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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 Group Strategy
This strategy is prepared by Greene King Limited and all its subsidiaries (collectively, “the Group”). It sets out the Group’s approach to managing its tax affairs. This strategy has been approved by the Chief Financial Officer and will be subject to regular review by the newly formed Board of Directors of the Group.
This strategy complies with paragraph 16 of Schedule 19 of Finance Act 2016. It relates to the financial year ended 03 May 2020.
Greene King is a significant UK taxpayer responsible for paying and collecting on behalf of others between £500m - £600m of taxes and duties every year and it takes its statutory and legal obligations extremely seriously.
The primary objectives of our group tax strategy are as follows:
1) To ensure that we always pay the right amount of tax at the right time
2) To effectively administer all taxes and duties reducing the level of risk
3) To arrange our affairs in a tax efficient manner but without avoiding tax
4) To maintain a collaborative and transparent relationship with HMRC
The approach of 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 within 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 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.
- It will provide periodic reports to the Board of Directors 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 of Directors 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 with HMRC towards ultimately achieving “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.
31 March 2020
Greene King Modern Slavery Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Greene King plc and other relevant group companies to prevent modern slavery and human trafficking it its business and supply chains.
Slavery and human trafficking are abuses of a person’s freedoms and rights. They are however a growing issue across the world, in every region and every economy. We recognise that we have a responsibility to prevent modern slavery and human trafficking both within our business and our supply chain. We are committed to making a positive contribution to society by developing and implementing business practices that allow us to deliver financial success whilst conducting our business strategy and operations in a responsible manner.
Greene King was founded in 1799 and is headquartered in Bury St. Edmunds, Suffolk. We currently employ around 44,000 people across our main trading businesses; Pub Company, Pub Partners and Brewing & Brands, all of which operate within the UK.
At our most recent financial year end in May 2016, we operated 3,035 pubs, restaurants and hotels across England, Wales and Scotland, of which 1,823 were retail pubs, restaurants and hotels, and 1,212 were tenanted, leased and franchised pubs. Our leading retail brands and formats include Hungry Horse, Farmhouse Inns, Chef & Brewer, Flaming Grill and the Greene King Local Pubs estate.
We also brew quality ale brands from our Bury St. Edmunds and Dunbar breweries, and we are the UK’s leading cask ale brewer and premium ale brewer. Our industry leading portfolio includes Greene King IPA, Old Speckled Hen, Abbot Ale and Belhaven Best.
We have adopted a code of conduct which sets out a number of principles with which we comply and that we expect our 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.
In relation to our suppliers, we believe that transparency is vital to a successful business relationship. 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.
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
We have started work on establishing a range of 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. Nevertheless, training will be developed and delivered to appropriate individuals across the business to ensure that they are aware of the issues and able to assess the risks in their area of responsibility.
We expect all major suppliers to have suitable anti-slavery and human trafficking policies and processes in place. Significant suppliers and those in businesses perceived to be most at risk have been asked to confirm their compliance with our code of conduct or to confirm that they have their own equivalent arrangements. This will be rolled out to our other smaller suppliers over time. As set out above, we reserve the right to terminate any agreement should a supplier decide that compliance is impossible or where a supplier shows repeated disregard for our code’s provisions.
We also propose to update our supplier terms and conditions to require compliance with the Modern Slavery Act and to permit periodic and targeted audits of suppliers in this regard using a risk-based approach.
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 our approach to mitigating this risk in the year ahead.
This statement was approved by the board of Greene King plc and covers the following subsidiary entities:
Greene King Brewing and Retailing Limited
Greene King Retailing Limited
Greene King Pubs Limited
- K. Holdings No. 1 Limited
Greene King Retail Services Limited
Greene King Services Limited
Greene King Investments Limited
Greene King Retailing Parent Limited
Premium Dining Restaurants and Pubs Limited
Spirit Financial Holdings Limited
Spirit Group Equity Limited
Spirit Group Holdings Limited
Spirit Group Parent Limited
Spirit Intermediate Holdings Limited
Spirit Managed Holdings Limited
Spirit Parent Limited
Spirit Pub Company Limited
Spirit Pub Company (Holdco) Limited
Spirit Pub Company (Leased) Limited
Spirit Pub Company (Managed) Limited
Spirit Pub Company (SGE) Limited
Spirit Pub Company (Services) Limited
Spirit Pub Company (Supply) Limited
Spirit Pub Company (Trent) Limited
Spirit Pubs Debenture Holdings Limited
Spirit Pubs Parent Limited
Chief executive officer