2 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting

ng Conducting our Protecting our Delivering value

message with PRIDE our people business with integrity assets and reputation to society

Being our best – 1. Delivering 2. Respecting 4. Protecting our

a message from with PRIDE our people assets and reputation
our executive chair
• Why we have Our Code • Creating a respectful work environment • Protecting our intellectual property
• How Our Code makes us unique • Acting inclusively and embracing • Securing information
equality and diversity
• Our Code and PRIDE values • Protecting our systems and assets
• How Our Code applies
• Operating safely
• Respecting privacy and data protection
• Our individual responsibilities
• Valuing health and wellbeing
• Engaging responsibly in political activity
• Additional expectations • Responsible public communications
of leaders and managers
3. Conducting our
• Making good decisions business with integrity
• Using your voice: how to Speak Up
5. Delivering
• Preventing bribery and corruption value to society
• Exchanging gifts and hospitality
• Delivering social outcomes
• Managing conflicts of interest
• Engaging with our communities
• Competing fairly
• Advancing sustainability
• Respecting international trade
• Respecting human rights
and export controls
• Treating our clients, suppliers
and partners fairly

Contents
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Whether we face an everyday

dilemma or something more
serious, as individuals or

Being
as a business, Our Code is
here to help us make good I am proud to work for
decisions and do what’s Mott MacDonald because
right. By setting out our I already feel this trust and
commitment to acting with mutual respect throughout

our best
integrity and our expectations our business. By following see or hear anything that
of all colleagues and those Our Code and delivering undermines Our Code or puts
we work with, Our Code on these expectations we our reputation at risk, have the
challenges us to work with will foster a culture that is courage to Speak Up, even if
each other, our partners, friendly and supportive, open you are not directly affected.
clients and communities and fair. This will protect and By speaking up, you give us
in a way that builds trust enhance the good name of the opportunity to be our best
Our Code brings together all and mutual respect. Mott MacDonald, support and deliver with PRIDE – for
our continued success to win the benefit of everyone we
that makes Mott MacDonald and deliver better projects, work with. All concerns raised
unique. Building on our purpose, and ensure Mott MacDonald will be considered seriously.
remains a company we
which explains why we’re here, can all be proud of. Please take time to familiarise
Our Code provides a framework yourself with Our Code, speak
We all have a responsibility about it with your colleagues
for living our PRIDE values. to uphold Our Code. If you and come back to it whenever
you need further guidance.

James Harris
Executive chair,
Mott MacDonald Group
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1 Delivering
with PRIDE
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Our Code consolidates By following Our Code, we build stronger, more

trusting relationships with our clients, communities
our commitment to doing and colleagues and increase our ability to comply
what’s right and building with country specific, federal and local laws,
and regulations. We follow local legislation and
an ethical culture throughout regulation wherever we work. However, where
Mott MacDonald. Our Code provides the higher standard, we

It sets out our standards and expectations on

the issues that matter to us; it’s a guide for making
expect that to apply. Our Code cannot cover
every situation. If in doubt, seek help – there’s
information about who to talk to on the pledge
Why we have Our Code
good choices and living our PRIDE values. page of each section.
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How our Code makes us unique

Our Code brings together our purpose,
our PRIDE values, our proposition and
our people promise.

Our purpose is to improve Our Code is about doing And our people promise
society by considering social things right. explains how we’re making
outcomes in everything the company we love.
we do, relentlessly focusing Our PRIDE values
on excellence and digital are what we stand for: Together, these provide
innovation, transforming progress, respect, integrity, a framework for how we
our clients’ businesses, our drive and excellence. achieve and sustain success
communities and employee as a responsible business.
opportunities. It sets out Our proposition
why we’re here, what makes summarises how we do what
us special to our clients and we do – opening opportunities
how we’re different from with connected thinking.
our competitors.
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Progress

