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Doing business responsibly

Being a responsible business and doing the right thing for our stakeholders is engrained in how we do business at Paragon. We actively promote good practice on a range of important issues and expect the same from our suppliers and other business partners.

Board meeting

Governance and accountability

The Board provides strong and transparent governance and sets the framework for how we do business.

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'Human rights

Human rights

Our Board and our CEO have overall responsibility for ensuring that all areas across the Group uphold and promote respect for human rights.

'Modern slavery

Modern slavery

We support the objectives of the Modern Slavery Act 2015 and we are committed to making sure there is no slavery, servitude, forced or compulsory labour or human trafficking in our supply chain or any part of our operations.

Supplier relationships

We are committed to the fair treatment of all suppliers. In return, we expect our suppliers to help deliver a high standard of service to our customers and to act responsibly. Our Supplier Code of Conduct sets out our overall approach to supplier engagement and corporate responsibility and, importantly, the standards of behaviour we expect from our suppliers.

Supplier Code of Conduct
Supplier relationships

Business practices

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Anti-corruption

We follow the requirements of the Bribery Act 2010 and have a comprehensive anti-bribery and corruption policy, covering all employees and operated throughout the Group.

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Anti-money laundering

Operating in the financial services industry, we have procedures in place to make sure Paragon is not used to facilitate money laundering, sanctions abuse or other forms of financial crime.

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Whistleblowing

We have an established whistleblowing procedure, operated by Protect, a third-party charity, and supervised by the Board.

Full details are set out on pages 73 and 74 of our 2021 Annual Report and Accounts

Taxation

Materially all of the Group’s taxable income arises in the UK. Our tax strategy is to comply with all relevant tax obligations and cooperate fully with the tax authorities. We publish a tax strategy document annually, outlining our approach in relation to UK taxation.

Tax strategy
Tax strategy
Online learning

Learning together

Working in the banking environment means employees need to know about the different rules and regulations that we follow to make sure we support our different stakeholders effectively. To help with this, all employees take part in structured online learning throughout the year on topics ranging from vulnerable customers and modern slavery to money laundering and operational resilience.

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Human Rights

We respect all human rights and, in conducting our business, we regard those rights relating to non-discrimination, fair treatment and respect for privacy to be the most relevant and to have the greatest potential impact on our key stakeholder groups of customers, employees and suppliers.

We operate exclusively in the UK and, as such, we are subject to the European Convention on Human Rights and the UK Human Rights Act 1998.

We take steps to anticipate, prevent and mitigate any potential negative human rights impacts as well as enhance positive impacts through our policies and procedures and, in particular, through our policies regarding employment, equality and diversity, treating customers fairly, and information security.

Our policies seek to make sure employees comply with the relevant legislation and regulations in place in the UK and to promote good practice. They are formulated and kept up-to-date by the relevant business areas, authorised in accordance with the Group’s governance procedures and communicated to all employees.

The Group’s compliance with human rights regulation falls within its overall compliance regime, and any breaches or potential breaches would be investigated and addressed through the Group’s risk management framework.

Controversial sectors

Our credit policy prohibits lending to the follow sectors:

  • public houses and bars
  • licensed clubs
  • gambling and betting activities
  • activities of political organisations
  • manufacture of weapons and ammunition

Executive remuneration

Sustainability and ESG-related metrics are included in our remuneration structures:

  • risk, governance, customer and people metrics are included in our long-term incentive plan awards for senior managers
  • ensuring good customer outcomes and support for our customers form clear and regular strands in the annual bonus targets for both the CEO and CFO
  • the CFO has additional ESG-related metrics due to his Senior Management Function responsibility for the financial risks related to climate change