Our Code

Our Code embodies the principles of ethics, integrity and leadership expected of us, consistent with our vision for a more human and humble Bank. It also accords with the behaviours we expect of senior managers in the firms that we regulate.

Adhering to Our Code is not simply about observing the letter of requirements in the policies: as they cannot provide for every contingency. We aspire to set an example of the best in public service: complying with Our Code is about understanding and embracing the values, principles and the spirit behind it. Compliance should not be merely passive: we need to speak out when we see something isn't right. Complacency, or a lack of curiosity about things that seem wrong, is as much a risk to our mission as is wilful non-compliance with our requirements.

Our Code outlines the disclosure and approval requirements under the applicable policies, focusing on what matters most. Key requirements are highlighted in Our Code, as appropriate. Declarations can be kept up to date easily using the Our Code Compliance system.

The Bank is a better place when we encourage errors to be identified and corrected, not hidden; where we do the right thing, even when it is difficult; and where we demonstrate that colleagues have nothing to fear from admitting an honest mistake. The Bank does not operate a 'one strike and you're out' approach for such matters.

Our Code applies to all of us: Governors, members of the statutory policy committees and colleagues from across the full range of the business. The non-executive directors of Court are subject to a separate 'Court Code' which, insofar as is relevant to their functions, is consistent with Our Code.

The Governors are all committed to Our Code and its four overarching principles: (1) acting with integrity, demonstrating impartiality, (2) being open and accountable, (3) being safe and secure and, (4) creating a diverse, inclusive and empowering culture, which are integral to our mission. We trust you share that same commitment and will find Our Code useful in guiding you in your contribution to the Bank of England.

The Governors

Introduction to Our Code

Our Code is in four sections.

Acting with integrity and demonstrating impartiality…

brings together the Bank's conflicts of interest policies, setting out our disclosure and approval requirements, and includes the proper use of Bank resources. These requirements apply to all of us at all times. We are individually responsible for making full, timely and accurate disclosures and approvals. This enables others within the Bank to decide whether these disclosures could represent a perceived or actual conflict of interest, and how any such conflicts should be handled.

Being open and accountable…

focuses on policies about how we communicate and keep appropriate records. It also includes policies on record keeping, internal and external information sharing, escalating external misconduct concerns and audio and audio visual recording of meetings.

Being safe and secure…

covers some of the fundamentals of how we work, in relation to operational, conduct and security risks, including the risk of financial crime. If we fail to work in a safe and secure way we could cause operational, reputational and legal harm to the Bank and undermine our mission. Mishandling firm sensitive or personal data could also have consequences for individual staff.

Creating an inclusive and empowering culture…

reflects the Bank's commitment to wellbeing, diversity and inclusion and confirms we do not tolerate discrimination, bullying or harassment. It includes details of how we are empowered, without any fear of retaliation, to 'speak up' about malpractice or misconduct, or raise serious concerns if we feel the Bank or anyone in it is contravening our policies.

Attestation

You must attest to Our Code annually, confirming that you have read, understood and complied (as appropriate) with the requirements in all Bank-wide policies and summarised in Our Code. This is an opportunity for each of us to check that we are up to date with the disclosures which should be made throughout the year and approvals which should be sought. Attestation is completed using the Our Code Compliance system.

Compliance and breaches

You are expected to protect yourself, colleagues and the Bank by identifying and reporting breaches^{footnote [1]} of Our Code and other Bank policies promptly. If you realise you have breached - or suspect that you might have breached - a requirement in a policy please report it to AskCompliance as quickly as possible, so that the issue can be redressed under the Bank's updated >Breach Management policy.

The Bank gives credit for you taking prompt responsibility for your mistakes. You should be aware that failing to discharge your responsibilities could lead to disciplinary or other action.

Managers should encourage a culture of openness and integrity around reporting breaches, ensuring their staff understand that prompt and full reporting is an integral part of managing breaches. Guidance for this can be found in the >Our Code and compliance guidance for managers.

There is useful information in the sections: 'Mandatory courses we need to complete', 'What do I need to disclose or seek approval/permission for?', 'How can I raise or report matters of concern?' and 'Who do I speak to for further information about the policies?'.

As well as Our Code, we must also comply with other Bank policies on the >Policy bank.

You are required to:

• Know, understand, and comply with the requirements in our Bank policies, of which the key ones are summarised in Our Code and ask questions if you need clarification or advice.
• Gain permissions or make the disclosures required.
• Confirm annually that you have read, understood and complied (as appropriate) with the requirements in internal Bank policies, some of which are summarised in Our Code.
• Report breaches, and challenge where you have concerns; escalate to your management if you feel you need to, or, where appropriate, use the Bank's Speaking up (whistleblowing) policy.

Acting with integrity, demonstrating impartiality

We strive to be objective in our decision-making and decisive in our actions. We take pride in the quality and the impartiality of our analysis and research. We engage with others professionally and make decisions fairly and on merit, using the best evidence available. We know that our reputation for impartiality and independence is vital to our effectiveness and, if lost, would be hard to recover.

The Secretary of the Bank - as the Bank's 'Conflicts Officer' - has senior manager responsibility for promoting the importance of identifying and managing conflicts of interest throughout the Bank.