Excellence
Integrity
Respect

Drive
We drive change and use We always care about the We deliver on our promises. We constantly stretch our
it to create opportunity. human and environmental We behave ethically and do not thinking to find extra value for
We aim to make a lasting impact of what we do. tolerate bribery or corruption. our clients and their end-users. We act on our belief that
positive difference for present We value all peoples and We uphold safety, security We work as one Mott MacDonald, there is always a better way.
and future generations. cultures, and promote equality, and wellbeing as a connecting all our skills to create We use our restless curiosity
We actively develop ourselves diversity and inclusion. fundamental right of all. the best outcomes. and leading-edge skills to
as individuals and professionals. We treat everyone with respect. We stay focused and persevere challenge and innovate.
to achieve our goals. We connect our people and
experience to turn opportunity
into the best outcomes for all.

Our Code and PRIDE values

Our Code and PRIDE values guide our behaviour and how we
act every day. Together they shape our culture and inform our
relationships with our clients, partners and each other. Our PRIDE
values are the platform from which we deliver social outcomes
and they underpin our unique employee-ownership model.
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How Individual responsibilities

Our Code We are all responsible for our own behaviour
and have a collective responsibility to do our
• Speak up when we identify possible
breaches of Our Code.

applies
best for each other, our clients, communities • Participate fully and honestly in any
and society. Each of us must: investigation into suspected breaches
of Our Code.
• Read and be familiar with the standards • Complete mandatory training and annually
and commitments in Our Code. certify that we have acted and will continue
• Be accountable to the standards of Our Code. to act in line with Our Code.
• Make informed decisions based on our PRIDE
It does not matter where All employees of Mott MacDonald values, using our decision-making model.
Group companies must agree
you work or what you do to uphold Our Code. Suspected
for Mott MacDonald, Our breaches will be investigated.
Code applies to everyone: If a breach has occurred it may Additional expectations
all employees, regardless
of leaders and managers
result in disciplinary action, up to
and including dismissal.
of grade or role; all agency
staff and consultants; Our choice of business partners, Leaders and managers are instrumental • Be consistent and fair when holding
whether working full-time, clients and third parties, including
joint ventures, affiliated companies,
in setting expectations and reinforcing
standards. They must:
themselves and others to account on matters
covered by Our Code.
or part-time, under a suppliers and sub-contractors, can • Act courageously to address any shortcomings
permanent or temporary affect our reputation. Therefore, we • Be positive role models for Our Code and not shy away from difficult conversations.
only want to work with those who and PRIDE values. • Encourage colleagues to seek help and advice,
contract. It also applies operate in a way that is consistent • Create a working environment in which including through the Speak Up helpline, if they
to all who work in with Our Code and PRIDE values Our Code and PRIDE values are understood are unsure what to do or are concerned that
and can meet those standards. and promoted as part of everyday practice. the standards of Our Code are not being met.
Mott MacDonald-operated • Make time to listen to and address concerns
joint ventures. If a business partner or third party raised by team members, protecting them
fails to do so, we may terminate from retaliation if they speak up or help
the relationship. with an investigation.
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Our
Making good decisions Is it legal? decision-
We trust our colleagues to make good decisions. making
However, not every decision is straightforward.
Does it comply with model
There may be instances when the right answer
Mott MacDonald policy?
is not clear, and you are unsure how to do the right
thing. When in doubt, it is important that you don’t
feel you need to make these difficult decisions on Is it consistent
your own. Taking five minutes to work through the with Our Code
questions in our decision-making model, either and PRIDE
on your own or with a manager or colleague, can values? Would I be
be helpful in guiding you to the right choice. comfortable
if this appeared
in the news or
Would this be on social media?
a good way to
operate if we did
things this way
all the time? Does it help to build
our ethical culture
and the reputation
of Mott MacDonald?

