Policy

Code of Professional and Ethical Conduct

1. Introduction

WagePerks Ltd ("the Company") is committed to maintaining the highest standards of professional and ethical conduct in all aspects of its operations. As a provider of employee management, benefits, healthcare access, and HR technology services, we recognise that the trust placed in us by employers, employees, and partners depends on our unwavering commitment to acting with integrity.

This Code applies to all directors, officers, employees, contractors, consultants, and any other person acting on behalf of WagePerks Ltd ("Personnel").

2. Purpose and Scope

This Code sets out the principles and standards of behaviour expected of all Personnel. It provides a framework for ethical decision-making and serves as a reference point for conduct in day-to-day business activities.

The Code applies to all business activities conducted by or on behalf of the Company, including interactions with clients, users of the WagePerks platform, suppliers, regulators, and the general public.

3. Core Principles

3.1 Integrity and Honesty

All Personnel must:

  • Act honestly and with integrity in all professional dealings.
  • Avoid any conduct that could bring the Company into disrepute.
  • Ensure that all statements, reports, and communications are accurate, complete, and not misleading.
  • Honour commitments made to clients, partners, and colleagues.

3.2 Confidentiality

Personnel must protect confidential information belonging to the Company, its clients, and platform users. This includes, but is not limited to:

  • Employee personal data processed through the WagePerks platform.
  • Employer business information, financial records, and operational data.
  • Health-related information accessed through the 24/7 GP and Employee Assistance Programme services.
  • Proprietary software, algorithms, and business strategies.
  • Commercial terms and pricing arrangements.

Confidential information must not be disclosed to any unauthorised person, whether during or after employment, except where required by law or with proper authorisation. All Personnel must comply with non-disclosure agreements and the Company's data protection policies.

3.3 Data Protection

WagePerks Ltd processes significant volumes of personal data, including sensitive health and financial information. All Personnel must:

  • Comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
  • Process personal data only for lawful, specified, and transparent purposes.
  • Collect only the minimum personal data necessary for the stated purpose.
  • Ensure personal data is kept accurate and up to date.
  • Report any actual or suspected data breaches immediately to the Data Protection Officer.
  • Complete all mandatory data protection training.
  • Never access personal data unless authorised and required for legitimate business purposes.

3.4 Conflicts of Interest

Personnel must avoid situations where their personal interests conflict, or could reasonably appear to conflict, with the interests of the Company. This includes:

  • Financial interests in competitors, suppliers, or clients that could influence business decisions.
  • Outside employment or consultancy that could interfere with duties to the Company.
  • Personal relationships with individuals at client or supplier organisations where such relationships could influence commercial decisions.
  • Accepting gifts or hospitality that could create an obligation or perception of bias.

Any actual or potential conflict of interest must be disclosed promptly to the individual's line manager and to the Company Secretary. The Company maintains a register of declared interests.

4. Anti-Bribery and Corruption

4.1 Commitment

WagePerks Ltd has zero tolerance for bribery and corruption in any form. The Company is committed to full compliance with the Bribery Act 2010 and all applicable anti-corruption laws.

4.2 Prohibited Conduct

Personnel must not:

  • Offer, promise, give, request, or accept any bribe, whether in cash or any other inducement.
  • Make facilitation payments to any person.
  • Offer or accept gifts or hospitality where the purpose or effect is to improperly influence a business decision.
  • Use third parties, agents, or intermediaries to engage in any conduct that would constitute bribery if carried out directly.

4.3 Gifts and Hospitality

Modest gifts and hospitality may be acceptable where they are reasonable, proportionate, and given or received openly. Personnel must:

  • Decline any gift or hospitality that could create a sense of obligation.
  • Record all gifts and hospitality received or offered above the value of fifty pounds in the Company's Gifts and Hospitality Register.
  • Seek prior approval from their line manager before offering gifts or hospitality to external parties above the value of fifty pounds.
  • Never offer or accept cash or cash equivalents.

5. Professional Standards

5.1 Quality of Service

All Personnel must:

  • Deliver services to the highest professional standard.
  • Ensure that the WagePerks platform, including benefits access, GP services, EAP provision, HR tools, and shift management features, operates reliably and as represented to clients.
  • Respond to client and user queries promptly and professionally.
  • Continuously seek to improve service quality and user experience.

5.2 Fair Dealing

Personnel must deal fairly with clients, suppliers, competitors, and colleagues. This includes:

  • Representing the Company's products and services honestly and accurately.
  • Not making misleading claims about competitor products or services.
  • Honouring contractual obligations and agreed terms.
  • Treating all parties with respect and courtesy.

5.3 Competence and Development

Personnel are expected to:

  • Maintain and develop the skills and knowledge necessary to perform their role effectively.
  • Complete all mandatory training programmes, including those relating to data protection, anti-money laundering, and equality and diversity.
  • Stay informed about regulatory and industry developments relevant to their role.

6. Use of Company Resources

Company resources, including technology systems, equipment, and intellectual property, must be used responsibly and primarily for legitimate business purposes. Personnel must not:

  • Use Company resources for personal financial gain.
  • Install unauthorised software on Company systems.
  • Use Company systems to access, store, or distribute inappropriate, offensive, or illegal material.
  • Waste or misuse Company resources.

7. Compliance with Laws and Regulations

All Personnel must comply with applicable laws, regulations, and industry standards. This includes, but is not limited to:

  • The Companies Act 2006.
  • The UK General Data Protection Regulation and the Data Protection Act 2018.
  • The Bribery Act 2010.
  • The Equality Act 2010.
  • The Modern Slavery Act 2015.
  • The Proceeds of Crime Act 2002.
  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
  • Financial Conduct Authority rules and guidance, where applicable.
  • Health and safety legislation.

Personnel who are unsure whether a particular action or course of conduct is lawful must seek guidance from their line manager or the Company's legal team before proceeding.

8. Reporting Concerns

8.1 Obligation to Report

All Personnel have a duty to report any conduct that they reasonably believe constitutes a breach of this Code, any Company policy, or any applicable law or regulation.

8.2 How to Report

Concerns may be reported through any of the following channels:

  • Directly to a line manager or senior manager.
  • To the Company Secretary.
  • To the Data Protection Officer, where the concern relates to data protection.
  • Through the Company's confidential whistleblowing procedure.

8.3 Whistleblowing Protection

WagePerks Ltd is committed to protecting individuals who raise concerns in good faith. In accordance with the Public Interest Disclosure Act 1998 and the Employment Rights Act 1996, no individual will be subjected to detriment or dismissal for making a protected disclosure.

All reports will be investigated promptly, thoroughly, and confidentially. The identity of the person raising the concern will be protected to the fullest extent possible.

9. Consequences of Non-Compliance

Breaches of this Code may result in disciplinary action, up to and including dismissal. In cases involving potential criminal conduct, the Company may refer the matter to the relevant authorities.

Where a breach results in loss or damage to the Company or any third party, the Company reserves the right to pursue recovery through legal proceedings.

10. Review

This Code of Professional and Ethical Conduct is reviewed annually by the Board of Directors to ensure it remains current, comprehensive, and aligned with the Company's values and legal obligations.

Policy Owner: Board of Directors, WagePerks Ltd

Last Reviewed: April 2026

Registered in Scotland