Ethics principles.

Groupwide Ethical Principles

We’re a long-term business with strong principles about how we like to act responsibly. We’ve drawn up commitments which show our key stakeholders what they can expect when dealing with us.

Responsibility for selecting key stakeholders rests with John Godfrey, Director of Corporate Communications.

Who is important to Legal & General in doing business responsibly?

What can you expect from us when you deal with Legal & General?

Boundaries over which we will not cross

Our Customers

When dealing with customers, we are open and transparent and provide clear, factually correct and sufficient information to enable customers to make informed choices.

  • We don’t overload customers with documentation that makes it difficult for them to understand our products and services.
  • We design our products and services around our current and potential customers.
  • When marketing to potential customers we design our campaigns responsibly to highlight a need or gap in their financial safety net.
  • We deliver on our promises and make it easy for customers to do business with us throughout the life of a product.
  • We take great care with customer information and personal data.

We consider claims and complaints fairly and will never seek to avoid our responsibilities because of financial considerations.

We do not pass customer data or information onto others.

Financial intermediaries, for example, independent financial advisers

Where our products or services to customers are introduced through financial advisers we want to make sure that:

  • We are easy to deal with.
  • We work together with intermediaries with long term commercial integrity. We know it’s in our mutual interests to retaining customers.

We will not tolerate disadvantage to customers because of the need for financial intermediaries to be paid.

We will not tolerate poor advice from intermediaries that disadvantages customers.

We will not vary our contractual terms and conditions to disadvantagefinancial intermediaries, unless obliged to do so by legislation.

Joint venture partners, for example, IndiaFirst or CIL (Egypt)

When setting up joint ventures, we will seek ways of establishing higher operating standards. This includes having competent and challenging board representatives focused upon the environmental, social and governance performance of the organisation.

If we believe that the business gets close to overstepping regulatory boundaries, we will intervene on behalf of its overall customers, not just our own customers.

Not-for-Profit Organisations, for example Shelter

We invest time, money and gifts in kind in issues that resonate with our core business namely inequalities in Housing, Health and having more income in later life.

  • We support our employees in the raising of money and in funding volunteering days for charitable organisations.
  • We will invest in local community organisations and projects that operate within 10 miles of our offices or our commercial property portfolio.

We don’t invest in charitable organisations who make indirect political donations.

We don’t make donations to financial Intermediaries or ask suppliers for donations as part of doing business.

Non-Government Organisations

When approached, we will listen to Non-Government Organisations in relation to our direct operations and our investments to see if they have raised material opportunities and issues.

We will reach out to, and fund, NGOs where we have a need for their expertise and training to enhance our business.

We will not deal with NGOs who aren’t receptive to a conversation about an issue or opportunity.

We will protect our employees from harmful NGO activities as a priority.

We do not fund NGOs directly to support political campaigns.

Suppliers

When working with suppliers we will:

  • Treat suppliers fairly and objectively at all times.
  • Give each supplier an equal opportunity to win our business.
  • Pay suppliers on time.
  • Select suppliers without consideration of their gender or ethnic origin.
  • Select supplier regardless of size.

Suppliers that are either unwilling or do not comply with our sustainable procurement standards will not have an opportunity to do business with us.

Environmental resources

We recognise that our operations impact the environment:

  • directly, through our buildings and business travel in the UK and overseas
  • Indirectly, through our investment assets
  • Indirectly, through our supply chain

Our approach isto use natural resources more efficiently when running our business. We will bring issues to the attention of our customers shareholders or investors that:

  • enable them to become more environmentally efficient
  • or enable them to benefit from the effects of climate change

We will raise issues with investees or suppliers if we believe they are not aware of the impact that they have on the environment.

We don’t offset our impacts or make claims of ‘carbon neutrality’.

Investees

We expect companies that we invest in on behalf of our clients to have effective Environmental, Social and Governance (ESG) programmes.

  • We actively encourage companies to improve their ESG standards on behalf of our clients by: engaging with companies, voting on shares globally, integrating ESG in portfolio management and addressing systemic risks and opportunities.
  • The ultimate goal of ESG is to ensure company management align their business objectives with the long-term interests of investors.

We will invest in all mainstream financial assets based upon the collective mandates provided by our clients.

Our approach is to influence through ownership, rather than exclude assets.

We accept that there is a school of thought that influence through exclusion of assets is a way of changing corporate behaviour.

Government

When working with government and policy makers, we think it's important that people know what we do and what we stand for.

  • We will work collaboratively through, for example, trade bodies, or on our own.
  • We aim to deliver evidence-based, practical proposals for consideration by policy-makers.
  • We aim to be experts and thought-leaders in our fields of expertise.
  • We are an organisation rich in expertise that we’re willing to share with those responsible for formulating public policy.
  • We do this because we are focused on delivering positive outcomes for customers, the business, investment markets, the broader economy and society.

We make no political donations direct or indirect.

We are politically neutral, working equally with all parties, officials and other policy organisations.

Employees

As an employer, we make a number of commitments which include:

  • We adopt policies and practices which encourage an appropriate work-life balance
  • We working in close partnership with our recognised Trade Union Unite and Management Consultative Forum, when making decisions that affect our employees.
  • We apply open and fair processes in major decisions affecting recruitment, promotions, outsourcing and downsizing.
  • We provide employees with an understanding of what we expect in terms of ethical behaviours.
  • We promote and celebrate employee diversity in all its forms.
  • We provide a flexible, supportive, healthy and safe working environment.

We will not employ people who are not permitted to work in the countries in which we operate.

We uphold the principles of the UN Global Compact in our employee practices.

Investors

We aim to be responsive and show integrity when dealing with potential and future investors.

We will not make any statements, whether in meetings or through written communications, that are misleading, false, deceptive or omit anything that is likely to effect the interpretation of the information.

Regulators

Working with regulators, we aim to be easy to deal with and open and transparent. We will provide clear,factually correct and sufficient information.

  • We are proactive in our approach and seek to address underlying concerns and not just questions asked.
  • We seek to influence the long-term regulatory agenda through thought-leadership to deliver overall benefits for consumers.

We will not be obstructive, but we will be prepared to disagree where we believe this is appropriate for our stakeholders and does not inappropriately disadvantage consumers.

The media

We will treat media partners and journalists with integrity and fairness.

We also play a role in providing training and knowledge to help the media to understand our business and sector a little better.

We will not provide false or misleading information about our business or our trading situation.

Our tenants

We have a number of commercial property tenants running businesses and paying rents directly to us or via a managing agent.

  • Our leases and agreements around tenancy will be clear and fair and support the needs of their business.
  • We will work with tenants to reduce waste, optimise energy efficiency and improve the social impact of our properties.
  • We will campaign on our tenant’s behalf to improve standards of building design and refurbishment at an industry level.
  • We will aim to enhance the environmental, social and economic performance of the asset.

We will not invest in assets that have a significant negative impact upon society and the environment.

Feedback

If you think we have fulfilled our promises or not please contact:

Graham Precey
Head of Corporate Responsibility and Ethics
E: Graham.precey@landg.com
T (+44) (0) 203 124 2091

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