If you answer no to any of these questions,

or are unsure about your response, you
should stop and seek advice from others.
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We recognise that from time Speaking up means using your voice Speak Up helpline
to ask a question, seek advice or report The Speak Up helpline is operated by
to time behaviour falls short a concern about misconduct, malpractice an independent third party. It allows you
of expected standards. When or suspected breaches of Our Code. to report concerns and ask questions
this happens, it is important in complete confidence, by internet
Using your voice: that concerns are raised and
This includes speaking up about any
previous concern that may not have
or telephone. It is available:

how to Speak Up dealt with. They must never been suitably addressed, anywhere in
Mott MacDonald.
• 24 hours a day, seven days a week,
every day of the year
be ignored. We therefore • free of charge
promote an open, transparent Talking to your line manager will usually
be the best course of action. However, if
• from anywhere in the world.

and safe working environment this is not possible, you can speak to another Our Speak Up helpline is also available
where you are empowered to manager, a colleague from a supporting to business partners, including contractors,
function, such as legal, human resources, secondees, agency staff, consultants, suppliers
speak up and are protected or health and safety, or you can contact the and joint venture partners, and members
when doing so. Speak Up helpline. You are free to choose of the public. Anyone wishing to report a
whichever you are most comfortable with. suspected breach of Our Code can use it.

No No No
Can you speak to your Can you speak to Can you contact a relevant
line manager? another manager? supporting function? Contact the Speak
Up helpline by
Yes Yes Yes clicking here, or
search ‘Speak Up,
Mott MacDonald’
and click on our
Contact supporting functions, Ethics page.
Contact your line manager. Speak to another manager.
e.g. HR, legal and finance.
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How we respond Non-retaliation and good faith

Our Code…
We take breaches of Our Code extremely We do not tolerate any form of retaliation
seriously and respond to all concerns raised. or discrimination against those who raise
Line managers are expected to assess any concerns or those who investigate them.
concerns raised directly with them and to We expect all involved – the concerned sets out our standards
address or escalate as appropriate. individual, the person or people alleged and expectations on the
to have done wrong, or anyone else issues that matter to us;
All concerns received through the Speak Up involved in any other way – to be treated it is a guide for making
helpline are initially assessed by one of the legal fairly, objectively and with respect. good choices and living
team and where necessary will be investigated our PRIDE values
by a suitably trained and objective individual. We expect concerns to be raised in good faith
and do not tolerate knowingly false reporting. is key to how we achieve
If a breach of Our Code is found, appropriate False reporting can damage morale, harm our and sustain success as
steps will be taken to address the issue, which reputation and undermine our PRIDE values. a responsible business
may include disciplinary action, up to and
including dismissal. together with our PRIDE
values helps us all
Confidentiality and anonymity understand what doing
All concerns raised through the Speak Up things right means
helpline are treated confidentially. at Mott MacDonald

Information relating to the concern will only

be shared with those who need to know
for legitimate business purposes including
investigation, risk management and remedial
or disciplinary actions.

Concerns can be raised anonymously, unless

prohibited by local legislation.
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2 Respecting
our people
We commit to respecting
others and working safely.
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Our people promise

We’re committed to creating an
organisation where people feel valued.

Each of us will: Together we will:

• Create a nurturing • Celebrate our differences
environment where we can and treat everyone fairly
be ourselves, feel valued, and with respect.
safe and at our best. • Take ownership for our
• Apply our skills to challenging growth and find the
and worthwhile projects opportunities that are
and inspire each other to right for us.
be the best we can be. • Be generous with our
• Be part of a global family knowledge, work together
of passionate innovators, to solve problems and take
problem-solvers, doers pride in each other’s success
and thinkers. as much as our own.
• Make a difference to • See change, however big
other people’s lives and or small, as an opportunity
our planet’s future. to learn and improve.
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Creating a respectful work environment

Together, we create a nurturing environment where each of us can
be ourselves, feel valued and safe, and enabled to perform at our
best. We celebrate our differences and treat everyone fairly and with
respect, including those we interact with outside our organisation.

