Here at TrustFord, PartsPlus and Quicklane, we know that we’re only as strong as the communities in which we work. So we actively look for ways in which we can provide help and support.

We see being a good corporate citizen as an essential part of how we do business. We’re committed to investing in our people, being a trusted business for our customers and being a great business partner to work with – as well as being a great place for our shareholders to invest.

What’s more, we work hard to minimise the impact we have on the environment and support our local communities.

Guiding Principles

We want to develop long-term partnerships with suppliers that share our view on corporate social responsibility. That’s why we’ve developed these basic policies and business practices, to show how we operate and outline what we expect from our suppliers.

• We expect all our suppliers to work in line with all the relevant regulations and legal requirements.
• We also expect them to operate ethically, to maintain high standards of corporate conduct, to respect the welfare and wellbeing of their employees and to respect the environment and communities in which they operate.
• We provide clear lines of communication with suppliers and actively seek feedback from them on our own behaviour and conduct.
• We respect the confidentiality of information provided by our suppliers. We don’t share this with third parties without specific approval to do so, and we always respect our suppliers’ intellectual property, only using it how and where permitted.
• We expect all suppliers who are visiting or working on our sites to apply safe working practices and consider the safety of their own employees, TrustFord colleagues and customers.

Corporate ConductWe conduct our business fairly, honestly and openly. We comply fully with the spirit as well as the letter of all applicable laws, rules and regulations, including the Bribery Act 2010.

Bribery & Corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duties and encourage them to act in a way that a reasonable person would consider to be dishonest in the circumstances. With that in mind, we have a zero tolerance approach to bribery and corruption.All our colleagues are made aware that there are criminal penalties associated with breaching the Bribery Act 2010. These penalties can affect both individual colleagues and the business.Although friendly relationships with external organisations are desirable and may be advantageous, our employees are guided by high standards of personal conduct and integrity. Not only should colleagues avoid favouritism, preferential treatment and unethical business practices, they should also avoid conduct that might be misinterpreted by others or might provide any basis for question as to its propriety.

Gifts/Awards from Suppliers or Other Third Parties

None of our colleagues are permitted to directly or indirectly accept any incentives from any supplier or other third party without written approval from their direct line manager. This includes things like awards, trips, vouchers, gifts, any other form of inducement or any benefits offered as part of any sales promotion.If the incentives are approved, the recipient will be personally responsible for any related tax liability. If the supplier of the incentive takes responsibility for this tax contribution, this must be documented to provide a robust audit trail.

Gifts/Awards to Customers or Other Third Parties

Our colleagues are not permitted to directly or indirectly offer any incentive to any customer or third party without the prior written approval of a TrustFord Board member. This includes incentives such as awards, trips, vouchers, gifts or any other form of inducement.This also includes offering an incentive to our customers’ employees as part of a sales promotion. This will also require prior written approval from a TrustFord Board member.

Corporate Entertaining / Hospitality

Our colleagues are not permitted to accept any form of corporate or social entertaining – including, but not limited to, meals, evenings out, invitations to sporting or cultural events – unless they have prior written approval from a TrustFord Board member.What’s more, none of our employees are allowed to offer any form of corporate entertaining to any customer, supplier or other party without the express and prior written approval of a Leadership Team member or above.The giving or receipt of corporate entertaining will only be considered for approval only if it is:

• offered or received for a legitimate business purpose
• proportionate - neither lavish nor frequent
• not intended to induce an employee or third party to perform a function improperly

Our colleagues are permitted to accept invitations to legitimate business functions such as complimentary seminars or training courses, which are offered by third parties (e.g. lawyers, accountants, pension advisors, etc.) if they have written approval from their line manager.Data ProtectionThe TrustFord data protection policy sets out our commitment to protect data and how we implement this with regard to the collection and use of data.

NOTE: Any references to "data" within this policy refers to personal (including customer), employee and corporate data.

