Governance

The Group Board recognises that Newable, because of its status as a company limited by guarantee, does not have traditional shareholders and therefore does not benefit from the challenge they ordinarily offer to the Board. As a consequence, Newable applies a high standard of corporate governance, seeks objective challenge proactively, as appropriate and necessary during the normal course of its business, and has applied this approach to corporate leadership effectively and consistently throughout its history. To maintain this high standard of governance, the Group Board has adopted the Quoted Companies Alliance (QCA) corporate governance code. The details of the QCA code, Newable’s compliance with it and details of our governance structures are set out in the Annual Report and Financial Statements.

Newable has a zero-tolerance approach to any form of modern slavery and acts in an ethical manner, with integrity and transparency in all business dealings. We have effective systems and controls in place to safeguard against any form of modern slavery or human trafficking in our businesses, partnerships or supply chains. Our commitment to our clients is very clear: we will always treat people in our businesses, partnerships or supply chains fairly and we expect our employees, suppliers and partners to act responsibly and to comply with this policy at all times.

Our approach to procurement is based on applying an objective criteria reflecting the principles of non-discrimination, equal treatment, transparency, procedural fairness, mutual recognition, proportionality and business efficiency. We carry out due diligence on prospective partners and suppliers as part of any tender process and they are expected to agree to our contractual terms and conditions, confirm that they will comply with our policies and procedures and provide their services in accordance with all applicable laws and regulations. Newable expects its partners and suppliers to exercise due diligence along their own partnerships or supply chains and we are introducing additional and specific obligations in our agreements to require them to comply with all laws relating to modern slavery and human trafficking and undertake that there is no trafficked, bonded, child or forced labour within their supply chain.

Newable’s anti-bribery policy complies fully with the UK Bribery Act 2010, which provides for the prosecution of both individuals and companies for bribery offences, and incorporates other related legislation including the US Foreign Corrupt Practices Act 1977. In addition, Newable is required by the Financial Conduct Authority (FCA) to set up and maintain effective systems and controls to counter the wider risk of financial crime including bribery and corruption. Newable’s suite of anti-financial crimes policies comply fully with FCA requirements.

Newable has developed a comprehensive risk framework and a suite of polices to manage the key risks it faces. This is supported and monitored by the Group Board’s Risk and Governance Committee and its processes are designed to identify Newable’s principal risks, define its risk appetite and ensure that business plans are consistent with it, ensure that its risk appetite is supported by an effective risk infrastructure and manage risks within the business with effective and independent oversight. Newable’s risk processes are supported by a positive and proactive approach to raising and maintaining awareness of risk across the business to ensure that: – all staff at every level (including Board members) manage risks appropriately as an intrinsic part of their day-to-day work; – our culture supports open and honest discussions of uncertainties or opportunities; – we encourage staff to express any concerns they have and maintain processes to elevate such concerns to the appropriate level promptly; – we can calibrate the risk to reward trade-off through improved decision making; and, – we comply with the QCA corporate governance code and FCA regulations.

Newable complies fully with both the letter and intended spirit of all relevant tax legislation. We do not support or agree with overly-aggressive interpretation of legislation in order to minimise tax liabilities and we have always held that a successful economy, with strong and well-functioning public services, requires that all parts of society pay tax in full accordance with the law. Newable is developing a comprehensive anti-tax evasion policy to document its historic approach and culture to tax compliance and this includes a commitment to: – not creating or using offshore or other corporate ownership structures with the sole intention of reducing its tax liabilities; – paying its tax liabilities as and when they fall due; and, – minimising the use of payroll contractors and consultants. Newable has an excellent record in complying fully with its tax obligations and has an unblemished history with no significant issues or problems raised by HM Revenue & Customs or any other tax authority in relation to its affairs.