Code of Business Conduct

Blue Light Card is a market leading omnichannel consumer marketplace, providing a range of market leading offers from brand partners for its member base of emergency services, NHS, social care, and armed forces personnel.

Scope

This Code of Conduct applies to all the companies in the Blue Light Card Group, including Blue Light Card Ltd in the UK and Blue Light Card Pty Ltd in Australia, as well as their parent holding companies Project Hive BidCo Ltd, Project Hive MidCo1 Ltd, Project Hive MidCo 2 Ltd and Project Hive TopCo Ltd. This group of companies is collectively referred to as ‘Blue Light Card.’

Code of Conduct

The inspirational and selfless work carried out by the Blue Light Community inspires who we are as a company too. We have specific and meaningful values that underpin our culture and collective behaviour. We strive to always do the right thing, and this Code of Conduct sets out our policies that guide us:

• Bribery & Corruption: As set out in our Anti-Corruption and Bribery Policy, we prohibit corruption in all its forms, including bribery, extortion, fraud, embezzlement, money laundering and facilitation payments. Gifts and hospitality are not accepted if they are in any way thought or perceived to be in return for either doing/not doing something or showing favour/disfavour to a person or organisation.
• Business Ethics: Our commitment to integrity begins with complying with laws, rules, and regulations. Beyond this, our behaviours are guided by our values and strong moral compass.
• Conflicts of Interest: Conflicts of interest and/or the appearance of a conflict of interest are actively avoided. Potential financial or non-financial conflicts of interest should be declared and are reviewed on a case-by-case base to determine and implement an appropriate course of action.
• Community: Blue Light Card donates a proportion of its annual profits to the Blue Light Card Foundation, which contributes to UK initiatives that promote and enhance the wellbeing of the Blue Light community. Additionally, Blue Light Card supports other charitable projects that resonate with its members.
• Employee Wellbeing: We put people first, always treating them with kindness and respect, acknowledging individual preferences and beliefs. Our efforts in this area are externally recognised through our Investors in Wellbeing accreditation, and inclusion in Great Places To Work’s lists of Best UK Workplaces, Best UK Workplaces for Women, and Best UK Workplaces for Wellbeing (as updated from time to time) Core to this is proactively supporting the physical, mental and social wellbeing of our colleagues. We do this in a range of ways, from a colleague assistance programme and mental health first aiders, to our company-funded private medical insurance and employee-led Culture Club, where a collection of volunteers organise regular social and cultural events.
• Environment: We are committed to understanding and making continuous improvements in the management of our environmental impacts. As an office-based organisation our overall environmental impacts are low but we still proactively take strides to reduce both our carbon emissions and waste, and increase recycling. Our commitment to climate change mitigation is detailed in our Carbon Policy, and we are in the process of expanding our emissions measurement to include all relevant scope 1, 2 and 3 emission sources.
• Ways of Working: We operate hybrid working that allows colleagues to split their time between home and our offices. Colleagues are encouraged to attend their local office regularly. This hybrid model aspires to strike a healthy balance between giving colleagues the choice of working environment acknowledging individual preferred working styles to optimise productivity, whilst ensuring everyone continues to benefit from the connectivity, creativity and innovation that is fostered through face-to-face interactions. We have a proactive approach to flexible working ensuring compliance with all relevant regulatory and legislative requirements.
• Health & Safety: Colleague health, safety, and welfare is of paramount importance to us. We identify, assess and alleviate workplace health and safety risks in line with our Health & Safety Policy and take all reasonable steps to keep those who work for us and visit us, safe.
• Human Rights: We respect human rights and operatein accordance with the eleven fundamental conventions set out in the International Labour Organisation (ILO)’s Declaration on Fundamental Principles and Rights at Work. This includes upholding freedom of association and collective bargaining, not using forced or child labour, and eliminating discrimination.
• Inclusion & discrimination: Our colleague value proposition is to be, “individually great, together unstoppable”. As such, we embrace individual differences and aim to have a work environment where everyone can thrive. As set out in our Equal Opportunities Policy, we, at a minimum, provide equal opportunities in all aspects of employment and work conditions, and avoid unlawful discrimination against our candidates, colleagues, members, or partners. We are proud to be aDisability Confident employer. Direct discrimination, indirect discrimination, harassment, and victimisation in relation to age; disability (mental or physical); race, racial group, ethnic or national origin, or nationality; gender, gender identity or gender reassignment status; marriage or civil partnership status; political opinion; pregnancy and maternity; paternity, religion or belief; sexual orientation; educational background, socio-economic background, caring responsibilities, part-time or fixed-term status and worker representative organisations are all prohibited.
• Information Security & Data Privacy: We take cyber security issues very seriously. Our Data Protection Policy details our commitment to safeguarding and protecting our information and any other information entrusted to us and. All colleagues are required to read our policy as part of their induction and periodically to complete training. We are both Cyber Essentials Plus certified and ISO 27001:2022 compliant, covering ourselves and our members.
• Labour Standards: We pay equal and fair remuneration, including discretionary company bonuses linked to performance. Colleagues receive far more than the ILO recommended paid holiday, are offered maternity/paternity pay in excess of statutory requirements, and we do not operate zero hours contracts.
• Modern Slavery: We assess and take steps to mitigate the potential risk of modern slavery in our colleagues/candidates, our brand partners, and our supply chain. Our specific approach to assessing and mitigating the risks in each of these areas is set out in ourModern Slavery Statement.
• Political Donations: We do not give financial support, or support of any kind, to political parties.
• Whistleblowing: Openness and transparency are core to our culture. All colleagues can confidentially, and without fear of reprisal, raise any suspected concerns through our Whistleblowing Policy.

This Code of Conduct policy covers all colleagues. We take very seriously anyone who violates this Code, the law, or our policies, and colleagues may be subject to disciplinary action, up to and including termination for breaches.

Signed: Alidad Moghaddam, Chief Executive Officer

Date: December 2024