code of personal responsibility

7/25/2019 Code of Personal Responsibility

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CODE OF PERSONALRESPONSIBILITYTHE WAY WE DO BUSINESSIS BASED ON OUR VALUES

CONTACT US:Group Corporate Affairs

Lloyds Banking Group25 Gresham StreetLondon EC2V 7HN

[email protected]

Version 2.0 published November 2013
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CODE OF PERSONAL

RESPONSIBILITYCONTENTS

04. Foreword by Chief Executive

06. Introduction

10. Putting Customers First

12. Keeping It Simple

14. Making a Difference Together

16. Compliance with Code of Personal Responsibility

18. Help, Advice & Guidance

20. Decision Guide

22. FAQs


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OUR VISION IS TO BERECOGNISED AS THE BEST BANKFOR CUSTOMERS.

We believe that we can make our greatestcontribution to society by Helping BritainProsper, and that means serving the financial

needs of UK families, businesses andcommunities in a responsible way.

Using input from external expertsand colleagues across the Group wehave developed our Code of PersonalResponsibility and Code of BusinessResponsibility so that each of us candemonstrate our commitment, as individualsand as a business, to operating responsibly.

We expect all colleagues to live up tothe Codes of Responsibility, and we take

any non-compliance with the codes veryseriously. We acknowledge that we wontalways be perfect and there will be occasionswhen we get it wrong. When this happens,we commit to putting things right as quicklyand fairly as possible.

We can only be the Best Bank for Customersby building a great reputation foundedon the highest standards of responsiblebehaviour. The Codes of Responsibility willguide our decision-making and help us putinto practice our commitment to strive toalways do the right thing.

Antnio

On behalf of the Board, I strongly endorse and fullysupport the Codes of Responsibility. The way thatbusiness is conducted has never been more important.

Anita Frew, Group Non-Executive Director and Chair of theResponsible Business Committee

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FOREWORD FROM

CHIEF EXECUTIVEANTNIO HORTA-OSRIO

We can onlybe the Best Bank

for Customersby building agreat reputation

founded on thehighest standardsof responsiblebehaviour.Antnio Horta-Osrio,Group Chief Executive


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3. Challenge others when they are notoperating in line with the Codes ofResponsibility. If necessary escalate to aLine Manager, a Senior Leader in theirbusiness area, HR Advice and Guidance orthe Whistleblowing Line

We are expected to speak out if we haveany suspicion of inappropriate behaviourwhich violates the standards set out in theCodes of Responsibility (see Help, Advice &Guidance section). We provide mechanismsto facilitate disclosure if a colleague is unableor unwilling to inform their line managementand will thoroughly investigate all genuinereports. Furthermore, Lloyds Banking Groupdoes not tolerate any form of retaliationagainst colleagues or third parties who havemade reports of threatened, ongoing, pastor suspected violations of the Codes ofResponsibility.

This Code of Personal Responsibility includesa Decision Guide to help us if a situationarises where we are uncertain of the mostappropriate course of action. We areencouraged to use the Decision Guide andshare it with our teams to help us do the rightthing.

We recognise that this Code of PersonalResponsibility cannot cover every aspect ofthe way we should conduct ourselves and so,where relevant, we are expected to use ourown personal judgement to make the rightdecision.

Lloyds Banking Group is an initial signatory tothe Chartered Banker Professional StandardsBoard (CB:PSB). As part of our ongoingcommitment to professionalism in bankingwe have subscribed to the CB:PSB Code ofProfessional Conduct and have embeddedthe requirements in both our Code of

Business Responsibility and our Code ofPersonal Responsibility. More informationon the CB:PSB and its Code of ProfessionalConduct can be found here.

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CODE OF PERSONAL

RESPONSIBILITYINTRODUCTION

OUR CODE OF PERSONALRESPONSIBILITY REFLECTS THEBEHAVIOURS THAT WE ALL WANTTO BE KNOWN FOR.

That is why we have based it around ourGroup Valuesof Putting Customers First,

Keeping It Simpleand Making a DifferenceTogetheras these Values guide the way webehave and give us standards to measureourselves by.

The Code of Personal Responsibility is linkedto the Code of Business Responsibility(together, the Codes of Responsibility) whichunderpins the way we do business as aGroup. Both Codes of Responsibility havebeen developed to help guide colleagues incarrying out their roles in a way that helps uslive our Values and deliver against ourfive pillars of responsible business. These

pillars are:1. We put customers at the heart of ourbusiness.

