Ethical issues The Company’s approach to ethical behaviour and corporate governance is speciﬁcally written into policy and Tullett Prebon documents, for observance by all members of staff, and provide for: – Maintaining high standards of compliance and risk management activities – ultimately reporting to the Chief Executive and monitored by the Board and Audit Committee; – Fully complying with legal and regulatory requirements in each of the jurisdictions in which it operates, including the Financial Services Authority’s Conduct of Business Sourcebook and the Bank of England’s Non-Investment Products Code; – Disallowing corrupt practices such as inappropriate payments to any third party – directly or indirectly; – Fully complying with tax laws in each of the jurisdictions in which it operates relating to its affairs and the deduction of taxes from staff remuneration; – Trading fairly, knowing its clients and properly understanding its trades with its clients. The Company has a policy of not participating in trading activities which it suspects may not be for legitimate trading purposes, or whose sole purpose appears to be tax reduction by the counterparty; – Guiding employees involved in procurement activities, including a requirement to adhere to the highest ethical and social standards; and – Maintaining appropriate guidelines on gifts, hospitality, entertainment and conﬂicts of interest.
Attracting and retaining the best brokers, professional and other support staff, and management remain crucial to the Company’s ongoing success. Management recognise that the Company’s ability to maximise returns to shareholders is dependent on employing and retaining the best staff in all the geographies in which it operates. The Company is committed to developing and motivating its staff and offers training where appropriate and measures performance to achieve this objective. Building on the management training review conducted in 2009 as part of the succession planning process, the Company undertook an extensive middle management career development programme across its European businesses in 2010. This involved some 50 directors and desk heads from the United Kingdom, France, Germany, Luxembourg, Poland and Switzerland completing a ﬁnancial analysis and training package designed and delivered by staff from one of the United Kingdom’s leading business schools. Concurrent with the director and desk head development programme, a parallel development programme for the Company’s Managing Directors across its European ofﬁces was also launched and will continue into the subsequent reporting period. Together, these two development programmes will provide the foundations for the Company’s succession planning in its European region.
Policies and ethical issues
The Board expects the Company to maintain high standards of governance and of ethical behaviour throughout the business, and policies and procedures exist to ensure employees at all levels maintain the standards that are set and which are expected of them. Policies on equal opportunities Tullett Prebon is committed to attract, retain, develop and advance the most qualiﬁed persons without regard to their race, ethnicity, religion, or belief, gender, age, sexual orientation or disability. This commitment is underpinned by policies on equal opportunities, harassment and discrimination, to which all employees are required to adhere.