Bullying and harassment We treat any allegations We comply with the laws of
Bullying and harassment can of bullying and harassment the countries we work in and
take many forms including seriously and ensure we adhere to Our Code where
threatening or distressing implement our policies and that provides the higher
language or behaviour, procedures impartially, swiftly standard. We report any
physical or verbal intimidation and fairly. potentially criminal behaviour
or discrimination, and sexual to the police and/or other
harassment. These may be Safeguarding relevant authorities including
associated with an abuse We are committed to the client, where appropriate.
or misuse of power. safeguarding children,
None are acceptable. young people and adults Any inappropriate behaviour
at risk of harm. or safeguarding concerns
We value and respect each must be reported to a
other. We are committed to We have a collective safeguarding lead, via
providing a work environment responsibility to prevent [email protected],
where all can contribute, free abuse and exploitation, and to a manager or through the
from the fear of bullying or we apply appropriate measures Speak Up helpline. We seek to
harassment. All colleagues are to safeguard those in need of take swift action to support and
expected to be role models, protection, within and outside protect vulnerable people
aware of their own behaviour our organisation. We have a where concerns arise regarding
and how this may affect others. zero-tolerance approach to possible abuse or exploitation.
Anyone who observes bullying safeguarding misconduct. All concerns are investigated
or harassment must report confidentially using the
and take steps to prevent it. Speak Up process.
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Acting inclusively
and embracing
equality and diversity

Ensuring that we have a diverse workforce, We value all peoples and cultures, celebrating
whose talents are harnessed through inclusive our differences and treating each other with
cultures and behaviours, is one of the ways respect, kindness and fairness. We show
we live and breathe our purpose every day. sensitivity to cultural differences and comply
We commit to creating equitable, accessible with local employment and equality legislation.
and inclusive working environments where We recruit and develop a workforce that reflects
trust, respect and psychological safety are the diversity of the communities in which we
the norm. We do not tolerate any form of work. We are fair and open in our decisions
discrimination, including where characteristics about hiring, promotion and compensation
are protected by law, which may include: because this leads to more equitable outcomes.

• Age • Neurodiversity Everyone has a role to play in making our

• Caring • Nationality work environments more inclusive, so that
responsibilities • Parental status all colleagues feel able to be themselves and
• Caste • Race or ethnic origin perform at their best. This includes our shared
• Class/social mobility • Religion or belief responsibility for being allies and respectfully
• Colour • Sex challenging and reporting behaviour that
• Disability • Sexual orientation is not acceptable.
• Gender identity • Veteran status
• Marital status
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Operating
safely

We are committed to behaving requirements and to fulfilling We all have a personal

and operating safely. Everyone the requirements and responsibility to come to
has a right to go home without processes relevant to our work in a fit state, free from
harm to their physical or mental contracted and professional the influence of alcohol
health. If we can’t perform a roles, working to our standards or drugs – including
task safely, we won’t do it. where they are higher. prescribed and over-the-
counter medications.
Through application of safe We all have a role to play Performance and judgement
systems of work and strong in identifying, assessing must never be impaired.
leadership, supported by and mitigating risks, and
a comprehensive training speaking up and intervening All safety incidents, no matter
programme, we aim for zero if we observe or suspect how minor, must be reported
harm – part of our duty of unsafe practices. We will through our health and safety
care to all we work with. stop work when necessary portal so that action can be
We commit to complying with to prevent an unsafe taken to prevent recurrence
all local legal and regulatory situation developing. and promote learning.
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Valuing health
and wellbeing

Our goals as an organisation us; to give attention, time and

depend on each of us being energy to something worthwhile
able to thrive and achieve outside work; and to be active,
our full potential. We know because any and all forms of
that good health and wellbeing exercise are mentally as well
support a good business. as physically beneficial.
So we are committed to
creating an open and honest We promote agile working,
culture where everyone is able which enables flexibility in
to be happy, healthy and safe. managing the demands of work
and home life, while remaining
We encourage all colleagues to productive and connected.
develop a broad understanding
of wellbeing and to take Respect, inclusion, equality
ownership and responsibility and safety are all fundamental
by applying the five ways to to our wellbeing culture. Line
wellbeing: to keep learning, managers are encouraged to
which boosts self-esteem; to intervene on wellbeing issues.
connect with family, friends, All colleagues can find support
colleagues and community; through our external Employee
to take notice of and engage Assistance Programmes.
with what is going on around
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Speak Up
If you have a question about how we
conduct our business or suspect
a breach of Our Code, don’t keep it to
yourself. Speak to your line manager,
another manager or a colleague in legal,
human resources, health and safety or
other supporting function, as appropriate.