2. We aim to be a great company to work for.3. We work responsibly with our external

stakeholders.

4. We invest in communities to help themprosper and grow.

5. We work to continually reduceenvironmental impact.

What do colleaguesneed to do?

All colleagues and those acting on behalfof, or representing, Lloyds Banking Group(such as contractors, consultants andother service providers) are required to

adhere to the Codes of Responsibility,and confirm they understand them, on anannual basis. Compliance with these Codesof Responsibility helps all colleagues tocontribute towards the delivery of our GroupValues and the five pillars of responsiblebusiness, and ultimately enables us toachieve our vision of being recognised as thebest bank for customers.

Colleagues are expected to adhere to theCodes of Responsibility in conjunction withour Personal Integrity Policy, Ethics Policy andour other Group Policies (see Useful Links).

All colleagues and those acting on behalfof, or representing, Lloyds Banking Groupare expected to adhere to the Codes ofResponsibility and are required to:

1. Take time to understand the Codes ofResponsibility and how they apply toour roles.

2. Operate in line with the Codes ofResponsibility in all aspects of our roles.
http://www.cbpsb.org/http://lbg.intranet.group/values/default.shtmhttp://lbg.intranet.group/values/default.shtmhttp://www.cbpsb.org/


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CODE OF

PERSONALRESPONSIBILITY

SUMMARISED HERE ARE THE KEYBEHAVIOURS WHICH ENABLEUS TO ENSURE THAT WE AREALIGNED TO OUR GROUPVALUES.

We recognise that for many colleagues, for

example in parts of IT or HR, their immediatecustomers may be other colleagues andso, where relevant, customer can meancolleagues orcustomers. We also recognise,however, that for every colleague, ourultimate customers are the people andbusinesses who depend on us every day fortheir banking and other financial services,and we must ensure that we always considerthem in our day-to-day roles.

In addition, we have implemented theChartered Banker Foundation Standardfor Professional Bankers. The FoundationStandard consists of a set of indicatorsthat assess professional knowledge, skills,attitudes and behaviours. Our internaltraining, assessment and performance

management approaches have beenbenchmarked against the FoundationStandard, and over 50,000 customer facingcolleagues across the Group have beenreviewed against the criteria.

As a result, Lloyds Banking Group has thelargest workforce in the UK banking industryto achieve the Foundation Standard.

To ensure the content is current, theCodes of Responsibility will be reviewed onan annual basis. Queries or comments canbe shared at any time by [email protected]

To access a copy of the Codes ofResponsibility suitable for sharing withpeople outside the Bank, please visitwww.lloydsbankinggroup.comanddownload the Codes of Responsibility fromwithin the Responsibility section.
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CODE OF PERSONAL

RESPONSIBILITYPUTTING CUSTOMERS FIRST

WE THINK ABOUT CUSTOMERSFIRST IN EVERYTHING WEDO, CONSISTENTLY STRIVINGTO TAKE ACTIONS TO DRIVETOWARDS POSITIVE CUSTOMEROUTCOMES.

YOUR COMMITMENT:

1.Think about customers first ineverything I do

I seek to design products, services orprocesses which put customers first and arereadily understandable and I will challengeothers who do not. I will always give easilyunderstandable and accurate descriptions ofthese products, services or processes to my

customers.

I comply with all current legal and regulatoryrequirements relevant to my role and strive toset a good example.

I take the time to understand how I can makea positive difference to customers livesthrough the products and services that theGroup provides.

2.Understand and anticipatecustomers needs

I serve my customers by listening to them,understanding and anticipating their needs

and aspirations, and delivering goodcustomer service.

I treat customers fairly, and serve themwith professionalism, respect, honesty andintegrity.

I consider the risks and implications ofmy actions and advice and hold myselfaccountable for them and for the impact theymay have on my customers, today and in thefuture.

3.Deliver on our promises tocustomers and each other

I deliver on my promises to my customersand when things go wrong, as they

sometimes do, I take responsibility to putthem right.

4.Take ownership to get thingsright for customers

I recognise the responsibility I have to deliverexcellent service to my customers and takeownership of any issues to ensure this isachieved.


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2.Communicate clearly andopenly

I communicate with customers, colleaguesand stakeholders in a way which is easy for

them to understand, including avoidingtechnical jargon and acronyms wherepossible.

3.Identify opportunities to simplifythe things we do

I challenge others if I believe a process orprocedure is unnecessarily complicated, andprovide suggestions on how to improve it.