We are committed to:

• ensuring that we comply with the policies set out below in order to meet our legal obligations as laid down by the current Data Protection Act (DPA).
• ensuring that data is collected and used fairly and lawfully
• processing data only in order to meet our operational needs or to fulfil legal requirements
• taking steps to ensure that data is up to date and accurate
• establishing appropriate retention periods for data
• ensuring that data subjects' rights can be appropriately exercised
• providing adequate security measures to protect data
• ensuring that a nominated officer is responsible for data protection compliance and provides a point of contact for all data protection issues
• ensuring that all staff are made aware of good practice in data protection
• providing adequate training for all staff responsible for data
• ensuring that everyone handling data knows where to find further guidance
• regularly reviewing data protection procedures and guidelines within the organisation.

How we look after data

Personal, employee and corporate data is any data or information that we hold as a Company. It refers specifically to an individual or business that has previously, or may in the future, have dealings with us.All data records (eg deal files, salary details, or corporate information) are kept in areas of the building with restricted access to members of the public at all times. Where this is not possible, data is kept in locked cabinets – these must be locked during the day and only opened when information is needed. Data must not be left unattended on desks or other exposed areas.It is our responsibility to ensure that this data is processed fairly and lawfully. Everybody within the business that deals with it has clear guidelines within which to work.

• We only collect information provided by individuals and Companies.
• We only use it for the specific purpose for which it was sought, and in the way that the individuals and Companies have consented to.
• Their data must be deleted or updated upon request.
• If an individual or Company no longer wishes to receive the information for which their data was collected, or requests for their data to be deleted or amended for any reason, a written request will be submitted to the Dealership Secretary, or equivalent, or other nominated officer.
• To dispose of data, either by the request of individuals and Companies or by direction of TrustFord management, provision will be made to completely destroy the data, either by permanent deletion from electronic records, or by shredding of paper records.
• All records awaiting collection by a third party for destruction are subject to the same controls as above. Any skips or bins containing personal data will be kept locked at all times.
• Third parties must also provide a Certificate of Destruction, without delay, on every occasion.
• All third parties processing TrustFord confidential customer data must be covered by a confidentiality and service level agreement which details the requirement to comply with this policy.

Here at TrustFord and TrustFirstParts, we aim to be recognised as an employer of choice. We adopt the highest standard of employment practices, being fully compliant with both the spirit and the letter of all applicable laws and regulations.

Equal Opportunities

It’s our policy to treat all job applicants, colleagues and customers in the same way, regardless of culture, ethnic or national origin, or any other protected characteristics as determined by the Equality Act (2010) which include race, sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, pregnancy, maternity, religion and belief, or any other grounds. We want to create a business where we value and respect each other, recognising the contribution that we all have to bring. Everything that we do and say has an impact on the person sitting next to us. To be truly successful, we must all consider this in our working lives. We treat our colleagues the way that that we would like to be treated and we’re aware that what one person thinks is an innocent comment or joke could be offensive to someone else. This policy applies to the advertisement of jobs, recruitment, and appointment of new colleagues, training, terms and conditions and to every other aspect of employment at TrustFord. We maintain a neutral working environment in which no worker feels under threat or intimidated. This policy also applies to the treatment of our customers. Any colleague who contravenes this equal opportunities policy will be subject to our disciplinary procedure. In serious cases, this behaviour will constitute gross misconduct resulting in summary dismissal.

Harassment

Any kind of harassment or bullying within the workplace is not tolerated. All cases will be dealt with discreetly but firmly. Harassment is determined as: any unwanted verbal, non-verbal or physical conduct, which another individual considers violates his or her dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. Conduct may become harassment or bullying if it continues after the recipient has made it clear that it’s regarded as offensive. However, a single incident may amount to harassment or bullying if it is sufficiently serious. We're committed to ensuring that colleagues feel able to raise complaints about harassment and won’t be penalised for doing so, unless the complaint is found to be malicious. If one of our colleagues is found to have been harassing or bullying another employee or customer, disciplinary action may be taken – up to and including summary dismissal. This policy also covers instances where a colleague may feel harassed or bullied by third parties such as customers, suppliers or visitors to our premises.

Recruitment

We aim to apply fair and transparent recruitment policies. This includes the use of role profiles to assess candidate suitability, personality profiling, attendance at an assessment centre and direct candidate interview.Successful applicants are required to provide details of two references and provide proof of eligibility to work in the UK. Where the role is in scope of FCA regulation, a full background check will be undertaken. All new colleagues are provided with an induction programme appropriate to their role, as well as a formal employment offer letter, a copy of their role profile and a statement of the terms and conditions of their employment.

