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Supplier Code of Conduct

About Paragon Banking Group PLC

Paragon Banking Group PLC (the Group) is a specialist banking group. We offer a range of savings and specialist lending products to individuals and SMEs in the UK.

Listed on the London Stock Exchange, we are a FTSE 250 company, headquartered in Solihull, employing around 1,400 people across the UK.

We are a regulated organisation which means that we are obliged to apply regulatory controls when appointing suppliers and managing contract delivery. This is particularly relevant to any suppliers with access to our systems, our data, or who engage directly with our customers. In these circumstances we need to ensure that we have identified and managed any associated risks. This Code of Conduct sets out the Group’s overall approach in respect of supplier engagement and our own corporate responsibility.

What we expect from our suppliers

We believe that working well with our suppliers is central to our purpose and key to our continued success. As a baseline we therefore expect our suppliers:

  • to work in line with all relevant regulations and legislative requirements
  • to consider the impacts of their products, operations and working practices on the environment and to the Group, and have measures in place to manage these
  • to operate ethically, to maintain high standards of corporate conduct, to respect the welfare and wellbeing of their employees and the communities in which they operate

Corporate Conduct

Bribery and Corruption

The Group has no tolerance for and does not in any way condone bribery and corruption. We have a culture of ethical behaviour and expect our employees and individuals acting on our behalf to act with integrity in all dealings related to the Group’s business.

We value our reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above commission of any crime, any involvement in bribery reflects adversely on the Group and all employees are required to complete mandatory training to recognise and respond appropriately to bribery and corruption.

Gifts and Awards from Suppliers

Under no instance may gifts or hospitality be accepted from a supplier during, or for a period of three months after, any contract negotiation (including the procurement tender process, awarding and/or variations to the contract).

Gifts and/or hospitality offered outside of these circumstances are subject to internal approval.

Data Protection

The Group has policies and procedures to ensure compliance with The Data Protection Act. The Group’s Data Protection Policy Standard applies to all data acquired, held, used and managed by all constituent parts of the Group and its suppliers.

Modern Slavery

The Group has a zero-tolerance approach to slavery and human trafficking and is committed to taking all reasonable steps to ensure that there is no slavery and human trafficking in our supply chains or in any part of our business.

Our policy is to require all our suppliers to comply with applicable legal requirements, including in relation to modern slavery and human trafficking. Paragon’s slavery and human trafficking statement can be found on our website wwwparagonbankingoup.co.uk.

Employment Practices

We’re passionate and committed to our people. We aim to be an organisation that our employees are proud of, providing great training and development opportunities. We adopt the highest standard of employment practices, being fully compliant with both the spirit and the letter of all applicable laws and regulations.

We work closely with Investors in People (IIP) because we recognise the value of our people. We are proud to be recognised currently by IIP with the Gold standard award.

Equal Opportunities

The Group is fully committed to the elimination of unfair and unlawful discrimination and values the differences that a diverse workforce brings to the organisation and to the community in which it operates.

Further policies are in place to ensure that all employees and every worker and/or contractor engaged (directly or via third parties) by the Group meet the highest standards of integrity and professional conduct. These policies relate specifically to:

Harassment - defined as unwanted and offensive conduct relating to a relevant protected characteristic that affects the dignity of men and women in the workplace. Protected characteristics include: sexual orientation, transgender status, marital or family status, colour, race, nationality, creed, culture, religion or belief, age, disability, political conviction, trade union membership, AIDS/ HIV or any other personal characteristic and may be persistent or an isolated incident.

Recruitment - the Group actively maintains assurance regarding the integrity and professional conduct through implementation of its policies and risk and performance frameworks and aims to apply fair and transparent recruitment policies. This includes the use of role profiles to assess candidate suitability, personality profiling, attendance at an assessment centre and direct candidate interview.

Working practices - the Working Time Regulations 1998 were put in place to safeguard the health and safety of employees. They regulate hours of work, rest periods, breaks and annual leave and we fully observe the requirements of the Working Time Regulations. However, at their individual choice, colleagues may elect to opt out of certain aspects of the regulations. Hours of work are specified in each contract, but these hours of work may be subject to change.

Living Wage - Remuneration packages across the business are compliant with the UK’s national minimum wage rates. In addition, we are an accredited employer with the Living Wage Foundation and first met this standard in June 2016. The independent Living Wage Foundation sets an hourly rate calculated according to the cost of living in the UK which is updated annually. This is a higher rate than the government’s National Living Wage. We support the Living Wage Foundation’s principle of a living wage being good for business, good for the individual and good for society and this is an important part of the Group’s values and people strategy.

Equality, Diversity and Inclusion - the Group promotes equality of opportunity which is supported by its Equality, Diversity and Inclusion Network and senior leadership team. We are committed to ensuring that no individual is discriminated against on the grounds of age, disability, gender and reassignment, marriage or civil partnership status, pregnancy and maternity, race, religion or belief, sex, or sexual orientation.

Health & Safety

It is the Group’s policy to ensure, so far as is reasonably practicable, the health, safety and welfare of its employees, suppliers, customers and others who may be affected by the Group's work activities. The Group has several policies and processes in place to identify and manage risks in relation to health and safety and ensure compliance with all relevant legislation.


As a Bank, we recognise that we have an important role to playing creating a fairer, more resilient society. This informs our approach to our products and services, but also how we work with our local communities. Through our Community Programme, we provide funding and volunteering time to a range of organisations working to improve the lives of those around them. Some of the projects we have supported include:

  • SIFA Fireside - a specialist centre in Birmingham dedicated to supporting the city’s homeless people
  • Let’s Feed Brum – an initiative to redistribute food waste to the homeless
  • Ready for Work – an initiative that supports homeless people to get back into the workplace
  • Education initiatives – ‘Life Ready’ days to talk about managing finances, budgeting and the implications of debt to teenagers
  • Careers conventions at local schools


The Group complies with all applicable laws and regulations relating to the environment. It operates a Green Charter to raise employees’ awareness of recycling and campaigns are also run to reduce various forms of waste such as food, consumables or energy.

Contact us

If you would like more information about this Supplier Code of Conduct, please contact us [email protected] . We recognise that the key to greater sustainability is in working with others.

26 March 2021