General requirements

We are expected not to allow outside interests to influence or be suspected of influencing our judgement or decisions in our work at the Bank. We need to ensure that actual or perceived conflicts of interest, and perceptions of influence or unfair advantage, do not arise between the work of the Bank and our personal lives - whether from close personal relationships, business relationships, outside activities or from the nature or timing of our personal financial transactions. Policies in this section of Our Code contain disclosure and approval requirements, to safeguard ourselves and the Bank.

In addition to any disclosure and approval requirements set out in this section, you should inform your line management if you consider there is a risk of an actual or perceived conflict of interest, or a perception of influence or unfair advantage. You will need to help mitigate or resolve any such issue. It is particularly important to inform your new line manager of any actual or perceived conflicts when you change roles or teams within the Bank.

You must use the Bank's resources responsibly, ensuring value for money. When incurring travel and expenses costs on behalf of the Bank, you must ensure that these are reasonable and in accordance with the Bank's >Travel and expenses policy. For other expenditure, if you purchase or authorise the purchase of goods or services on behalf of the Bank, you must follow the requirements of the Bank's >Procurement policy. Failing to do so exposes the Bank to financial, legal and reputational risk. Where contractual arrangements are below £500 the >Non-travel expenses policy applies. This policy requires you to raise a purchase order, unless there is business justification for incurring the expenditure by another route. You must also adhere to the limits and conditions that apply to certain types of non-travel related expenditure.

The >Working from abroad policy outlines the requirements to follow when planning to work from abroad, as a result of an employee-instigated trip. We can work from abroad for a total of 40 working days in any rolling 12-month period (pro-rated for part-time working patterns). Executive Directors are required to attest annually that staff and managers in their areas are adhering to this policy.

If you are joining the Bank, the disclosure and approval requirements apply to existing roles you hold (directorships; relevant community or charity roles; other employment or certain political activities) and you will need to seek approval or disclose immediately in the Our Code Compliance system to determine whether you can retain those roles.

If you are a Head of Division (HoD) or more senior, references in these requirements to your 'HoD' should be read as referring to your line manager.

On appointment and annually as part of attestation, Governors and policy committee members will have a face-to-face meeting with the Secretary to provide an opportunity for full review of the individual's existing declared interests and to allow individuals to obtain advice about what needs to be disclosed.

Personal relationships

We are required to disclose certain close personal relationships within the Bank or externally that could create or be perceived as creating a conflict of interest, influence or unfair advantage.

This is particularly important in areas of the Bank's operations where there is dual control of assets or signature panels for release of payments. Also, you should not directly supervise, negotiate with, approve or otherwise participate in hiring, compensating, promoting, or retaining any person with whom you have a close personal relationship (as defined below).

Beyond this, if you know someone seeking employment with or business from the Bank you should discuss it with your line manager before you become involved in any way with the related decision-making process.

If you are unsure about whether to disclose such a relationship, please seek guidance from the Conflicts Team before making a declaration.

Please also seek guidance if you need to make lengthy inquiries to judge if you need to disclose a family relationship. Where an individual could not reasonably be expected to be aware of a relative's personal situation, the Secretary, Deputy Secretary or Conflicts Team in the Secretary's Department may allow an exception to the disclosure requirement.

Discussions on prospective employment and restricted duties

Personal financial matters

Our own savings, investments and borrowings sometimes give us a personal interest in decisions that are to be made by the Bank; and it is important to show that our own decisions about investments are not influenced by information that we know only as a result of working here, which is often not in the public domain.

Furthermore, insider dealing (trading on the basis of 'insider information' or disclosing it to someone else so they can benefit) is a criminal offence, likewise the manipulation of markets - such as spreading false rumours.

To safeguard ourselves and the Bank, we must disclose certain financial relationships. We must seek prior approval for certain personal financial transactions that we wish to make, and avoid some transactions altogether.

The financial relationship and personal financial transaction requirements apply to:

• your own financial relationships and transactions; and
• any financial relationships or transactions for another individual or organisation that you direct or advise on, including where acting as an executor of a will, trustee, director or shareholder.

Financial relationships

Personal financial transactions

The approval requirements for certain personal financial transactions are designed to protect you and the Bank from potential reputational harm. You must not carry out the transaction before approval is granted or if approval has been refused.

If you are unsure about whether to seek approval for a personal financial transaction, please seek advice from the Conflicts Team.

Some personal transactions, such as mortgages, take some time to complete after approval; please execute any approved transaction promptly and consider seeking re-approval where there has been a material delay between the initial approval and the transaction.

Personal portfolio managers and discretionary portfolios

The personal financial transaction approval requirements do not apply to investment assets where they are managed by a personal portfolio manager with full discretion over investment decisions, on terms that have been approved by the Secretary or the Conflicts Team in Secretary's Department. If you are selecting specific investments or collective investment funds yourself, even where these are index-tracking funds, you must review the list in the Personal financial transactions section to check whether your transactions need advance approval.

Additional requirements and guidance for Governors and members of policy committees etc

If you are a Governor or a member of the MPC, FPC, PRC or some other Bank committees (eg FMI Board, SONIA Oversight Committee, RTGS/CHAPS Board), you must provide an annual paper-based report to the Secretary of your stock of financial assets and liabilities.

It is highly undesirable for members of this group to be actively involved in managing an investment portfolio, even within the transaction approval arrangements. Accordingly, if you hold a substantial portfolio you are strongly advised to place it under full discretionary management on terms approved in advance by the Secretary.

Prohibited transactions

Certain kinds of transaction are never allowed.

