This Code of Conduct (the “Code”) sets out the standards of conduct which the Rank Group (“Rank”) requires of all its directors, officers and colleagues across all its subsidiary companies and businesses.
Any questions involving the application of the Code should be referred to Rank’s Group Human Resources Director (HR) or Group General Counsel and Company Secretary. Any allegation that any individual has contravened any of its provisions should be similarly referred, or colleagues can raise any potential breaches via the process set out in the Speaking Up Policy.
Whilst the Code does not form part of colleagues’ contracts of employment, strict compliance is expected and any breach may result in disciplinary action.
The purpose of this Code
Rank expects the highest ethical standards from colleagues and other personnel in carrying out its business. This Code:
It is essential that everyone in Rank maintains its reputation for integrity. Everyone should act honestly, fairly and with transparency in the conduct of their work. They should not act in a manner which could discredit themselves or Rank or put themselves in a position which may result in a conflict of interest.
A number of the principles in this Code are supported by more detailed policies to guide colleagues, including those expressly mentioned in this document. All colleagues are required to comply with all Rank Policies. Furthermore, any action taken under the Code will use the principles and processes as outlined in the Disciplinary and Grievance Procedures.
Many business decisions may involve ethical dilemmas. This Code cannot address every possible situation, however, some of the key areas are outlined below. It is very important that colleagues recognise when they are in a difficult ethical situation and that they seek assistance as appropriate.
Honest and Ethical Conduct
Rank requires honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
Rank colleagues and other personnel must avoid situations where personal interests could conflict, or appear to conflict, with Rank interests. Please refer to the Conflicts of Interest Policy for further details of Rank’s expectations in this regard.
Disclosures / Misrepresentation
Rank insists on full, fair, accurate, timely and understandable disclosure in papers, reports and documents, including financial statements and in other internal and external documents circulated and communications made by the Company.
Rank is committed to high legal, ethical and moral standards which includes a zero tolerance to fraud. Colleagues are responsible for the prevention and detection of fraud, misappropriations and other irregularities which can be prevented by adherence to company policies and procedures.
Where instances of fraud are suspected or detected these should be reported (anonymously if required) to senior management to allow a proper and thorough investigation to be undertaken.
Colleagues who are found to be associated with fraudulent activity will be subject to disciplinary action up to and including termination and prosecution.
Each individual is required to support and promote Rank’s long-standing commitment to operate in compliance with all applicable laws, rules and regulations in each jurisdiction in which it carries on business. This includes compliance with applicable gambling legislation and, in respect of the UK market, the licensing objectives set out under the Gambling Act 2005, being:
Player protection and our approach to improving Rank’s safer gambling measures and culture remain at the highest possible level of importance and priorities. Rank seeks not only to comply with its regulatory requirements but to embed safer gambling as a key driver of behaviour amongst our colleagues and for our customers. Rank regards it as incumbent that each colleague takes responsibility for ensuring that we provide a service that is delivered in a safe, fair and responsible way. Please see the Safer Gambling Policy for more information.
Health and Safety (H&S)
Rank treats the physical safety of our customers and colleagues as high priority and is committed to achieving the highest level of health and safety standards across the Group. Colleagues are required to support and promote that commitment.
Bribery and Corruption
Rank takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships.
A bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. It includes offering, promising, giving accepting or seeking a bribe. The amount of the bribe offered or paid is irrelevant and it need not actually be paid. A kickback (e.g. the payment or receipt of a payment in return for securing a contract) is a form of bribe. All forms of bribery are strictly prohibited and are likely to be criminal offences.
You must not:
Before accepting, offering or giving any gift or hospitality, you must carefully consider the possible motives for it being accepted, offered or given and how acceptance might subsequently be perceived by the public, Rank shareholders, work colleagues or other stakeholders. All activity in relation to gifts and hospitality should be carefully considered under the terms of the Anti-Corruption and Bribery, Gifts and Hospitality Policy.
You will receive confidential information, whether about Rank, its businesses, your colleagues or customers in the course of fulfilling your role. Such information should be treated sensitively and its confidentiality maintained. It must not be used for personal gain or for the benefit of any third party. The dissemination and disclosure of confidential information must be dealt with in accordance with relevant policies and your contract of employment, as well as in line with competition laws. The obligation of confidentiality extends to periods after you cease to work for Rank and includes the disclosure of information to others.
Please also be aware that some information will be price sensitive if it is of a precise nature that is not generally available and its release into the public domain would be sufficiently significant to affect Rank’s share price.
Many colleagues use social media for personal use outside of work. Some colleagues use social media in connection with their work for Rank. Any use of social media that links you to Rank should be relevant, protective of Rank’s reputation and not disclose confidential information. You should always be mindful of the risks in using social media and of protecting yourself and your own privacy. Please see the Social Media Policy for more information.
If you find yourself in a situation where you are unsure of the right course of action to take, you may find it helpful to ask yourself the following questions:
If you still find that you do not know the right course of action to take, if you suspect someone else of acting contrary to this Code or Rank’s policies, or if you have any concerns or questions about anything contained in this Code, you should consider the appropriate person with whom to raise the matter, this could be one of the following:
Alternatively, concerns regarding breaches of the Code can be reported under the Speaking Up Policy, including via the Safecall portal and telephone line.
Rank will not tolerate harassment or victimisation of colleagues who raise concerns regarding breaches of the Code (by any means) and will take action to protect these employees.
 This Code of Conduct applies in addition to the enracha Venues Code of Conduct. If for enracha venues colleagues there is any conflict between the two Codes, the enracha Venues Code of Conduct shall prevail.