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Pub Code Regulations
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Code of Conduct
The Greene King group of companies (“Greene King”) is committed to making a positive contribution to society and to the environment in which it operates by developing and implementing business practices that allow us to deliver financial success whilst conducting our business strategy and operations in a responsible manner. In doing this, we seek to create value for our shareholder and our broader stakeholders, including our employees, our business partners and the communities in which we operate.
Greene King employs more than 40,000 people across the United Kingdom and all employees are to be treated with respect, and their health, safety and basic human rights must be protected and promoted.
The Code of Conduct (the “Code”) sets out the principles that Greene King complies with. All suppliers and sub-contractors shall be made aware of this Code and shall be expected to comply with the provisions of the Code or meet the same standard through their own code.
We expect our suppliers to support this process fully and to encourage their own suppliers to work to these principles as well. To ensure adherence to and continual improvement against the Code, Greene King reserves the right to visit and assess our suppliers’ commitment to the Code.
See Greene King's full Code of Conduct.
Greene King Tax Strategy
This strategy is prepared by Greene King Limited and sets out its approach and that of all of its subsidiaries (collectively, the “Group”) to managing the tax affairs of the Group. This strategy has been approved by the Board Committee, as established by the Board of Directors of Greene King Limited.
This strategy complies with paragraph 16 of Schedule 19 of Finance Act 2016. It relates to the financial year ended 31 December 2023.
The Greene King Group is a significant UK taxpayer responsible for paying and collecting on behalf of others between £500m - £600m of taxes and duties annually and it takes its statutory and legal obligations extremely seriously.
- To ensure that we always pay the right amount of tax at the right time.
- To effectively administer all taxes and duties reducing the level of risk.
- To arrange our affairs in a tax efficient manner, within both the letter and the spirit of the tax legislation.
- To maintain a collaborative and transparent relationship with HMRC.
The approach to the Group to tax risk management and governance arrangements:
- The Group maintains compliance with all relevant statutory and legal obligations by identifying and mitigating tax risks through a structured governance framework.
- The group tax function consists of suitably qualified and experienced staff.
- The members of the group tax function carry out their roles and responsibilities in accordance with the Professional Rules and Practice Guidelines and the Professional Conduct in Relation to Taxation as required by the professional bodies they are members of.
- The Group’s tax function works closely with the business to ensure that our internal controls and processes are robust, and carries out annual tests to identify ineffective or inefficient controls and implements improvements as required which are reviewed and signed off by the Group’s Chief Financial Officer.
- Regular reports will be provided to the Board Committee on any significant tax issues or developments affecting the Group.
- Ultimate responsibility for tax rests with the Group’s Chief Financial Officer.
Attitude of the Group towards tax planning:
- Tax evasion in any form either by knowingly not declaring income or inaccurately declaring income or expenditure is unacceptable. This policy applies to all employees of the Group, in accordance with the UK rules on the corporate criminal offence for failing to prevent the facilitation of tax evasion.
- Any tax planning being considered is reviewed in the light of the Group’s obligations as a responsible UK taxpayer.
- Transactions whose sole purpose is to reduce tax are not undertaken unless such transactions are clearly envisaged by the tax legislation.
- Any non-routine tax arrangements will be reported to the Board Committee in compliance with this policy. Independent professional advice is sought where considered appropriate to ensure compliance with all relevant statutory and legal obligations.
Level of risk of taxation the Group is prepared to accept:
- The tax strategy protects shareholder value in terms of the overall tax burden and cash flows in a manner consistent with the Group’s obligations as a responsible UK tax payer.
- The Group is well aware of all of its statutory and legal obligations and is continuing to work alongside HMRC in maintaining its “low risk” status.
Approach of the Group towards its dealings with HMRC:
- The Group actively works in partnership with HMRC in order to ensure that it meets all its relevant statutory and legal obligations.
- Where errors arise it is our policy to disclose these to HMRC and to also ensure that appropriate remedial action is undertaken to our systems and processes.
- Where necessary, we will seek HMRC’s formal or informal clearance on notified tax issues.
- The Group encourages and maintains a transparent and constructive working relationship with HMRC in relation to all current, future and retrospective tax matters.
21 November 2023
Greene King Modern Slavery Statement 2020
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Greene King Limited and other relevant group companies to prevent modern slavery and human trafficking it its business and supply chains.
We recognise that we have a responsibility to prevent modern slavery and human trafficking both within our business and our supply chain, as slavery and human trafficking are abuses of a person’s freedoms and rights.
Greene King was founded in 1799 and is headquartered in Bury St. Edmunds, Suffolk. We currently employ around 40,000 people across five divisions: Local Pubs; Destination Food Brands; Premium, Urban and Venture Brands; Pub Partners; and Brewing & Brands.
We operate c.2,700 pubs, restaurants and hotels across England, Wales and Scotland, of which c.1,700 are managed pubs, restaurants and hotels in the Locals, Destination and Premium, Urban and Venture Brands divisions, and c.1,000 are tenanted and leased pubs in the Pub Partners division. Our leading managed brands and formats include Hungry Horse, Farmhouse Inns and Chef & Brewer. Our Brewing & Brands division covers the brewing sides of the business, with quality ale brands brewed at the Greene King brewery in Bury St Edmunds and the Belhaven Brewery in Dunbar. Our industry-leading portfolio includes Greene King IPA, Old Speckled Hen, Abbot Ale, Ice Breaker and Belhaven Best.