Roles and activities outside the Bank

Directorships

Permission will not normally be granted for you to become a director of a company engaged in business, as this can give rise to a range of financial, legal and reputational risks. It will not be granted in the case of organisations engaged in financial markets or Bank-regulated firms and their holding companies. You may be permitted to take on the directorship of a non-trading company - for example, one set up by leaseholders in a block of flats to acquire or manage the freehold. Directorships of social enterprises or charities raise fewer concerns but still need approval. If you wish to become a director of a company (whether non-executive or otherwise), approval is required in advance. Any real or perceived conflicts of interest will need to be discussed and resolved.

You must seek approval via the Our Code Compliance system before becoming a >director.

Your request will be considered by the Secretary's Department and your HoD.

If you are a director through your employment at the Bank (eg of a Bank subsidiary) this should also be disclosed in the Our Code Compliance system, so that a central list is maintained. Examples include directors of the Bank of England Asset Purchase Facility Fund Limited and director trustees of BE Pension Fund Trustees Limited.

Community and charity roles

The Bank encourages employees to take on roles with charities and community organisations in a personal capacity. Certain roles have formal duties, for example as charity trustee or school governor. Although usually uncontentious, these may occasionally be controversial - as public cases have shown. Disclosure requirements apply to these kinds of roles so that we can consider, mitigate or resolve any real or perceived conflicts of interest or reputational concerns in advance. If these exist, we will discuss how they may be handled with you. In rare circumstances you may be asked to stand down from the role.

You must disclose via the Our Code Compliance system before taking on a >charity or community role with formal responsibilities such as:

• a charity trustee or member of a charity's investment committee;
• a school governor.

Your disclosure will be reviewed by the Secretary's Department and your line manager.

If the nature of the charity/organisation and its activities changes, or if your role changes, you should notify the Secretary's Department and your line manager.

Please note that if you make or advise on financial decisions as part of such a role then the 'personal financial transactions' pre-approval requirements will apply, as though the transactions were your own.

You do not need to disclose other forms of community and charity volunteering, such as coaching a football team, being a guide leader, helping with a charity event or working in a charity shop, but you will need to discuss this with your line management if it could have an impact on your work at the Bank, eg due to time commitments.

Any compensation you receive for community or charity roles or volunteering (other than expenses) must be refused or donated to charity, rather than being retained, unless the role has been approved as 'other employment'.

Some charities take the form of companies, in which case the approval procedure in the 'Directorships' policy applies.

Other employment

Most people at the Bank do not have additional employment. You must seek the approval of your HoD before you take up additional employment. This is in case it may give rise to an actual or perceived conflict of interest, influence or undue advantage and/or reputational harm to the Bank, or otherwise be considered detrimental to the Bank's interests. Your HoD will also need to consider whether this might impact on your ability to deliver your work at the Bank to the necessary standard. Sometimes, an external role might bring benefits; for example, a research career at the Bank might involve occasional teaching assignments or guest lecturing as part of maintaining an academic network.

Your HoD will also need to consider whether this might impact on (a) your ability to deliver your work at the Bank to the necessary standard, (b) your health, safety and wellbeing and (c) the Bank's compliance with any legal or regulatory obligations (for example, but not limited to, the Working Time Regulations 1998).

You must seek approval via the Our Code Compliance system from your HoD before taking on >Other employment.

Roles which are never permitted

Some roles are never permitted as they inherently give rise to the risk of a conflict of interest or perception of advantage.

Personal data and changes of personal circumstances

Everyone who works at any of the Bank's sites is required to have an appropriate level of security clearance for their role. This includes all employees, temporary staff, and contractors. In order to ensure your security clearance remains valid it is important to ensure the information it is based on is kept up to date. This means that you must make the Security Vetting Team aware of any changes in your personal circumstances. This includes reporting mental health conditions and abuse, misuse or addiction issues.

It is very unlikely that disclosing mental health conditions will affect your security clearance. Each case is dealt with on a case by case basis in consultation with the individual concerned. The Security Vetting Team are trained to deal sensitively and confidentially with any disclosures of mental health conditions. They understand that disclosure can be difficult and they will work with the affected colleague to support them through the process. Further information on this, including a list of the mental health conditions to be reported, can be found in the >Security vetting standard and >Vetting and mental health FAQs.

You mustcomplete personal data reviews when prompted and keep your personal data in the One Bank Service and Our Code Compliance system up to date.

You must complete actions directed by the Security Vetting Team, when requested.

You must disclose to the Security Vetting Team promptly details of >changes in personal circumstances that may affect security clearance. The list of relevant changes in personal circumstances now includes:

• a change in partner, getting married or entering a civil partnership or co-habiting;
• a change in nationality (this could be newly acquired or renouncing a previously held nationality);
• receiving a court judgment;
• being arrested, bailed, summonsed, receiving a police caution, being charged with a criminal offence or being convicted (other than minor road traffic offences);
• a material change in personal or financial circumstances;^{footnote [3]}
• severe medical or psychological illness (specifically where it or its treatment may cause blackouts, issues regarding perception of reality, judgements or paranoia); and
• abuse, misuse or addiction issues for prescription or illegal drugs, or alcohol.

If you hold a Developed Vetting level clearance you need to declare all the above changes in circumstances, plus the following:

• changes in adult co-residents at your address. This includes any house sharers/flatmates over 18 who are in addition to your declared partner; or
• your personal travel to high cyber threat countries.