4.Work to get things right firsttime, every time

Where things are not right first time, I willwork to swiftly and simply resolve the

issues. Where processes make it difficult toget it right first time, I will work to improveprocesses and procedures.

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CODE OF PERSONAL

RESPONSIBILITYKEEPING IT SIMPLE

WE MAKE OURSELVES EASYTO DO BUSINESS WITH,COMMUNICATING CLEARLYAND PROACTIVELY SEEKINGOPPORTUNITIES TO DELIVERIMPROVEMENTS FOR A SIMPLER

CUSTOMER OR COLLEAGUEEXPERIENCE.

YOUR COMMITMENT:

1.Make ourselves easy to dobusiness with

When designing processes or procedures,I will ensure that I make them as simple aspossible to avoid unnecessary bureaucracy,thereby making it easier for my customersand my colleagues.

I ensure that any internal processes orprocedures are designed in a way whichmakes it easy for different teams anddivisions within the Group to work together.

Rather than designing a new process orprocedure from scratch, where relevant I willseek to follow best practice from other teamsacross the Group.


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CODE OF PERSONALRESPONSIBILITYMAKING A DIFFERENCETOGETHER

WE WORK TOGETHERCONSISTENTLY IN ACOLLABORATIVE WAYWITH COLLEAGUES ANDSTAKEHOLDERS TO CONTRIBUTEPOSITIVELY TO THE CUSTOMERS

AND COMMUNITIES WE SERVE.YOUR COMMITMENT:

1.Work together to deliver forcustomers

I listen to and work with my colleagues toensure that I always put the customer first andI challenge those who do not.

I seek to develop my knowledge and skills to

enable me to enhance my contribution to theGroups performance.

2.Use feedback to improve whatwe do

I take the time to listen to my customers tohelp me understand how I can better support

them to deliver value to them and LloydsBanking Group.

3.Treat people fairly and actresponsibly at all times

I treat my colleagues as they would wish to betreated, recognising that we are all different.

I will not discriminate against any individual orgroup based on factors which are irrelevant totheir ability to do their job.

I lead by example and act as a positive rolemodel.

I treat individuals who raise an issue, report abreach or participate in an investigation withrespect and good faith and in such a way thatencourages colleagues to raise concerns.

I acknowledge and promote a healthybalance between work and home lives, andrespect the commitments that others haveoutside of the work environment.

I consider all the risks and implications ofmy actions and advice and hold myselfaccountable for them and for the impact theymay have on my colleagues and communities.

I act in a professional, ethical and sensitivemanner when dealing with confidentialinformation to ensure that confidentiality ismaintained. I always behave in an appropriatemanner at work-related events whether withinor outside of office hours.

I always ensure that my communications,whether written or verbal, which relate to,or could be associated with the Group,for example through Social Media, are ofan appropriate nature and will not bringembarrassment to, or harm the reputationof the Group, my colleagues, customers orsuppliers.

4.Contribute positively to thecommunities I serve

I take the time to listen to my customers andcolleagues to help me understand how I cansupport and work with them to deliver valueand contribute positively to the communitiesin which we live and work.

I seek to understand the environmental andcommunity impacts associated with my roleand take these into account when makingdecisions which have an impact on thecommunities in which we live and work.


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COMPLIANCE WITH

THECODE OF PERSONALRESPONSIBILITY

WE REQUIRE COLLEAGUESTO EVIDENCE THATTHEY UNDERSTAND THEREQUIREMENTS OF THE CODEOF PERSONAL RESPONSIBILITY,ON AN ANNUAL BASIS.

Failure to comply with this Code of PersonalResponsibility, the Code of BusinessResponsibility, the Personal Integrity Policy,the Ethics Policy or any of our other GroupPolicies, regulations or codes of conductlaid down by external authorities (e.g. theRegulators, British Bankers Association,Association of British Insurers) may result insevere consequences for Lloyds BankingGroup and/or its employees. This may,therefore, constitute grounds for disciplinaryaction, which could potentially includedismissal or, in some circumstances, criminalprosecution.

We recognise that in some circumstances,failure to comply with the Codes ofResponsibility may be due to capability ora need for additional training or support.Where this is the case, the relevantPerformance Management or PerformanceImprovement Policy will be used to address

concerns to ensure that colleagues aretreated fairly and are given appropriatemanagement support, coaching and trainingto improve their performance.

