Statement of business principles and corporate ethics

‘Keeping Openness and Excellence at the Forefront’

Company Profile

Shanks Group plc is one of the UK’s largest waste management companies and, with its operations in Belgium and The Netherlands, is also a leading player in the European market. Beyond Europe, Shanks also has activities through its environmental remediation services. As a Group, Shanks employs over 3,000 people based at more than 100 sites.

The Group provides an extensive range of waste management services and handles a wide variety of wastes, including domestic refuse, commercial waste, contaminated spoils and hazardous waste. Operations range from collections, domestic and commercial waste recycling, thermal treatment systems, industrial cleaning to special waste treatment and modern landfill. Shanks is a significant generator of electricity from landfill gas and produces a range of fuel-from-waste products.

Introduction from the Group Chief Executive

Those who lead a modern company have a duty to ensure commercial success. However, the way this is achieved is equally important. This document defines the basic principles and ethics that guide Shanks in its business conduct around the world. This is the first time that our principles have been consolidated into one document, although the key elements of it have previously been included in our Group Annual Report and Accounts, Health & Safety Annual Report, Environmental Report and numerous Group Policy documents and company standards.

Shanks is strongly committed to the principle that our business goals will be best achieved when we act with honesty, integrity, openness and fairness in all of our dealings with stakeholders. This principle provides the overall ethical framework for all our operations and activities. It is critical that we live up to our values, build a relationship of trust with our stakeholders and protect our reputation.

At Shanks we want to be regarded as a good ‘corporate citizen’ wherever we conduct our business. Shanks employees will inevitably encounter customs and laws, which vary widely, but the guiding rule is that our business principles should never be compromised. We want the principles and ethics set out in this document to provide guidance, vision and a charter to inspire Shanks employees to take leadership and responsibility in ensuring the proper conduct of our business.

Group Chief Executive

Business Conduct

Shanks companies will behave legally, honourably and ethically. At all times we will:

• Ensure that our business practices comply with relevant legislation and regulations as a minimum in each country in which we operate
• Treat our stakeholders and other interested parties as we would want to be treated ourselves
• Ensure that decisions are taken by people duly authorised, qualified and accountable
• Trade and compete fairly, within a framework of applicable competition laws, never obtaining or maintaining business through illegal conduct
• Report financial information in a complete, accurate, honest and timely manner
• Not tolerate any employee or agent of the company offering, soliciting or receiving any form of bribe or any other similar inducement
• Consider the social, ethical, health and environmental implications of our business activities
• Uphold the principles set forth in the United Nations Universal Declaration of Human Rights wherever we operate, respecting local laws and regulations
• Not make any payments to political parties, organisations or their representatives
• Recognise that we have a responsibility to define and support externally all our commercial activities where that affects ourselves or any of our stakeholders
• Measure, review and monitor our performance against this statement of business principles and ethics

Shanks Commitment to its Stakeholders

‘Honesty, integrity and fairness’

Shareholders

Shanks aims to deliver superior value to its shareholders and in order to do this we will:

• Protect their investment, manage risk and ensure funds are used as agreed
• Communicate to shareholders all matters that are material to an understanding of the future prospect of the business

People

Our people are our most important and valuable asset. Shanks wants its employees to feel respected, well managed and able to fulfil their potential. In order to achieve this we will:

• Ensure that dignity at work and mutual respect are enshrined in all our working practices and the way we behave towards each other
• Respect the human rights of all employees and support the rights of the child by not employing anyone under the age of sixteen
• Provide all employees with good and safe conditions at work
• Treat employees honestly and fairly, respecting their individual and collective rights
• Promote equality of opportunity and encourage diversity in our workforce ensuring the recruitment, recognition, development and best use of talent
• Promote effective communications and consultation to encourage the involvement of employees in the planning and direction of their work, wherever appropriate involving Trade Unions, Works Councils and other employee groups
• Maintain clear disciplinary and grievance procedures with access to advice for fair and consistent application.

Customers

Shanks wants to win and maintain its customers by developing and providing a range of services which are high quality, safe, environmentally acceptable and value for money. We want to build relationships of trust and confidence. In order to do this we will:

• Communicate regularly with customers and listen to their views
• Talk to customers about their environmental and health & safety liabilities and responsibilities
• Aim to anticipate the future needs of our customers, promoting innovation, best practice and value for money
• Respond promptly to customer feedback, taking speedy action to improve our performance
• Ensure that all our services are supported by the requisite technological, environmental and commercial expertise
• Work with our customers to create added value

Suppliers and Subcontractors

Shanks aims to procure the highest quality products, services and value for money from all its suppliers and subcontractors. We will encourage our suppliers and subcontractors to abide by the principles of our policy on corporate ethics. To ensure that this is the case we will:

• Assess critical suppliers and subcontractors as appropriate
• Communicate regularly to guarantee that our ongoing and changing needs are addressed
• Expect that our complaints are dealt with promptly and action is taken to improve future performance
• Pay in accordance with contractual terms for products and services which meet our requirements

The Community

We want to succeed as a business in alliance with the communities in which we operate. We will therefore:

• Engage in a constructive dialogue with the community to balance our needs and achieve solutions which will have a mutual benefit, particularly via community liaison committees at all appropriate sites
• Operate an open door policy at all operational sites
• Work with local communities to develop skills, education, training and shared knowledge
• Respect at all times local cultural and religious needs
• Seek opportunities for involvement through community, educational and donation programmes
• Respond promptly to enquiries from interested parties and provide relevant information regarding our activities

Health, Safety and the Environment

Shanks has a continuing commitment to high standards of health safety and environmental protection, we will therefore:

• Guarantee that health, safety and the environment will be a prime consideration in any activity undertaken by Shanks
• Apply health, safety and environmental law as the starting point for all Shanks operations and, wherever practicable exceed legal standards
• Promote and maintain policies on health, safety and the environment which will encourage best practice
• Carry out regular risk and impact assessment of our activities
• Allocate responsibilities clearly across all levels of the Company
• Ensure that all employees are competent and adequately trained
• Measure, review and monitor our performance and report publicly on critical performance measures