Alternatively contact the confidential

Speak Up helpline. Click here or

Our Code.
search ‘Speak Up, Mott MacDonald’.

My pledge:
19 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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3 Conducting
our business
with integrity
We commit to business practices
that are responsible, fair and
promote the highest standards
of integrity. We comply with
all legal and regulatory
requirements and respect the
customs and culture of the
countries we operate in.
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Preventing bribery
and corruption
Simply, we do not tolerate any form of bribery or corruption.
They can cause harm to Mott MacDonald, cause clients
and business partners to lose trust in us and damage the
communities in which we work.

Bribery and corruption Anyone who suspects bribery or corruption Money laundering and tax evasion
We are committed to countering all forms of is taking place must report it to a manager, We are all responsible for protecting our business
bribery and corruption. We support initiatives the legal team, or through the Speak Up against money laundering or tax evasion.
to eliminate them, and work to continually helpline.
improve our anti-bribery and corruption Money laundering is the process of hiding illegal
systems and practices. All allegations of bribery are investigated. funds or making them look as though they are
Appropriate follow-up steps are taken, with legitimate. It also covers the use of legitimate
We comply with all anti-bribery and corruption breaches reported to the police and other funds to support crime or terrorism. Criminals
laws and will never offer or accept bribes, relevant authorities when necessary. may try to hide their identity or the identities
kickbacks or other improper payments. of third parties, as well as disguise the origin
We prohibit improper payments including to Fraud of the funds they are seeking to launder.
secure permits or approvals, and small payments Any fraudulent and dishonest conduct is
to speed up a routine government process unacceptable, within our organisation or in those Tax evasion and the failure to prevent its
(often known as ‘facilitation payments’). we do business with. Fraud can take many forms, facilitation, however minor, are criminal
including false representation, failing to disclose offences. Wherever they are in the world,
We conduct due diligence to mitigate the risk information and abuse of position. It is important nobody who works for us or on our behalf
that colleagues or those working on our behalf we are all vigilant to identify and report should facilitate a third-party taxpayer to
will be exposed to bribery or corruption when fraudulent or dishonest conduct. evade tax. Suspected incidences must be
working on projects or providing services. reported to a manager, the legal or finance
team, or through the Speak Up helpline.
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Exchanging gifts
and hospitality
Exchanging gifts and hospitality
can generate goodwill
and be part of building and
strengthening business
relationships. However, we Before offering or accepting
do not offer or accept gifts any gift or hospitality, we
or hospitality that could consider if it is part of a regular
appear to create an improper pattern, or if it places an
advantage for Mott MacDonald, obligation to deliver something Any gift or hospitality offered
or improperly influence us in return. Close attention is or received must have a
or any third party. Everyone paid to the timing of any gifts business purpose and be
working for or with us must or hospitality, which must reasonable and proportionate,
use good judgement and never be offered or accepted in terms of value, nature and
ensure their actions cannot during a tender process. occasion. Gifts or hospitality
be viewed as inappropriate must not include cash or a
or constitute a bribe. Particular care is taken when cash equivalent. Care is applied
dealing with government or when offering or accepting
public officials or making any gift or hospitality that
charitable donations to ensure involves family members.
that such transactions do
not breach anti-bribery or All gifts and hospitality above
corruption laws. set limits must be discussed
with line management
and included within the
Mott MacDonald gifts
and hospitality register.

When in doubt, seek advice

from the legal team.
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Managing Organisational conflicts can

arise when our role on one

conflicts project has the potential to

unfairly benefit Mott MacDonald

of interest in another role or project.