For Lloyds Banking Group Colleagues Only:

All colleagues are required to review andcomply with all of the Group Policies whichare relevant to their roles. The Group Policyframework is published on Interchange andcan be accessed by clicking here.

Further information on the underlying HRpolicies can be accessed on Interchange byclicking here.
http://lbg.intranet.group/group_risk/Group_Policy/default.shtmhttp://lbg.intranet.group/colleague_support/default.shtm?WT.mc_id=192http://lbg.intranet.group/colleague_support/default.shtm?WT.mc_id=192http://lbg.intranet.group/group_risk/Group_Policy/default.shtm


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Useful Links1.Code of Business Responsibility

2.Lloyds Banking Group annual ResponsibleBusiness Report

3.For Lloyds Banking Group ColleaguesOnly:

a. We are required to review and comply withall of the Group Policies which are relevantto our roles. To access the Group Policyframework on Interchangeclick here.

b. Further information on underlying HRPolicies, including the Personal IntegrityPolicy, and contact details for HR Adviceand Guidance can be accessed onInterchangehere.

Contact UsAlthough the Codes of Responsibility willbe reviewed on an annual basis, any queriesor comments can be shared at any time byemailing Responsible Business Mailbox [email protected]

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CODE OF PERSONAL

RESPONSIBILITYHELP, ADVICE AND GUIDANCE

If you believe that you have witnessedsomething which contravenes the standardsof personal or business conduct outlinedin this Code of Personal Responsibility, theCode of Business Responsibility, our PersonalIntegrity Policy or our other Group Policies,you must discuss this with someone via one

of the routes below:1. Your first port of call should be your Line

Manager (who is the person you report toon a day-to-day basis).

2. If you are unable or unwilling to speak toyour Line Manager, you should speak toanother Senior Leader in your businessarea, such as your Line Managersmanager.

3.If none of these options are possible oryou feel your concerns are not beingaddressed by your Line Manager, youshould raise your concerns through

HR Advice and Guidance or theWhistleblowing Line. The Whistleblowing

Line provides colleagues with amechanism for expressing their concernsabout wrongdoing in the workplace.All concerns raised are taken seriouslyand fully investigated. The identity ofcolleagues who raise a concern will bekept confidential, and no colleague will

be discriminated against in any way as aresult of raising an issue. Please see theWhistleblowing FAQ for more information.

For Lloyds Banking Group Colleagues Only:

Colleagues should read the Guidance onHow to Make a Whistleblowing Reportbefore contacting the Whistleblowing Line toensure the report is made correctly. Reportscan be made by email, phone or web based.Contact details can be found on Interchangeby clicking here. Mandatory training onWhistleblowing is available internally to allcolleagues.
http://lbg.intranet.group/corporateresponsibility/PDF/Code_of_Business_Responsibility.pdfhttp://www.lloydsbankinggroup-cr.com/http://www.lloydsbankinggroup-cr.com/http://lbg.intranet.group/group_risk/Group_Policy/default.shtmhttp://lbg.intranet.group/colleague_support/default.shtmmailto:Responsible.Business%40lloydsbanking.com?subject=http://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://lbg.intranet.group/pandp/whistleblowing/default.shtmhttp://lbg.intranet.group/pandp/whistleblowing/default.shtmhttp://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfmailto:Responsible.Business%40lloydsbanking.com?subject=http://lbg.intranet.group/colleague_support/default.shtmhttp://lbg.intranet.group/group_risk/Group_Policy/default.shtmhttp://www.lloydsbankinggroup-cr.com/http://www.lloydsbankinggroup-cr.com/http://lbg.intranet.group/corporateresponsibility/PDF/Code_of_Business_Responsibility.pdf


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Are my actionsconsistent with our

Group Values of PuttingCustomers First, Keepingit Simple and Making aDifference Together?

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CODE OF PERSONAL RESPONSIBILITY DECISION GUIDEHELPING YOU TO DO THE RIGHT THING

For the occasions in which an issue or situation arises and you are uncertain how to proceed, use the following guide to help you do the right thing,whilst remembering Lloyds Banking Groups basic expectations of your behaviour and conduct as detailed in the Codes of Responsibility.

All questions below should be taken into account they are in no particular order.

WouldLloyds

Banking

Group becomfortableif my actions

werereported

externally?

Am I leadingby example?

Will my colleaguesalso be able to behavein line with the Codes

of Responsibility

following my actions?

Am I suremy actions

are legal andcompliant?

