on behalf of the board: k Updates the code and policy each year, incorporating evolving legislation and evaluating any risks to the group’s integrity kDistributes the code and policy to managers and require them to personally sign up to playing their part in ensuring their implementation and therefore the group’s compliance k Requires managers to disseminate the code and policy within their area of responsibility and reinforce the importance of ethical behaviour through employee induction, training, employment contracts, staff handbooks and other actions.