They may compromise
our ability to give impartial
To protect the integrity of our assistance or advice, or
decision making we never provide an unfair competitive
allow an external interest advantage, compromising
to influence, or appear to our stance on corruption.
influence, our judgement.
We protect our ability to Personal and organisational
make decisions in the best conflicts are identified and
interests of Mott MacDonald resolved swiftly. They are
by avoiding all actual, potential discussed with clients and
and perceived conflicts other stakeholders where
of interest when possible
and managing them when
appropriate, and management
plans agreed. Competing we work, adhering to Our Code
where that provides the higher
sensitive information or other
anti-competitive behaviour
they are unavoidable.
All actual, potential and fairly standard. We do not engage
in anti-competitive agreements
are identified, we will cease
the communication and take
Personal conflicts can occur in perceived conflicts of or behaviour, such as dividing clear and immediate steps
many different circumstances, interest must be entered We support open and or sharing markets, price fixing, to remove ourselves.
including close relationships into our conflict of interest transparent markets where limiting production or output,
inside or outside the workplace, management tool to ensure businesses can compete bid-rigging, collusive tendering Any anti-competitive practices
affiliations with competitors or proper action is taken. fairly. This builds trust and or other cartel behaviour. must be reported to a manager,
suppliers, outside positions, provides the best value and the legal team, or through
or financial investments which When in doubt, speak with outcomes for our clients, When exchanging information the Speak Up helpline. All
may influence or appear to a manager or seek advice their customers and society. with a third party, we respect allegations of anti-competitive
influence decision making. from the legal team. confidentiality. We do not behaviour are investigated.
In our dealings, we respect exchange commercially We take appropriate follow-
competition and anti-trust laws sensitive information with up steps and inform relevant
as well as the ethical practices competitors. If unilateral authorities when appropriate.
of the jurisdictions in which disclosures of commercially
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Respecting
international trade
and export controls
We respect and abide by national and
international trade laws, including economic
sanctions, anti-boycott provisions and import
and export controls.

Many countries impose controls on the

movement of items across their borders,
including goods, software and technology.
Specific licences and approvals are required
before listed items can be exported. When our
business operations require us to export any
item, we identify if it is listed and proactively
comply with any relevant legislation.

Economic sanctions may prohibit or restrict our

Treating
ability to conduct business with governments, The support of our clients, and within their own supply sustainably and ethically and to
entities and individuals in certain countries. suppliers and partners is chains. We conduct due deliver services to our clients at

our clients,
Sanctions change frequently, and we review essential to the long-term diligence checks on our clients, the optimum value and required
and adjust our project work and business success, resilience and suppliers and partners. We quality. We endeavour to treat
relationships accordingly. We understand who
suppliers
sustainability of our business. communicate our expectations, our supply chain fairly and
we are doing business with and conduct proper Mutual respect and good monitor performance and consistently, and to pay them in
due diligence checks on business partners, governance underpin all our address any issues. This line with contractual obligations.
clients, suppliers and other third parties.
These checks include screening for breaches
and partners business relationships. includes withdrawing from
contracts if our standards We aim to always provide
of sanctions and other trade controls.
fairly We seek to work only with
those who share our values
are not being met. open and honest feedback
on performance, and to be
Any questions or concerns about international and operate in a manner We work innovatively with open to feedback on our own
trade should be reported to a manager, the consistent with Our Code suppliers and partners to performance from others.
legal team, or through the Speak Up helpline. – in their dealings with us procure goods and services
24 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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Speak Up
If you have a question about how we
conduct our business or suspect
a breach of Our Code, don’t keep it to
yourself. Speak to your line manager,
another manager or a colleague in legal,
human resources, health and safety or
other supporting function, as appropriate.

Alternatively contact the confidential

Speak Up helpline. Click here or
search ‘Speak Up, Mott MacDonald’.