Reporting Concerns

We encourage colleagues to raise genuine and legitimate concerns connected with the workplace without fear of any detriment, victimisation or disciplinary action. This provides an opportunity for concerns to be investigated and for any appropriate action to be taken so that the matter is resolved effectively.

• Our Standards of Corporate Conduct describe the basic obligations of all colleagues to know and comply with the spirit and the letter of all Company policies and legal requirements related to their work.
• Colleagues are asked to report any known or suspected violations of Company Policy or legal requirements related to the operation of the business, including any known or suspected cases of fraud, losses, organised criminal activity, misuse of computer resources or intellectual property, security or safety concerns, or other improprieties.
• Any colleague who becomes aware of an ‘unusual event’, or has a concern or suspicion of wrongdoing at TrustFord, should initially raise it with their immediate Line Manager. Alternatively, they may contact the Internal Audit and Risk Manager, phone a secure voicemail facility on 01206xxxxxx or e-mail xxxxxx@trustford.co.uk.
• Our Policy prohibits any form of retaliation against individuals who report suspected violations in good faith. Colleagues are not disciplined for raising a legitimate and genuine concern following the procedure set out in this policy.
• Colleagues may also choose to remain anonymous. Every effort will be made to protect the confidence of the colleague who has reported a concern.
• If it is found that the colleague concerned has abused this process by raising unfounded allegations maliciously, they may be subject to disciplinary action.

All reported incidents are thoroughly investigated by the Company’s internal audit team who will take appropriate action. Such action may include disciplinary or criminal proceedings against those who have been involved.

Working Practices

The Working Time Regulations 1998 were put in place to safeguard the health and safety of employees. They regulate hours of work, rest periods, breaks and annual leave – we fully observe the requirements of the Working Time Regulations. However, at their individual choice, colleagues may elect to opt out of certain aspects of the regulations. Hours of work are specified in each contract, but these hours of work may be subject to change following consultation.

• Colleagues are entitled to unpaid breaks of no less than 30 minutes in a standard 9-hour working day. Due to the nature of the business, this break may have to be taken over two 15-minute periods.
• We aim to provide more than the minimum 20 minutes per 6 hours. Breaks will be scheduled in advance where possible – but may vary from day to day to meet the demands of the business.

Young workers

Young workers under the Regulations are those workers aged 15 and over, of compulsory school age but under 18. Young workers enjoy similar rights to adults but with increased protection in respect of daily, weekly and in work rest periods. These regulations limit their daily working to 8 hours per day and 40 hours per week. Night working is prohibited between 10pm - 6 am or 11pm - 7 am. Young workers also receive a 30-minute rest break if the working day is longer than 4 hours, and a weekly rest break of 2 days off per week. Under the Company Health and Safety policy, risk assessments must be carried out for any young worker employed prior to commencement of employment/work experience.

Our Operations

• We ensure that our operations comply with all applicable environmental laws.
• We ensure that our contractors and waste management suppliers comply with all applicable environmental laws.
• We aim to apply industry best practice.
• We act to minimise the environmental impact of our operations. This includes recycling of waste streams wherever possible, reduction of energy and water usage, and reduction of fuel usage by the Company fleet.
• We encourage local initiatives in support of this policy.

Our Facilities

• We undertake environmental audits of our facilities on a regular basis and act upon the findings.
• We consider the environmental impact of our operations as a critical factor when specifying the design or refurbishment of dealerships and when considering the purchase of capital equipment.
• We take steps to increase the use of renewable energy sources.

Our Staff and Customers

• We ensure that our colleagues are knowledgeable about the environmental considerations of our products and services.
• We ensure that our customers are made aware of both the environmental impact and environmental benefit of our products and services.

Our Health and Safety Policy Statement reflects the importance we attach to the safety of all our employees and any other person who may be affected by the Company's actions, including customers, visitors, contractors to the Company and our neighbours.

