Management

The Main Board of Marshalls plc is committed to ensuring that all Company employees and representatives behave in a manner consistent with its corporate Statement of Values & Principles. The Employee Code of Business Ethics provides guidance on those standards to which we expect employees and representatives to adhere in the transactions that they undertake on behalf of Marshalls plc, with the aim of ensuring that our trading principles and interactions with other companies and individuals reflect the Company’s core values.

Employee Code Of Business Ethics

You are required to use your best judgement and endeavours, at all times, in operating in accordance with the Code.

1. Employees of the Marshalls Group will never use their
authority or office for personal gain, and will seek to uphold the
standing of the Company by:

a) maintaining the highest standards of personal and professional integrity in all business relationships both within and outside of
Marshalls.

b) fostering the highest possible standards of professional
competence amongst those for whom they are responsible.

c) optimising the use of resources for which they are responsible to provide maximum benefit to Marshalls.

d) complying with both the letter and the spirit of;
i) the law of the country in which they practise
ii) any contractual obligations that Marshalls may have entered
into.

e) rejecting any business practice which might by any
consideration be deemed unlawful, improper, or inappropriate.

2. In applying these precepts, Employees of the Marshalls Group will adhere to the following guidelines;

a) Conflict of Interest

All employees must draw a clear distinction between any private interest or potential for personal gain and their responsibilities on behalf of the Marshalls Group which require them to exercise impartial judgment and to seek to promote the Company’s best interests regardless of their own personal feelings, views or attachments.

If an employee has any shareholding or personal business interest in a Supplier or Customer, or finds that he or she has a personal interest in a decision to be taken on behalf of Marshalls, even in a limited way, then they must declare this to their Manager immediately and take no further part in the decision without his or her written authority.

b) Confidentiality and Accuracy of Information

All employees must respect and maintain the confidentiality of information received in the course of their work and never pass it to third parties or use it for personal gain. All information given in the course of duty should be fair and true, and not designed deliberately to mislead.

c) Competition

Whilst bearing in mind any advantages to the Marshalls Group of maintaining a continuing relationship with a supplier or customer, all employees should avoid any arrangement that might prevent the effective operation of fair competition.

d) Business Gifts

Business gifts other than those of small intrinsic value and which bear a supplier’s or customer’s logo, such as pens, diaries or calendars, should not be accepted by employees. If any doubt arises that any gift is other than a simple appreciation of a cordial business relationship then the gift should be declined and guidance sought from the employee’s Manager.

e) Hospitality and Corporate Entertainment

Modest hospitality is an accepted courtesy of a business relationship. However, the recipient should not allow him or herself to reach a position whereby he or she might be, or might by others be deemed to have been, influenced in making a business decision as a consequence of accepting such hospitality.

Normally offers of travel and accommodation should not be accepted (including overnight stays and holidays). However under certain limited circumstances, for example where an employee is giving a speech or presentation, offers of travel and accommodation may be accepted following Manager approval.

All employees of the Marshalls Group must inform their Manager of any offer of hospitality to them or their family. As a guide, approval should not be given more than twice a year from the same source or for a single instance where the value of the hospitality exceeds £200. Any hospitality or corporate entertainment that is approved following consultation with the employee’s Manager must be openly recorded in the Register of Interests maintained by the Director responsible.