Political activities

We recognise that, in engaging with your community, you may want to engage in political activities. The following requirements reflect that the Bank is apolitical. The requirement to obtain consent if you wish to stand for local or national elected office is in place because the Bank will wish to consider any sensitivity arising from your work, and any risk to our reputation for impartiality.

If you engage in any >political activity:

• Make clear that your involvement is solely in a personal capacity.
• Do not publicise that you work for the Bank.
• Take care to avoid any suggestion that the Bank supports or endorses your activities.
• Do not engage in political activity while on duty, or using Bank premises, systems or resources.
• You must comply with the Bank's >External communications and engagement policy when engaging in political activities, and raise any questions about media contact or public debate with the Executive Director, Communications or the Chief Press Officer.

You must seek consent from the Secretary via the Our Code Compliance system, giving at least three months' notice, if you wish to stand for local or national elected office. In exceptional circumstances, the Secretary may allow a shorter notice period.

The Secretary may consult local management and Governors.

You must notify the Secretary via the Our Code Compliance system if your political activity is likely to include involvement in party organisation, fundraising or campaigning (eg door-to-door canvassing).

You do not need to notify the Secretary about providing administrative support, such as delivering leaflets.

If you decide to stand for national elected office, you will be required to take unpaid leave from the point of adoption as a prospective candidate until the election. If you are elected, you must resign immediately.

In principle, the Bank is prepared to allow a member of staff elected as a member of a local authority or similar body to remain employed by the Bank.

'National elected office' includes: Member of Parliament; Scottish Parliament; or the London, Northern Ireland or Welsh Assemblies; or any other remunerated elected office.

Entertainment and gifts

Our role as the United Kingdom's central bank requires many of us to develop contacts with external parties. This will often involve the giving and receiving of hospitality. Occasionally we may be offered gifts. The Bank's position as a public body means that it has to apply, and be seen to be applying, high standards of ethical behaviour to maintain objectivity and commercial impartiality and to protect against any suggestion of impropriety.

When following the rules below, we need to apply common sense about whether an offer of entertainment or a gift should be accepted, and should consider the accumulating effect of entertainment and gifts on individuals or areas. If the acceptance of entertainment or gifts by an individual member of staff was challenged, it would be necessary to show that acceptance was lawful, appropriate, consistent with the Bank's rules, and did not give concern that personal judgement or integrity had been compromised.

UK legislation on bribery applies to us all at the Bank. Under the Bribery Act 2010, it is an offence for a Bank employee to offer, promise or give a bribe to another person, or to request, agree to receive or accept a bribe from another person, and individuals may be subject to prosecution. The Bank may also be found liable if it fails to prevent a bribe by an associated person.

General requirements

If you are in any doubt about accepting or offering a gift or entertainment, then you should discuss this with senior management before doing so.

Entertainment and gifts must be fully and accurately recorded for reporting in accordance with arrangements approved by the Secretary's Department. In general this means using the Our Code Compliance system for entertainment and gift reporting. This includes recording gifts you have accepted, that you are subsequently not given permission to keep. This process is subject to audit.

Where necessary, business areas may, with the approval of the Secretary, adopt additional local business area rules for gifts and entertainment to suit the particular circumstances of their work. These must be at least as stringent as the >Bank-wide entertainment and gift policy. As different areas may have different general permissions in place, you should make sure you understand any general permissions in your area.

Entertainment rules

For example, it would not be appropriate to accept hospitality from professional advisers or suppliers which was, or could be perceived as, seeking to influence a decision to use their services or procure goods.

Business contacts may also be personal friends. For the purpose of these rules, any hospitality enjoyed in your role at work should be reported unless it is both clearly offered and accepted in a personal capacity, not an official capacity (eg where a firm is paying for the hospitality). Invitations from personal friends that are not offered in an official capacity and do not involve corporate hospitality (ie not paid for by a firm) do not need to be reported.

If you are invited to an event accompanying your spouse or partner, you should treat the invitation as though it was to yourself at the Bank and apply these rules accordingly (for example, is the invitation from a Bank or FCA regulated firm; from professional advisers; or from an organisation that you have contact with as part of your role?)

If in doubt about whether it is appropriate to accept an invitation, please discuss with senior management or seek advice from the Secretary's Department before accepting the entertainment.

Gift rules

Sometimes gifts take the form of 'prizes' offered by a corporate entity when you are on Bank business. The same rules apply.

If you have accepted a gift and you are not given permission to keep it:

• pass it to Community for disposal for charity;
• give it to charity directly if the value is under £30;
• if it has a value less than £100 it may be disposed of for charity under local arrangements (eg raffle) approved by your HoD. No gifts worth more than £30 (such as hampers or 'goodie' bags) should be broken up into smaller portions to comply with the £30 rule.

Being open and accountable

We must communicate effectively across the Bank, the public sector and the financial sector and with the public. In our communications, we are open, honest and straightforward. This is supported by the policies in this section and by good record keeping. When sharing information in the Bank and making information available outside the Bank we need to be mindful of the obligations set out in the policies in this section, and the circumstances in which we have a duty to escalate - including misconduct concerns.

Record keeping

Good record keeping is vital. In the course of our work, we make critical policy, supervisory and operational decisions that have a broad impact. We are ultimately accountable to the people of the United Kingdom for those decisions. We are responsible for the information entrusted to us in the work we do and we have to be accountable for managing it with due care, skill and diligence.