Our Code.
My pledge:
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4 Protecting
our assets
and reputation
We commit to protecting our
brand, assets and reputation.
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message with PRIDE our people business with integrity assets and reputation to society

Protecting our intellectual property

Intellectual property is the We all have a responsibility to infringing, the intellectual
product of our technical manage and use our intellectual property rights of others.
excellence and can property appropriately, protect Failure to do so risks damage
differentiate us from our it from unauthorised use and to us and our reputation.
competitors. When providing ensure rights are not granted
our services we generate and to third parties without If in doubt, speak with a
provide valuable intellectual suitable terms in place. manager or seek advice
property, over which we It is equally important that from the legal team.
assert our ownership rights. we respect, and avoid

Securing information
Information security is any type of information that is Any organisation or individual
essential in every part of commercially, reputationally we intend to share
our business. It helps build or legally sensitive. confidential, sensitive
confidence and trust with information with must sign
our clients, business partners Information is only shared a confidentiality agreement
and colleagues. Information if there is a valid business in advance.
is core to our delivery of requirement and a legitimate
insightful and innovative need to know. Any information security
projects, and to our own incident must be reported
operations. Our services To protect our own data immediately by contacting
and reputation depend and information, as well as the IT Service Desk (either
on maintaining the that of our clients, business by calling or raising an
confidentiality, integrity and partners and colleagues, incident via My IT).
availability of information. we have controls in place
governing how information General questions or
We undertake to protect should be accessed, stored, concerns about information
information and never transferred and disposed of. security can also be raised
use, offer or accept it This applies to information through the Speak Up helpline.
inappropriately. This includes held electronically or on paper.
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Protecting our Respecting privacy

systems and assets and data protection
To enable us to do our jobs, we are provided In an increasingly digital and connected world,
with access to systems and assets. These we are determined to maintain the trust and
systems and assets must be used only confidence of every individual whose personal
for their intended purposes, with care taken information we collect, access, use, analyse
not to compromise security or expose or store.
Mott MacDonald to any type of risk.
We protect the confidentiality and integrity
While personal use of some assets is permitted, of personal information, are open and
it should be appropriate and within reason, transparent about how we process it, and only
as allowed by local policies and procedures. ever use it for legitimate business purposes.

In addition, we must never expose our systems We comply with privacy and data protection
or assets to unauthorised persons, cause laws and regulatory guidance, and respect
damage to them or use them unsafely. the associated rights of our people, our
clients, and members of the communities
We use appropriate controls when sharing in which we work. Where it is unclear whether
confidential information or using portable we are processing personal information or
storage solutions. We never use unauthorised whether it is being processed in accordance
or unlicensed software, nor make unauthorised with the law and our policies, procedures,
changes to our systems or assets. and values, seek advice from line management,
local privacy practitioners, or the legal team.

Any suspected personal data breaches must

be reported immediately to a manager and the
IT Service Desk (either by calling or raising an
incident via My IT), or the Speak Up helpline.
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Responsible public
communications
Engaging
responsibly Any public external communication must have

in political the prior approval of our Group press office

and relevant regional management and

activity
marketing leads.

This includes all forms of public communication,

from talking with or responding to enquiries
We respect each individual’s Any lobbying of public from the media to publishing content or speaking
rights to engage in lawful officials or government at conferences.
political activity. However, representatives undertaken
as we work closely with on behalf of Mott MacDonald We always make sure we have permission from
government departments, must be approved by the our clients to share any information externally
agencies and regulators executive board. Anyone about work we are doing for them. We instruct
it is important we keep any we authorise to undertake our supply chain to obtain authorisation from
personal political activities lobbying activity on our us before publishing or speaking to the media
separate from our role behalf must comply with about any work they are undertaking on
at Mott MacDonald. local lobbyist registration our behalf.
and transparency laws.
Anyone undertaking political Public communication plays an important role When using social media in any capacity, we
activity must do so in their own When we take interim roles in raising awareness of the work we do with recognise that what we say online can affect
time and at their own expense. or secondments in public and on behalf of our clients. Positive articles, Mott MacDonald’s reputation. We therefore
Such activity must never be bodies or government social media activity, thought leadership, apply the principles of respect, inclusivity and
attributed to Mott MacDonald organisations, we always industry collaboration and participation in consideration to all our online communications,
and must be carried out in a take measures to avoid any events can be some of the most effective ways always present ourselves professionally,
way that will not conflict with potential conflicts of interest. to publicise Mott MacDonald’s contributions and make it clear that any personal views
professional responsibilities to and purpose. expressed are not those of Mott MacDonald.
Mott MacDonald and our clients.
We expect everyone who communicates
publicly on behalf of Mott MacDonald to adhere
to our PRIDE values, policies and guidance and
observe our legal and professional obligations.
29 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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Speak Up
If you have a question about how we
conduct our business or suspect a
breach of Our Code, don’t keep it to
yourself. Speak to your line manager,

