In fulfilling our purpose of ‘Keeping the UK Moving 24/7/365’ by ‘Managing Pipelines & Terminals Safely & Sustainably’ we expect all our employees to maintain the highest standards of ethical conduct. The principles below provide a framework within which the company carries out its business in line with our company values:
• We care.
• We do the right thing.
• We work as one team.
1. RESPONSIBILITIES
We recognise our responsibility to:
1.1 Keep our employees, contractors, the public, the environment, and the assets we operate safe; placing safety and sustainability at the heart of everything we do.
1.2 Add value for our customers through providing professional and cost-effective services.
1.3 Develop our people, providing a safe, fair, and energising working environment.
1.4 Protect our shareholders’ interests and providing a return on their investment.
2. HEALTH, SAFETY AND ENVIRONMENT
We take full account of the health and safety of any person affected by our operations, whilst safeguarding the environment by minimising any adverse impact of our activities. Principles are defined in BPA’s occupational health & safety policy with which all BPA employees must comply.
3. PEOPLE
BPA employees are entitled to work in an environment in which people are treated with respect. This is in accordance with our Equality, Diversity & Inclusion, Neurodiversity and Victimisation, Bullying and Harassment Policies within our HR Policies.
4. BUSINESS INTEGRITY
4.1. Proper Control and Accounting
BPA undertakes to maintain internal financial controls and segregation of duties in compliance with good accounting practice. We ensure that company accounts accurately reflect, properly describe and promptly record financial transactions undertaken, and are subject to regular audit.
BPA’s financial accounting policies generally operate in accordance with the accounting policies of its shareholders to comply with their corporate governance requirements.
BPA adheres to money laundering and international trade regulations.
4.2. Business Conduct
BPA is committed to the highest standards of ethical conduct in our business activities wherever we operate, requiring all activities to be conducted with honesty, integrity and fairness. We expect the same in our relationships with business stakeholders and our supply chain.
BPA is committed to ensure best value in the procurement of goods and services for its customers and to ensuring equitable treatment of contractors and suppliers in our tendering processes.
BPA carries out counter party due diligence checks on defined contractors and suppliers and on new clients. This includes checks for compliance with Anti-Bribery and Corruption, Anti-Money Laundering, and International Trade Sanction Regulations.
4.3. Anti-Slavery and Human Trafficking
BPA have a zero-tolerance approach to modern slavery, committing to acting ethically and with integrity in all our business dealings and relationships. BPA implement systems and controls to ensure no slavery occurs in our own business or in our supply chain.
We are committed to ensuring transparency in our own business and in our supply chain consistent with our disclosure obligations under the Modern Slavery Act 2015.
4.4. Personal Conduct & Prevention of Bribery
All BPA employees are required to avoid conflicts of interest between their private affairs (including family members) and their conduct of BPA company business. The offer, payment, soliciting and acceptance of bribes or inducements in any form, by employees, by organisations and by individuals providing services on our behalf are unacceptable practices. In addition, corruption in any form is unacceptable.
Employees must not provide or accept gifts or hospitality without the prior agreement of line management. Such gifts or hospitality must not be of material value, nor of a nature that public disclosure would cause embarrassment to BPA or potential damage to the reputation of its shareholders.
BPA follow a risk based due diligence procedure for assessing associated persons (as defined in Bribery legislation) through the bidding process.
BPA’s Code of Conduct and Disciplinary Procedure can be found within our HR Policies, which also provides guidelines on gifts and hospitality.
4.5. Use of Company Information and Resources
BPA requires that all employees handle sensitive information discreetly, protecting assets and information from improper access or use by others. The unauthorised disclosure of company / client / personal information (and data) or misuse of company / client assets is treated as a disciplinary offence.
BPA conducts its business within competition law and confidentiality guidelines and any specific confidentiality agreements in place.
5. COMMUNICATION
BPA regards openness of communications as essential in its business dealings and will provide full and relevant information to legitimate interested parties about our activities, subject to the observance of commercial confidentiality constraints.
6. CONFIDENTIAL REPORTING TOOL
BPA maintains a confidential reporting tool ‘SpeakUp’ to enable our employees, contractors, clients, and suppliers to raise compliance concerns anonymously. A link to the tool can be found on the BPA website.
John Armstrong
Director and General Manager, BPA
For and on behalf of the BPA Board
July 2025
Our business principles reflect our commitment to a strong ethical culture. As part of it we have a robust anonymous reporting system that enables us to listen to anyone along our business chain who has any non-compliance concern.