In addition, the >Creating records of meetings, committees and calls policy sets out requirements for the prompt creation of notes for record and/or minutes of discussions. It also specifies record keeping requirements for committees that the Bank sponsors or attends which include external participants.

As we continue to conduct many of our meetings online or as hybrid meetings using services, such as MS Teams, it is important to ensure you are familiar with the requirements of the >Audio and audio visual recording of meetings policy. This policy sets out that meetings should only be recorded on an exceptional basis, with the prior approval of the meeting chair, the consent of others present and your line manager/HoD. The policy outlines when it is appropriate to make an audio or audio visual recording of a meeting and specifies the technology which must be used and how recordings should be saved, protected and shared.

Internal and external information sharing

The information held by the Bank is one of its most important assets. Information often needs to be shared actively and widely within the Bank to allow it to be used effectively. But in some cases, there may be contractual or other legal or policy reasons to restrict access to information internally (eg market sensitive information). We must understand when restricting access is necessary and how to achieve it. We trust our colleagues to be aware of these restrictions and to handle the information they receive properly (see also Being safe and secure).

Freedom of Information Act

Like other public bodies, the Bank is subject to the Freedom of Information Act 2000 (the FoI Act) and is accountable to the Information Commissioner for its compliance. We have a duty to respond to Freedom of Information (FoI) requests where information is held and not subject to exclusions or exemptions set out in the FoI Act. This applies whether or not the request specifies the FoI Act.

External communications and engagement

Engagement and how we communicate with external contacts is a core part of achieving our mission. We are open, honest and straightforward in our external engagement. Comments from any of us who work at the Bank can carry great weight.

The Bank's >External communications and engagement policy sets out the requirements for Bank staff when communicating and engaging externally, including specific provisions for the handling of media enquiries, social media use, and participation in 'non-core' meetings and initiatives.

Social media

When using social media in a personal capacity you must be mindful not to leave yourself and/or the Bank open to unwanted attention or reputational harm. The information you share on social media can also be used to target you, those you know and the Bank. It's common for criminals and hostile actors to hide behind seemingly legitimate social media profiles, even posing as recruiters or talent agents, so you must be mindful of engaging with someone you don't directly know.

Escalation of external misconduct concerns

We have contact with many parts of the financial sector and many people who work for financial sector firms. Through these contacts, we may occasionally receive indications or speak directly with individuals who allege misconduct (such as fraud, dishonesty, or market abuse). Equally, these contacts may allege misconduct by third parties. We should report such matters promptly and in the correct manner.

Local areas, such as Markets and Banking, Payments and Innovation, also have an embedded escalation process for external misconduct concerns, to be followed in addition to the general approach specified here.

If you have been contacted by an external whistleblower or have received evidence or indications of external misconduct in the financial sector, then please adhere to the following information:

• External whistleblowers should be re-directed to the >Intelligence and Whistleblowing (IAWB) Team in the first instance.^{footnote [4]}
• If it is not possible to re-direct an external whistleblower, then as much detail as possible should be captured (contact details in particular) and passed to IAWB so they can follow up appropriately.
• If you have any doubt as to whether you should treat a contact as a whistleblower or hold whistleblowing related information, please speak to IAWB.
• No further discussion or dissemination of the information should be made. This includes with the firm itself, regulatory counterparts or members within your own team. It is imperative that the 'need to know' principle is applied at all times.
• If discussions during a meeting begin to stray onto topics which you consider inappropriate and/or could give rise to some form of reputational harm to the Bank you should take action. Silence may erroneously be taken as consent or approval. You should request that your concerns are formally registered in the minutes or record, unless there is a 'tipping off' risk. Feel empowered to leave the meeting, if you consider it appropriate. In such circumstances, inform your line management promptly, record the details in writing as soon as possible, and follow the escalation process.
• If you have received external whistleblowing information via email, then please forward to [email protected] and delete the original email after IAWB have acknowledged receipt. Your HoD, Director or Executive Director will also advise you on how to manage the relationship with the relevant person or firm thereafter.

Information on how we can raise concerns about the Bank itself can be found in 'internal whistleblowing or Speaking Up'.

Being safe and secure

Classifying, handling and protecting information

We take decisions for the public good based on a vast amount of information; much is confidential and/or sensitive and concerns or belongs to others. We all have a collective responsibility to maintain the confidentiality, integrity and availability of the information we generate and use, as set out in the >Governor's security charter.

We all sign a >Declaration of Secrecy when joining the Bank. This requires us to observe the strictest secrecy with respect to information of any kind acquired in the course of our duties relating to matters concerning the Bank and others with whom we have dealings (for example, the firms that we supervise).

Our systems and controls for safeguarding information depend upon us classifying and handling it appropriately in accordance with the >Information security classification scheme standard.

The way we handle information, electronically or in paper form, must reflect its classification and our obligations with respect to different kinds of information (see also >Open and accountable on record keeping and internal and external information sharing).

Privacy and data protection

We all have a responsibility to help ensure that the Bank complies with the principles and requirements for handling personal data as set out in privacy and data protections laws.

Personal data means any information from which a living individual can be identified, whether directly from the information itself (eg a name, online identifier and location data) combined with any other information. Mishandling personal data can have far-reaching consequences for the Bank, the person whose data it is and - in some circumstances - for us as individuals.

The Bank has data protection policies and awareness initiatives to ensure that we are mindful of our responsibilities and that the personal data the Bank holds is handled safely and securely. Further advice is available from the Bank's Privacy Team. Please ensure you are familiar with the >Privacy and data protection conduct policy.