If not, canI seekguidance to

help me makean informed

decision?

Would Ibe happyto tell my

colleagues,family and

friends aboutmy actions?

NO/NOT SUREIf you answered No/Not Sure to one or more of the questions:Contact your Line Manager or a responsible Senior Leader in your

business area for further advice and guidance.

If this is not possible, or has been unsuccessful, contact HR Advice and Guidanceor the Whistleblowing Line.

YESIf you answered Yes to all of the above questions, this indicates thatyou are operating in line with the Codes.

You can proceed as appropriate, subject to normal sign-off procedures,commercial and business as usual considerations.

Have I understood the risksand possible implications

of what I am doing?

Are my actions in linewith the Codes of

Responsibility and GroupPolicy guidelines?Click here for Policies
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CODE OF PERSONAL RESPONSIBILITYTHE WAY WE DO BUSINESS ISBASED ON OUR VALUESFAQs

1.How does the Code of PersonalResponsibility differ from thePersonal Integrity Policy?The Personal Integrity Policy underpins theCode of Personal Responsibility and is one ofthe many Group Policies which is referencedwithin the Code. The Code of PersonalResponsibility has been designed to engagecolleagues and is suitable for sharing withour external stakeholders. As with all otherGroup Policies, colleagues may be subject todisciplinary procedures if they do not adhereto the Personal Integrity Policy, and this alsoapplies to non-adherence to the Code ofPersonal Responsibility.

2.Why do we have both a Businessand Personal Code of Responsibility?Our Code of Business Responsibility gives anoverview of how Lloyds Banking Group, as anorganisation, conducts responsible businesson a day-to-day basis, whereas the Code ofPersonal Responsibility is about how eachand every colleague is expected to conductthemselves. Each of us has a part to play in

shaping a culture based on our Group Valuesat Lloyds Banking Group and the Code ofPersonal Responsibility will help us to achievethis. It is important that colleagues read andunderstand both Codes of Responsibility asany behaviour which goes against the Codesof Responsibility may result in disciplinary

action.

3.What are my responsibilities withregards to adhering to the Codes ofResponsibility?You are required to review the Codes ofResponsibility each year as part of theMandatory Training curriculum. Once youhave completed the training, it is expectedthat you understand your responsibilitiesunder both Codes of Responsibility, and

adhere to them every day.

4.What will happen if I dont act inaccordance with either of the Codes

of Responsibility?If you do not operate in accordancewith the Codes of Responsibility, or thePersonal Integrity Policy, depending onthe circumstances, you may be subject todisciplinary procedures.

5.Can I share the Codes ofResponsibility with my stakeholderswho are not employed by LloydsBanking Group?Yes. Both Codes of Responsibility have beendesigned so they are suitable for sharing withour external stakeholders.

6.A customer has complained thatLloyds Banking Group has not actedin accordance with our Codes ofResponsibility what should I do?You should first ensure that you understandexactly which part of the Codes of

Responsibility the customer is referring toand should treat the complaint as you wouldany other complaint. You are then advised tospeak to your Line Manager who will engagethe necessary teams within the Group forsupport where necessary, such as GroupLegal or Group Risk.

7.I am unsure about the correct courseof action to take to resolve an issue

I have and need to make a quickdecision what can I do?If a situation arises where you would likesome guidance as to the correct courseof action to take, you should refer to theDecision Guide within the Code of PersonalResponsibility as this will prompt you to askyourself some key questions before youproceed. You should also speak to your LineManager who will be able to offer furtherguidance.

8.I have read the Codes ofResponsibility and reviewed ourGroup Policies but I am still not sureon what the right course of action is what should I do?If a situation arises where, despite reviewingboth Codes of Responsibility and therelevant Group Policies, you remain unsure ofthe right course of action, you must speak toyour Line Manager or another Senior Leaderin your area for guidance.


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9.I am concerned that a colleague isnot acting in accordance with the

Codes of Responsibility and haveraised this with my Line Manager,but I do not feel that they are fullyaddressing my concerns whatshould I do?If you are concerned that a colleague hasbroken, or is about to break, the Codes ofResponsibility, and you feel your concernsare not being suitably addressed by yourLine Manager, you should speak to anotherSenior Leader in your area. If you still feeluncomfortable, you can call HR Advice andGuidance or the Lloyds Banking Group

Whistleblowing Line. (For Lloyds BankingGroup Colleagues Only: More informationon Whistleblowing can be found on theInterchange by clicking here.)