Overall responsibility for health, safety and welfare within TrustFord lies with the Chief Executive and the Board of Directors. However, all colleagues have a responsibility to ensure that the Company meets the requirements of the Health and Safety at Work Act 1974 and all other current Health and Safety legislation applicable to the Company in the UK. We therefore ensure that the health and safety standards in the Company are, so far as reasonably practicable, at least as good as those required by the statute.The day-to-day operations associated with Health, Safety and Welfare are the responsibility of all managers and supervisors. They are responsible for the proper application of our health and safety objectives.

Health & Safety Objectives

• Promote high standards of Health, Safety and Welfare that comply with the terms of the Health & Safety at Work Act 1974 and any other statutory provision as well as all approved codes of practice as far as reasonably practicable.
• Provide resources to ensure that workplaces and methods of working are safe and healthy.
• Protect all persons, including customers, contractors and members of the public from any foreseeable danger arising from our business.
• Provide information, instruction, training and supervision to all employees to enable them to work safely.
• Provide and maintain sufficient facilities and arrangements for employees’ welfare.
• Promote awareness of health and safety and encourage all staff to take the necessary steps to safeguard the health and safety of both themselves and others.
• Encourage full and effective consultation on all safety matters.

The specific responsibilities for health and safety duties, and the arrangements to carry out this policy, should be documented and available for inspection at each site.

All our colleagues:

• Must read and comply with all Company safety policies and safe working practices
• must not misuse, modify equipment and plant in such a way as to endanger themselves or others and must not under any circumstances use equipment which they consider to be defective
• will report immediately any defect or unsafe working practices that could compromise health and safety
• must use protective equipment provided in the correct manner. Any defective equipment should be reported and replaced immediately
• will not act in a way as to endanger themselves or others in the workplace
• will not place themselves at additional risk in violent or criminal situations by withdrawing from the area if possible and surrender any company property if demanded in threatening circumstances
• will co-operate fully with the Company's Heath Surveillance and Medical Screening Programmes
• must report all accidents and incidents including near misses immediately to their Line Manager

These terms & conditions are the only terms and conditions upon which Ford Retail Limited ("the Customer") is prepared to deal with you ("the Supplier") and they shall govern our contractual relationship to the entire exclusion of all other terms or conditions. No variation or addition to these terms and conditions shall be binding unless agreed in writing by a director of the Customer.

The Supplier shall supply the goods and/or services in conformance with all due care and skill, in accordance with good practice and in compliance with relevant laws, regulations, standards, codes of practice and requirements of any competent authority (including those relating to health and safety). The Supplier shall obtain any licences, permits or consents necessary in order to do so.

All goods shall be new and unused, fit for their intended purposes, of good quality and workmanship, free from defects in design, materials and workmanship, equal in all respects to sample, in accordance with their description, and shall meet any performance or other specifications communicated by the Customer to the Supplier.

All services shall be free from errors and defects and performed by appropriately qualified and trained personnel to a high standard of quality as is reasonable for the Customer to expect.

In the event of a breach of this contract, or failure of any of its obligations under the same, the Supplier shall at the Customer’s option remedy the breach to the Customer’s satisfaction, or indemnify the Customer and keep the Customer indemnified against all direct, indirect or consequential liabilities (including without limitation loss of profit, loss of business and depletion of goodwill), losses, claims, costs, expenses and damages arising out of the Suppliers’ failure to comply with its obligations under the contract and the exercise by the Customer of its rights under the contract or law, to include, but not be confined to, undertaking remedial action itself or arranging for a third party to do so.

All equipment, materials and supplies provided by the Supplier for incorporation into goods or services shall become the property of the Customer upon appropriation to the goods or services or payment by the Customer, whichever is earlier.

The Customer is entitled to terminate the contract and the delivery or performance by the Supplier of goods and/or services without liability to the Supplier at any time by giving written notice, if the Supplier commits any material or persistent breach of any of its obligations under the contract.

The Supplier shall be responsible for and indemnify and hold the Customer harmless against all claims, proceedings, liability, losses, costs, damages and expense whatsoever arising out of or in connection with the performance of the contract.

The Supplier shall not claim any lien or attachment or make other similar claims in connection with any goods delivered or services supplied and shall indemnify the Customer against all loss, damage or liability resulting from any and all liens, attachments or other similar claims by any third party.

The contract shall be governed and construed in accordance with English law and the parties agree to submit to the exclusion jurisdiction of the English courts.