Using e-mail

We heavily rely on email to communicate with each other and the outside world. While it enables us to do our jobs, it is also the most common medium through which data loss and cyber incidents occur. Although there are technology safeguards in place, the only way to avoid mistakes - such as sending information to the wrong person - is to take extra care when sending e-mails; double-checking the recipient, attachments and classification and reading and appropriately responding to any warning prompts. This is particularly pertinent when working from home.

When you are sending e-mails, remember:

You can find out more about >phishing and how best to protect yourself.

Using Bank IT and other resources

We are permitted in certain circumstances to make limited, reasonable, personal use of Bank IT devices, but not in a way that would conflict with our work or compromise the security of the Bank. Reasonable levels of personal use however do not extend to using Bank IT to run an external business. If you have a Bank-owned mobile device, please ensure you are familiar with additional requirements in the >Personal usage guidance.

Using Bank IT for audio-visual calls

Your communications and activity whilst using Bank IT equipment must be appropriate and secure. All calls and any information you share via these mediums must be protected, particularly when it includes external participants.

To find out more on how to use Bank IT safely and securely, please see the >Security conduct policy, particularly the section on 'Use of Bank IT equipment' and 'Using audio and video conferencing facilities for Bank business'. This includes a >Monitoring Notice, which sets out the extent to which the Bank is monitoring use of its equipment.

Safety and security at the Bank's premises

The Bank's premises are a safe and secure environment, however we must all remain alert to matters that look out of place or may indicate a security risk. Immediate concerns must be reported to the Security Control Room. Health and Safety concerns can be reported via Facilities Online or to the Health and Safety team.

We help protect ourselves, colleagues and visitors by reporting promptly any issues or concerns about safety or security.

Safety and security outside the Bank's premises

Safety and security is also a priority whenever we are working away from Bank premises.

If you are 'working away from Bank premises', eg at home, in transit or abroad, the >Security conduct policy sets out the steps you must take in order to help maintain physical and information security.

Safeguarding against money laundering, terrorist financing and financial sanctions

As a financial institution, the Bank is committed to high standards of financial crime prevention and must comply with financial sanctions legislation. Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, Proceeds of Crime Act 2002 and the Terrorism Act 2000, we each have a statutory duty to disclose, as soon as reasonably possible, information that indicates money laundering or terrorist financing is occurring or has occurred. This could include suspicions about attempts to abuse the Bank's own processes in order to launder money or finance terrorists. This could also include indications that external institutions may be involved in, or instrumental to, money laundering or terrorist financing activity.

Within the Bank, the person responsible for investigating and reporting such suspicions is the Bank's >Money Laundering Reporting Officer (MLRO).

If you are involved in the Bank's financial operations then you must be aware of relevant anti-financial crime controls and support their effective operation. A small number of teams around the Bank may need to consider the impact of US sanctions and if you receive notification that you are a relevant line manager then you must seek advice from the AML and Sanctions Team if anyone in your team is a US person. See the >Anti-money laundering, counter terrorist financing and financial sanctions compliance policy.

Safeguarding against tax evasion

The Bank has zero tolerance to tax evasion and we safeguard against the risk of facilitating any such activity. If you have any concerns, raise these with the >MLRO.

You must complete relevant training, when asked to do so (within One Bank Service, navigate to Me >Learning).

Creating a diverse, inclusive and empowering culture

Building a diverse and inclusive Bank in which everyone feels they belong is a strategic priority for the Bank. The current global context presents both challenges and opportunities, and the Bank needs to be human, humble and in step with the changing world to respond effectively. We need leaders, managers and staff who embody this ambition, and a truly inclusive culture to enable all colleagues, whatever their background and ability, to reach their full potential. We also seek to ensure that colleagues are supported in managing their time between work and personal life, to enable them to thrive at the Bank. We do this because it is the ethically right thing to do and because it will make us even more effective as an organisation, now and for the future.

Diversity, Equity and Inclusion Strategy

The Diversity, Equity and Inclusion Strategy is evolving and is an important part of delivering the culture we need and in supporting Strategic Priority Six (SP6), 'Build a diverse and inclusive Bank'. SP6 creates a framework to bring together various strands of work which aim to:

• advance the development of an inclusive culture;
• adapt our culture and behaviours to support new ways of working, learning from internal and external experience;
• transform our leadership capability to support our human and humble ambition and cultural vision; and
• develop a more diverse workforce and implement the Court Review's recommendations.

There are Directorate, Deputy Governorship and Bank-wide inclusion initiatives and you can learn more about the Bank's approach to inclusion by speaking to the Culture, Diversity, Equity and Inclusion Division, or your area's Diversity and Inclusion lead, as outlined in >Inclusion across the Bank.

During attestation, each year, we ask you to complete the Personal Data Review (PDR) in One Bank Service to ensure your personal information, including contact details, are correct. As part of this, we ask you to complete the 'Demographic Info' and 'Disability and long-term health conditions' sections of the PDR. Sharing your personal information with us helps ensure that we support all colleagues effectively, allowing us to build a better picture of the people who work for the Bank and so target our activity effectively. Information shared with the Bank in the 'Demographic Info' and 'Disability and long-term health conditions' sections in One Bank Service cannot be viewed by your manager(s). Declared diversity characteristics are used to produce metrics across the employee lifecycle and for a range of activities to enable the Bank to monitor targets and pursue its diversity and inclusion objectives. Whenever possible, this is done without identifying individuals. For small populations, where it may be possible to identify an individual, access to this type of personal data is strictly limited with defined access controls. If you would prefer not to share this information at any stage, you can select 'Prefer not to say'.