10.I have followed regulatoryrequirements to resolve an issuewith a customer but they are still nothappy and have made a complaintto the Financial OmbudsmanService. I am concerned that I

may be disciplined for not havingfulfilled all of the Code of PersonalResponsibility commitments underPutting Customers First but I didnot feel I had a choice will I bedisciplined?Situations will arise when you may feel thatyou are breaking the Codes of Responsibilitybecause you are following a regulatory

procedure which does not appear to bein line with our Group Value of PuttingCustomers First. You must always followregulatory procedures and if you feel thismeans that you are breaking the Codes ofResponsibility, you should talk to your LineManager for guidance.

11.I do not deal directly with customers,so do the sections in the Codesof Responsibility which refer tocustomers still apply to me?Yes. The Codes of Responsibility still applyto you.

We recognise that for many colleagues, for

example in parts of IT or HR, their immediatecustomers may be other colleagues andso, where relevant, customer can meancolleaguesorcustomers. We also recognise,however, that for every colleague, ourultimate customers are the people andbusinesses who depend on us every day fortheir banking and other financial services,and we must ensure that we always considerthem in our day-to-day roles.

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12.My Line Manager has asked meto do something which I do not

feel comfortable with and which Ithink is not in line with the Codes ofResponsibility do I still have to do asmy Line Manager has asked?No. You should speak to your Line Manager,in the first instance, to explain your concernsthat their request would require you tobreak the Codes of Responsibility and tounderstand why they have asked you to carryout the task. If after discussing this with yourLine Manager you are still uncomfortable,you should speak to another Senior Leaderin your area. If you still feel that your concernsare not being addressed and need furtherguidance, you should call HR Advice andGuidance or the Whistleblowing Line. (ForLloyds Banking Group Colleagues Only:More information on Whistleblowing can befound on the Interchange by clicking here.)

13.Im concerned that Ive donesomething which is not in line withthe Codes of Responsibility whatshould I do?

You should speak to your Line Managerimmediately to ensure that you understand anypossible negative implications of your actions.If your Line Manager is not available, youshould speak to another Senior Leader in yourarea. If after doing so you still have concerns,you should call HR Advice and Guidance orthe Whistleblowing Line. (For Lloyds BankingGroup Colleagues Only: More information canbe found on the Interchange by clicking here.)

14.I have an issue which I cannot talk tomy Line Manager or a Senior Leader

about and so I think I need to callthe Whistleblowing Line for help isthere anything that this Line cannothelp me with?Yes. If you are unable to talk to your LineManager or a Senior Leader in your area,concerns over issues such as bullying,harassment, discrimination, careerprogression, workloads, pay awards and/orother terms and conditions of employmentshould be raised through the Groups HRAdvice and Guidance Line. More details ofthe types of issue for which it is appropriateto make a Whistleblowing report are setout in the Guidance on How to Makea Whistleblowing Report. Customercomplaints should be remedied via thenormal Complaints Governance processin the first instance. Reports made to theWhistleblowing Line which relate to issuesthat do not fall within the scope of theWhistleblowing Policywill not be treated aswhistleblowing cases and will be redirectedto the appropriate area.

15.I have spotted something in theCodes of Responsibility which I thinkshould be changed who should Icontact?Your feedback is welcome so please [email protected]
http://lbg.intranet.group/pandp/whistleblowing/default.shtm?WT.mc_id=280http://lbg.intranet.group/pandp/whistleblowing/default.shtm?WT.mc_id=280http://lbg.intranet.group/pandp/whistleblowing/default.shtm?WT.mc_id=280http://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://lbg.intranet.group/group_risk/Group_Policy/whistleblowing/whistleblowing_dgp.shtmmailto:Responsible.Business%40Lloydsbanking.com?subject=mailto:Responsible.Business%40Lloydsbanking.com?subject=http://lbg.intranet.group/group_risk/Group_Policy/whistleblowing/whistleblowing_dgp.shtmhttp://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://teamspace.intranet.group/sites/Group_Risk/Group_Policies/Whistleblowing/2013/Supporting_Documents/Whistleblowing_Report_Guidance_v3.0_092013.pdfhttp://lbg.intranet.group/pandp/whistleblowing/default.shtm?WT.mc_id=280http://lbg.intranet.group/pandp/whistleblowing/default.shtm?WT.mc_id=280http://lbg.intranet.group/pandp/whistleblowing/default.shtm?WT.mc_id=280