In October 2019 Greene King was acquired by the CK Asset Holdings Limited (“CKAH”) group. CKAH is a Cayman Islands company registered in Hong Kong whose shares are listed on the Hong Kong Stock Exchange. A new chief executive, Nick Mackenzie, also joined the group in May 2019, replacing Rooney Anand, who had been in role since 2005.
Since then, the COVID-19 pandemic in the UK has been the defining issue for our business. It has had an unprecedented and critical impact on the leisure and hospitality sector and therefore on the group. Priorities for the business have necessarily focussed on ensuring the financial stability and survival of the business, positioning the business to exit the crisis strongly and, as far as possible, to protect our employees/partners from the worst impact of the crisis – both financially and from a welfare perspective.
At the same time, management has been working hard to develop a new culture and strategy for the business. We are in the process of deploying a programme of cultural and strategic transformation, Greene King Unleashed, which is designed to develop a more sustainable business model achieving a balance between performance delivery and longer-term growth and meeting the needs of customers, employees and shareholders. Our new purpose, approved by the board, is We Pour Happiness into Lives; this sits alongside a new goal, to be the pride of British hospitality famous for outstanding customer experiences and a balanced portfolio of high growth, consistently profitable brands.
We have also been responding to press reports during 2020 regarding the company’s history. Benjamin Greene, the company’s founder, profited from slavery and argued against its abolition in the 1800s. During 2020 we committed to accelerate our inclusion and diversity strategy to support the careers of people from Black, Asian and minority ethnic backgrounds. We also became a member of the Slave Free Alliance, a social enterprise and membership initiative launched by anti-slavery charity Hope for Justice, so that we can access their support and knowhow with regard to modern slavery issues. Slave Free Alliance has already conducted a gap analysis and we will be working with them going forwards to redefine and strengthen our response to modern slavery.
We have a code of conduct which sets out a number of principles we expect our employees and suppliers to comply with. These include statements that all employees shall be free to choose their employment and shall not be forced to work against their will, and that there shall be no forced, bonded or involuntary prison labour or human trafficking.
For our employees, failure to comply with the provisions of the Code may result in disciplinary action which could result in their immediate suspension or the termination of their employment.
We also operate a whistle blowing policy, aimed at our employees, which encourages staff to report any wrongdoing, including human rights violations such as modern slavery or human trafficking. Any reports of this nature will be fully investigated and appropriate remedial actions taken.
We believe that transparency is vital to a successful business relationship with our suppliers. We are committed to building long-term relationships with suppliers and value open and honest communication with them. In the event of non-compliance with our Code of conduct, we expect our suppliers to be committed and engaged in remedying the issue within a time frame set out in a corrective action plan to be agreed with the supplier. We reserve the right to terminate any agreements should a supplier decide that compliance with the Code is impossible or where a supplier shows repeated disregard for the provisions of the Code.
As we develop our new strategies with regard to modern slavery we will review both our policies and procedures, and the expectations we set for our suppliers in this area.
Our supply chain
Our supply chain includes over 5,000 suppliers covering food and drink suppliers for our pubs, raw materials for our beers, as well as goods and services not for resale such as equipment used in our pubs, point of sale materials, IT equipment, utilities and waste services, contractors building, repairing or cleaning our pubs, marketing, advertising, recruitment and training.
Our suppliers vary enormously in terms of their size and expertise and many of those will themselves be reliant on their own supply chain, potentially across many countries, in order to be able to supply relevant goods or services to us.
Current and proposed due diligence processes for modern slavery and human trafficking
Our supplier terms and conditions require compliance with the Modern Slavery Act and we expect all major suppliers to have suitable anti-slavery and human trafficking policies and processes in place. We anticipate working with Slave Free Alliance to improve our due diligence processes to enable us to identify and assess potential risk areas in our business and our supply chain.
By running many of our pubs as managed houses we have optimum control of the work environment, including labour scheduling and pay rates, thus reducing the risks within our own business. We recognise however that no business can be risk free. We are already engaging with employees to raise awareness through live webinars available to all employees on transatlantic slavery and modern slavery with recordings and additional spotlight videos available on the online training platform. We are also looking to increase awareness of the routes available to employees to raise concerns about any slavery-related issues. More detailed training is likely to form part of our new strategy on modern slavery.
Our effectiveness in combating slavery and human trafficking
We understand that the risks of modern slavery and human trafficking are growing, and we will continue to monitor our approach to mitigating this risk in the year ahead. With the help of Slave Free Alliance we will work to develop a more comprehensive long term strategy for dealing with modern slavery risks both within our business and in our supply chain.
This statement covers the following subsidiary entities:
Greene King Brewing and Retailing Limited
Greene King Retailing Limited
Greene King Retail Services Limited
Spirit Pub Company (Managed) Limited
Spirit Pub Company (Services) Limited
Spirit Pub Company (Supply) Limited
Spirit Pub Company (Trent) Limited
Approved on behalf of the executive board of the Greene King group