CSR Management

Acting responsibly in how we do business will play a key part in winning the trust of our stakeholders and building a successful and sustainable business in the long term.

This CSR policy outlines our approach to CSR and how we manage and embed CSR in the business. The below standards provide a framework for businesses to help meet the Group’s CSR vision.
These standards cover the elements of CSR which are the responsibility of the group corporate social responsibility director, including:

1. Business ethics
2. Human rights and diversity
3. Community

In addition, the management and reporting of CSR in the 2sms businesses includes compliance with the CSR specific standards outlined in the following group risk management policies:

• Business protection
• Customer
• Environment
• Financial crime
• People
• Purchasing and supply management

1. Business Ethics

We are committed to being a responsible business. We aim to ensure that, in everything we do, we meet the highest standards of business conduct.

2sms’s principles for good business ethics:

• Commitment to fair business practices in our relationships with our customers, employees and suppliers.
• Commitment to transparent business practices.
• Commitment to honest business practices.
• Respecting the confidentiality of information entrusted to the company.
• Obeying the rule of law .
• A commitment to accurate and honest reporting to our stakeholders.

Detailed guidance supporting each of the above mentioned principles are outlined in the share dealing code and the following group risk management polices:

• Customer.
• Financial crime.
• Financial reporting .
• People.
• Purchasing and supply management.
• Regulatory.

2. Human rights and diversity

2sms respects all fundamental human rights and will be guided in the conduct of its business by the provisions of the United Nations Universal Declaration of Human Rights (UNUDHR) and the International Labour Organisation (ILO) core labour standards. 2sms also supports the UN Global Compact Principles.

The UNUDHR articles of greater relevance include 2 (which deals with discrimination), 23 (which deals with terms of employment), 24 (which deals with work life balance) and 25 (which deals with adequacy of standard of living).
2sms’s people policy outlines our people management practices.

Value and Respect Diversity

The group is committed to creating a working culture that respects, celebrates and harnesses differences to the benefit of customers, employees, shareholders, business partners and the wider communities within which we operate.
The principle of equal opportunities for everyone in employment is an important part of this working culture. Businesses shall have in place policies that reflect local legal requirements and group wide good practice.

Businesses will ensure that access to employment, training and promotion is:

• Free from discrimination on the grounds of sex, sexual orientation, marital status, creed, colour, race, religion, age, ethnic origin, nationality, union status or disability.
• Based solely on the objective assessment of ability and other relevant job related criteria.
• In the case of training and career development, based on assessed need.

Any allegations of harassment or discrimination will be treated seriously and investigated fully and will be dealt with in accordance with local disciplinary and other appropriate policies.

Businesses must apply group standards and establish monitoring and other supporting processes to ensure the objectivity of employment related decisions. Including:

• Those involved in decision making processes shall be trained to ensure decisions are taken based on objective criteria and can be justified.
• The main areas where such processes shall be established are: – Recruitment and selection; Career planning, promotion and transfer; Training and personal development; Performance management; and Redundancy.

Diversity vision

Diversity is about everyone. We believe in a working culture that respects, celebrates and harnesses difference to the benefit of customers, employees, shareholders, business partners and the wider communities.

Our competitive advantage depends on business teams that include people with different backgrounds, experiences and perspectives, who feel valued for the positive contribution they can make to 2sms’s success. (“Together We Are Stronger”.)

3. Community

2sms is committed to good corporate citizenship and to supporting charity and community initiatives which are relevant to its business, employees, customers and stakeholders. This document explains the parameters for this support and the way in which both the 2sms group and businesses can work within them.

2sms’s business activities bring it into contact with a range of stakeholders and communities. We recognise our responsibilities to these groups and fund a programme of investment in charity and community initiatives (e.g. programmes run by schools and other community groups that are not registered charities) to support them.)

Criteria for community investment

Our community investment programme centres on two core themes which are closely aligned to our ‘prosperity and peace of mind’ vision and where we have real expertise: ‘education and financial literacy’ and ‘life trauma’ (i.e. caring for people going through a distressing life event).

In addition, we have established a range of criteria through which we identify initiatives that it might be appropriate to invest in.

Any initiative must:

• Relate to the core themes identified above.
• Be clearly relevant to 2sms’s aims and brand values.
• Demonstrate partnership, by helping relevant charities to deliver long-term goals (rather than single events or milestones).
• Offer opportunities for communication both globally and in key local markets.
• Offer opportunities for 2sms people to ‘get involved’ through volunteering activities.
• Be measurable, with clear KPIs that evaluate both output and impact.

Please note that neither 2sms group nor its businesses will invest in initiatives that meet any of the following criteria:

• Individuals outside the company looking for charity fund-raising donations or personal sponsorship for fund-raising activities.
• Political or religious organisations.
• Extreme, “high risk” or “free” sports.
• Paid advertisements in charity brochures or event programmes that do not support the core themes identified above.

Guidance for businesses

2sms businesses will be expected to follow the above guidelines for the majority of their investment in charity/community initiatives.

Businesses should actively encourage staff participation in their charitable giving and community activities, providing employee volunteering opportunities during company time of up to three days per year.

Businesses are also encouraged to consider other opportunities for supporting employees’ good will and support for the community – including:

• Offering an employee payroll giving scheme – whereby employees can donate directly to charity from their salary.
• Match-funding employee fundraising activities.
• Offering an employee award scheme whereby employees can apply for funds to support a charity/community group of their choice.

Each business should develop its own community investment plan in line with the group approach, observing the relevant social, cultural and religious beliefs and conventions which exist in their respective markets.

Each business must report to its business CSR co-ordinator annually regarding its community investment plan, covering governance, aims, activities, spend involved and impact/evaluation. Annually, each region will submit a progress report to the Group CI committee.

Businesses should, in the first instance, contact their business CSR co-ordinator for any clarification on group strategy and guidance.