Discrimination, bullying and harassment

The Bank has zero tolerance for discrimination, harassment and bullying. We always need to be professional, courteous and respectful in our interactions with Bank colleagues, third party suppliers or visitors.

The impact of your actions matters as much as your intent. The Bank may consider an individual's actions and behaviour as bullying or harassment, even if this was not the intention.

If you feel you have been discriminated against, harassed or bullied, or have seen anyone else treated in such a way, raise the matter with your manager if appropriate and the Employee Relations Team under the >Diversity policy or the >Anti-harassment and bullying policy.

We recruit, hire, develop, promote, manage and provide conditions of employment without regard to age; disability; gender expression/gender identity/gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation. We are all personally responsible for the avoidance of unfair discrimination under the Equality Act 2010

Active by-standing

Active by-standing is taking action to stop the harm when a colleague is experiencing microaggression, harassment, bullying or other harmful or inappropriate behaviour that takes place in your presence. We strongly encourage appropriate active by-standing which helps to advance our diversity, equity and inclusion goals. We support colleagues who intervene. It is illegal to suffer adverse treatment from leaders, managers and colleagues because of your active bystander intervention. Please contact the Employee Relations Team if you need support.

Speaking up (internal whistleblowing)

We are all encouraged and empowered, without any fear of retaliation, to speak up about a serious concern about malpractice or misconduct that affects others or the Bank as a whole - such as possible fraud, criminality, breach of a legal obligation, environmental damage or a danger to the Bank and its staff. We can raise these concerns via the >Speak up (internal whistleblowing) arrangements, whether via line management, Secretary's Department, or via a Speak Up nominated representative.

We are committed to supporting those who speak up. It doesn't matter if they are mistaken. We do not tolerate any victimisation or harassment of those who speak up. They will not lose their job for speaking up. If you speak up and ask us to protect your identity we will do so unless otherwise required by law. If it becomes impossible to investigate without disclosing your identity, we will discuss this with you before taking the issue further.

Mandatory courses we need to complete

We must all keep up-to-date with mandatory training and complete (and repeat) courses when asked to do so. All courses are available in One Bank Service, navigate to Me > Learning.

The following mandatory e-learning courses must be completed by ALL new joiners within 30 days of joining the Bank:

• Emergency Procedures.
• Security Annual e-learning (2022).
• Data Protection e-learning (2022).
• Freedom of Information.
• Records and Information Management at the Bank of England (2022).
• FileSite.
• Inclusion (not currently available).

In addition, all existing colleagues will be asked to repeat the above courses (apart from the FileSite course) at periodic intervals.

Anti-money laundering training

The following areas of the Bank must complete the first module of anti-money laundering e-learning:

• All of BPI, Markets, Resolution, Risk (including Internal Audit), Governor's Office (including Deputy Governors' offices) and Legal Directorate;
• Finance and Performance: Finance Reporting, Control and Tax;
• Procurement;
• Secretary's Department: Investigations & Monitoring Team;
• Communications: Public Enquires Group, Press Office;
• FMID;
• MA: Agencies, DAT, CCBS;
• Notes: Notes Distribution Policy, Future of Money, S&NI Team, Notes Compliance Team, Notes Accounting, Banknote Education Team, Mutilated Notes Team; and
• PRA: Banking Supervision, SRS, UKDT, Insurance ED, Insurance Supervision, Regulatory Operations.

Staff in Markets and BPI, and those in Internal Audit looking after Markets and BPI, are also required to complete the second module of anti-money laundering e-learning.

If your work involves the physical process of exchanging bank notes you are required to complete the third module of anti-money laundering e-learning. The AML team will be in touch directly to let you know if this applies.

Tax evasion course

The following areas of the Bank must also complete the course 'Criminal facilitation of tax evasion':

• Finance and Performance Directorate;
• Technology Directorate; and
• Shared Services Directorate: Business Services Division, HoD & Support Office, PPSD Projects office, Procurement team, Capital Works Office & Estate management office, manager of the Audio Visual team, Events & Services team (including and above Scale F only) and HSE office.

What do I need to disclose or seek approval/permission for?

Conflict of interest checklist
Disclose and keep up to date:
Personal relationships	See here
Disclose to the Secretary, Deputy Secretary or Conflicts Team:
Discussions about employment with a Bank regulated firm, a significant dealing counterparty of the Bank or firm that you have contact with as a supplier	See here
Financial relationships	See here
Community or charity roles with formal responsibilities, including becoming a trustee	See here
Involvement in political activities	See here
Seek approval before:
Making a personal financial transaction covered by the pre-approval requirements	See here
Taking up a company directorship	See here
Taking up additional employment	See here
Putting yourself forward for selection for local or national elected office	See here
If offered entertainment and gifts:
Discuss with senior management if in doubt about what you can accept	See here
Report any entertainment and gifts received	See here
Other disclosures/permissions
If your personal circumstances change materially:
Make the Security Vetting Team aware	See here
If you want to take part in a media discussion or speak at an event where the media is present:
Seek the Bank's Press Office approval	See here
If you want to take OFFICIAL-GREEN or OFFICIAL-AMBER papers off-site overnight:
Follow the requirements in the >Security conduct policy to log these	See here
If you want to take a photograph, video or recording the Bank:
You need permission under the >Security conduct policy	See here

How can I raise or report matters of concern?

