Code of Ethics

Code of Ethics

We believe business should be a force for good, for our people, our customers, our partners, our communities, and our planet. Our commitment to ethical conduct is not only as a compliance exercise, but as a reflection of who we are.

Our Code of Ethics is rooted in our core values, which shape how we work, how we lead, and how we grow together.

Our values in practice

We Own It

We take as much individual responsibility as we can. Our long-term success comes from listening, learning and constantly improving.

• We own our actions and their impact on our people, our customers, our suppliers, our communities, and on the planet.

We are Creative

We continuously innovate and are tenacious in helping our customers, suppliers and each other to find the solution to achieve their goals.

• We approach challenges ethically, with curiosity and determination to do better.

We are Better Together

We have a friendly, open culture of collaboration with our customers, suppliers and each other, helping us to achieve the best results and overcome even the most difficult challenges.

• We build relationships based on respect, inclusion and shared success.

We are Authentic

We do what we say. Being honest, straightforward and humble builds trust in everything we do.

• We are committed to honesty, integrity and transparency in every interaction

• Commitment to all stakeholders

We balance commercial success with positive impact, ensuring we consider the effects of our decisions on:

• Employees
  • Fair pay and safe working conditions
  • Work-life balance and wellbeing
  • Opportunities for development and advancement
  • A culture guided by fairness, diversity, inclusion, and respect

Related policies: Equal Opportunities, Health & Safety, Learning & Development, Inclusive Recruitment see Employee Handbook

• Customers and Suppliers
  • Clear, honest communication
  • Mutual respect, confidentiality, and fair competition
  • Long-term partnerships based on shared goals

Related policies: Supplier Code of Conduct, Modern Slavery and Human Trafficking Policy.

• Communities
  • Positive local impact through engagement and volunteering
  • Support for local economies and responsible sourcing
  • Civic awareness and community investment

Related policies: Charity Top-up, Volunteering Policy

• The Environment and Global Community
  • Reducing our environmental footprint
  • Promoting responsible logistics and transport solutions
  • Making sustainability a core part of innovation

Related policies: Environmental Policy, Sustainability Plan (SFN)

2. Ethical conduct and compliance

We are committed to:

• Legal and Regulatory Compliance – We comply with applicable laws and regulations where we operate and, when required, rely on local experts and partners for guidance.
• Anti-Corruption and Fair Dealing – We have a zero-tolerance approach to bribery, corruption, or unethical influence. This includes a strict prohibition on offering, giving, requesting, or accepting bribes in any form, such as kickbacks, gifts, hospitality, or hidden payments connected to contracts.

See: Anti-Bribery & Corruption Policy

• Modern slavery and fair labour standards – We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to fair working conditions, responsible supplier selection and clear reporting routes for concerns.

See: Modern Slavery and Human Trafficking Policy and annual statement.

2552. Whistleblowing via Speak Up – Everyone has the right to speak up about unethical behaviour. Concerns can be raised confidentially through Health Assured Speak Up service by calling 0800 206 2552. This is the main Health Assured reception line, once connected, please state that you would like to be referred to the Whistleblowing/Speak Up service. Reports are handled fairly, respectfully, and without retaliation.

See: Whistleblowing Policy

• Accountability and Consequences – Violating this Code or any linked policies may lead to disciplinary action, up to and including termination of employment, contract, or service.

         3.Continuous improvement

We believe ethics is not a one-time declaration, it’s something we continually refine through:

• Annual Review – the Board of Directors reviews this Code each year and approves any changes (evidenced in board meeting minutes)
• Annual instruction – all employees complete refresher: managers complete a manager specific module and resign the code each year.
• Induction– new employees are introduced to our Code at induction.
• Internal audit – compliance reviews keep us accountably.
• Feedback Loops – employees (via Connect Reps), suppliers, and customers provide feedback via surveys, which is acted upon.
• Updates –When changes to this Code are approved by the Board, they will be communicated promptly to all relevant stakeholders, and a record of this communication will be maintained for accountability and audit purposes.

4. Donations, sponsorships, and political contributions

We make all financial and in-kind contributions including charitable donations, sponsorships, and any permitted non- partisan political engagement with integrity, transparency, and in line with our values. We do not make financial or in-kind donations to political parties or politicians. Any permitted contributions, such as community sponsorships or support for advocacy groups, must always comply with the law and avoid any real or perceived conflict of interest.

• Formal board-level oversight – All contributions, whether financial or in-kind, are reviewed and approved by the Board of Directors through a structured, documented process that ensures accountability, compliance, and alignment with our values.
• Public disclosure – We will publicly disclose all financial and in-kind contributions to lobby groups, charitable organisations, and advocacy groups in our annual financial statements or another public report.

The Board of Directors reviews this part of the Code annually and receives refresher training on its contents, with meeting minutes kept as evidence of this review.

5. How we embed ethics

To put this Code into practice, we use:

• Mission Lock – embedding ethical purpose into our Articles of Association.
• Board Accountability – ethics is a standing Board agenda item. Directors sign annual declarations of commitment.
• Clear Ownership – responsibilities are defined across HR, Compliance, Sales, Finance, Marketing, and Line Managers.
• Culture & Communication – the Code is published internally and externally.
• Third-Party Integration – suppliers and contractors must sign the Code or demonstrate equivalent standards. Speak Up access is extended to all partners.
• Measuring & Reporting – KPIs track performance (e.g., % staff re-signs, supplier signoffs, CO₂ per shipment, volunteering hours). Results are disclosed in annual reports.

6. Scope and applicability

This Code applies to all employees, directors, contractors, customers, suppliers and third-party partners working with or representing Baxter Freight Ltd.

7. Final statement

By living this Code and holding each other to it, we aim to build a business that’s not only successful, but meaningful, trusted and lasting.