LHP is committed to achieving the highest standards of probity and good governance in all its activities. LHP has adopted a probity policy which regulates payments and benefits, gifts and hospitality and deals with conflicts of interest situations for both Board members and employees. This policy:
Ensures we comply with the law
Ensures we comply with the requirements of our regulators
Demonstrates the we follow best practice
Safeguards our reputation
Board member expenses policy
The Board Member Expenses Policy sets out the parameters that allow Board Members to claim expenses. These are to meet all reasonable expenditure for travel, accommodation and other expenses incurred by members in connection with attendance at meetings with the Board or Committees of the Board or general meetings or otherwise in connection with the discharge of their duties.
Recruitment and selection
We have a shareholders policy which sets out the way in which we appoint shareholders. Our Rules state that only a shareholder can be a Board Member. It is through this policy that we renew our Board membership. The policy sets out the criteria by which we will assess applications and how we will seek to identify and recruit the best candidates. It also covers effective planning for succession on the Board. There is also a Board and Committee Member Recruitment and Succession Policy which outlines the approach to Board and Committee Member recruitment.
Access to information, confidentiality, Data Protection and GDPR
We have provisions dealing with access to information, confidentiality and GDPR/data protection which ensures that our board members and employees understand the need to manage and use the information we hold properly and lawfully. We uphold the basic rights of customers to access the information held about them and ensure that we meet our obligations under the GDPR/Data Protection Act and associated legislation and guidance to ensure confidentiality is maintain properly, particularly where we hold personal information about our customers. Our Data Protection Policy details our approach in this area.
Anti-Fraud and Corruption Policy
This Policy sets out and explains the various forms of and offences which relate to fraud and corruption. It gives examples of such and explains the obligations which fall to Board and employees. The policy sets out how LHP will mitigate against the risk of fraud with various measures. An example of a key preventative measure is proper assurance in selection of the right staff with high levels of integrity and honesty. The Policy explains how concerns can be identified and dealt with. The Policy has a Fraud Investigation Plan which gives detailed guidance on the processes and procedures to be followed and responsibilities for investigating and acting on LHP’s response to acts of fraud and corruption.
Bribery Act Policy
The bribery act policy explains our actions to deal with the Bribery Act 2010 and sets out what measures we have taken to avoid instances of bribery and corruption within our business activities and when contractors are acting on our behalf. There is a corporate risk if adequate measures are not in place to prevent and minimise acts which fall within the definition of bribery.
Anti Money Laundering
This policy explains the various forms money laundering can take and the relevance of money laundering in respect of LHP activities. It sets out a summary of the relevant legislation and the responsibilities of employees to not ignore signs which indicate suspicions of an offence. Examples of transactions and behaviours of customers are given to assist employees. The need to obtain appropriate proof of identification in dealings which are higher risk is emphasised. Designated Roles required under the Act are explained. Appendices set out processes and procedures in dealing with cases and reporting on to enforcement agencies.
LHP has created this new policy to reflect changes in reporting mechanisms and included the ability for staff to externally report and investigate disclosures. LHP is committed to conducting business at the highest standards of equality, probity, integrity and propriety. We believe that effective communication among people at all levels promotes better business practice. As part of this commitment, LHP will not tolerate wrongdoing by employees at any level. To support this, we look to have an open and supportive culture and encourage both Board and Committee members and all employees to report any serious concern as soon as possible relating to one of the areas listed in this policy, in the way set out in this procedure, without fear of reprisals.
Accountable Persons Policy
The purpose of the accountable persons policy is to enable LHP to promote the appropriate Directors for customers and stakeholders to contact should they feel that their concerns or enquiries are not being heard and therefore addressed and resolved in a timely manner.