If there is something of concern that you may need to report, typically the first thing to do is to discuss the matter with your line manager, if available.

Policy	Report
Breaches of Our Code or other Bank internal policies	Report direct to the Compliance Division via [email protected].
Security incidents/emergencies	Report to the Security Control Room For incidents of a technical nature, report to the Technology Service Desk For security concerns/queries [email protected]
Bullying, discrimination or harassment	Discuss with Employee Relations Team Log an AskHR call in One Bank Service
Data protection breach or any loss of Bank information or devices	Report to your line manager and HoD. Follow the >Data loss reporting process Outside working hours telephone the Security Control Room or the Technology Service Desk
Freedom of Information request and Subject Access request	Forward to the Information Access Team [email protected]
Money Laundering concerns, or financial sanctions issue	Report to Money Laundering Reporting Officer or deputy Money Laundering Reporting Officer [email protected]
Grievances (dissatisfaction with your treatment in the Bank, or problems or concerns about your work, working conditions or relationships with colleagues)	Discuss with Employee Relations Team Log an AskHR call in One Bank Service (NB Grievances are governed by the Staff Handbook, not Our Code)
Speaking up (internal whistleblowing: serious concerns about disregard of internal Bank policies, a risk to the Bank, a possible fraud, misconduct or malpractice)	Discuss with line manager, nominated representatives listed in the policy or the Conflicts Team via [email protected]
Escalation of external misconduct concerns	Your HoD, Director or the Bank's Intelligence and Whistleblowing Team via [email protected]

Who do I speak to for further information about the policies?

If you have a question about a policy under Our Code, you could:

Speak to your line manager or HoD; Email [email protected];

Contact the relevant policy owner/expert, as follows:

Policy	Policy owner/expert
Breach Management policy	The Compliance Department [email protected]
Conflicts of interest policies (personal relationships, financial relationships, personal financial transactions, directorships, community and charity roles, political activities)	The Secretary's Department Conflicts Team [email protected]
Entertainment and gifts policy; Secrecy declaration; Speak up policy (internal whistleblowing)	The Secretary's Department Conflicts Team [email protected]
Restricted duties policy; Other employment policy (co-owned with the Secretary's Department)	Employee Relations Team Log an AskHR call in One Bank Service
Anti-harassment and bullying policy; Inclusion; Working from abroad policy	Employee Relations Team Log an AskHR call in One Bank Service
Records management policy; Creating Records of Meetings, Committees and Calls policy; Audio and audio visual recordings of meetings policy; Internal and external information sharing policy	The Secretary's Department - Records Management Team [email protected]
Security conduct policy	Cyber Security [email protected]
Privacy and data protection conduct policy	Privacy [email protected]
Security Vetting	Security Vetting [email protected]
Social media	[email protected]
Health and Safety policy	Health and Safety [email protected]
Freedom of Information	Information Access Team [email protected]
Subject Access Request	Information Access Team [email protected]
External communications and engagement policy	Press office [email protected]
Anti-money laundering, counter terrorist financing and financial sanctions compliance policy	Money laundering, Operational Risk & Compliance, Markets & Banking COOD [email protected]
Procurement policy	PPSD, Procurement [email protected]
Safeguarding against tax evasion	Finance Division, ED Office [email protected]
Travel and expenses policy; non-travel related expenses policy	Finance Division, Expenses [email protected]

How we use your information

Information we collect

As part of the policies under Our Code, you may be required to provide personal data to the Bank.

From time to time, the Compliance Division may request further information from you about the matters you have disclosed or where you have sought prior approval, for example relevant bank statements or appropriate tax returns.

Why we need your personal data

We collect your personal data for the purposes of ensuring compliance with Our Code. This is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Bank. In particular, we use your data in order to:

• understand whether there are any actual or potential conflicts of interest between your work and your personal life, or any risk of perception of undue influence; and
• ensure appropriate mitigation where such matters arise.

In the case of special category personal data such as political opinions, it is in the substantial public interest to process this personal data.

What we do with your personal data

Information you provide will be treated as strictly confidential, and will be stored securely.

Information you provide in relation to an approval request or disclosure may be reviewed by the Secretary's Department, Local Reporting Officers (for personal financial transactions), line management, the Compliance Division and Internal Audit. It may also be necessary for Our Code related information to be made available to People and Culture (formerly HR), the Security Vetting Team, the Legal Directorate and relevant senior management, on a 'need to know' basis. Information relating to Policy Committee members may also be made available to the relevant Committee and its secretariat.

We will retain your personal data for the periods specified in the Bank Records Classification Scheme.

Your rights

You have a number of rights under data protection laws. For example, you have the right to ask for a copy of the personal data the Bank holds about you. This is known as a >Subject Access Request. You can ask about how the Bank processes or deals with your personal data, and you may also have the right in some circumstances to have your data amended or deleted.

To find out more about those rights, to make a complaint, or to contact our Data Protection Officer, please see >How we use staff data notice or visit >Privacy and the Bank of England.

Our Code
Version 1.0, June 2015
Version 1.1, September 2016
Version 2.0, September 2017
Version 2.1, September 2018
Version 2.2, August 2019
Version 2.3, November 2020
Version 2.4, November 2021
Version 2.5, January 2023

Public link

Please use the above public link if you want to share this noodl on another website.