Our Code.
another manager or a colleague in legal,
human resources, health and safety or
other supporting function, as appropriate.

Alternatively contact the confidential

Speak Up helpline. Click here or

My pledge:
search ‘Speak Up, Mott MacDonald’.
30 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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5 Delivering
value to
society
We commit to improving
the communities and
environments in which
we operate.
31 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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Delivering
social
outcomes
Positive and inclusive social knowledge, training, processes
outcomes are at the heart and resources to achieve this.
of our purpose, in which we We work with colleagues across
commit to improve society We support the increasing disciplines to holistically embed
and deliver benefits for the emphasis our clients place social inclusion opportunities
communities in which we work. on social value, social into other global agendas.
Our ambition extends beyond responsibility, engagement
avoiding adverse impacts. and equality. Using our social We partner with clients to
We work proactively and inclusion expertise, we advise, debate, provoke thought on
seize opportunities to deliver support and enable our clients and advance a social outcomes-
transformational change. to achieve better and more based approach in all we do.
inclusive social outcomes
for their communities.

We consider the social legacy

of projects by focusing
on long-term benefits and
identifying opportunities to
enhance accessibility, inclusion,
empowerment, resilience
and wellbeing. We expect
project teams to use available

© Divesh Mistry Photography

 32 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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Engaging
with our
communities

We commit to operating responsibly, respecting

local cultures, traditions and customs, and
earning trust in our communities.

We support causes aligned with our PRIDE

values that contribute to making society
more inclusive, sustainable and prosperous.
We partner with like-minded organisations,
including those who are not-for-profit.

By volunteering our skills, knowledge and

passions we help to improve the prospects
and wellbeing of local people, particularly
those who face barriers in society, by
supporting them to reach their potential.
 33 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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Advancing
sustainability

We commit to being a leading We talk openly to clients and

global partner in advancing colleagues about our climate
sustainability, creating change agenda. We are
positive social, environmental reducing our own carbon
and economic outcomes emissions to net-zero by
that provide lasting value 2040 or sooner and will adapt
for all. To achieve this, we as needed to remain resilient
promote company-wide to the physical impacts of
alignment with the Sustainable climate change. We are
Development Goals, are open committed to working with
and transparent through our our clients, partners and
Environmental, Social and suppliers to reduce their
Governance (ESG) reporting carbon emissions to net-
and are members of the United zero and develop resilience
Nations’ Global Compact and to climate change risk.
the Carbon Disclosure Project.
We equip our people with
We recognise both the climate the information they need
emergency and the biodiversity to make informed decisions,
emergency. We use the world’s encouraging them to address
resources responsibly, optimise sustainability at the outset of
the use of materials for the life each project, when it can be
of the assets and infrastructure addressed at little or no extra
we design and build, and cost. We view sustainability
minimise or eliminate waste, as a framework for initiating
including re-purposing materials change in our operations
at the decommissioning stage. and offices, as well as the
We avoid pollution and projects we deliver.
respect and protect wildlife.
34 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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We are committed to respecting the human We never knowingly cause or contribute to any
rights of everyone who works for us, with us, activity or relationship that violates human rights
or who lives in the communities we operate and will address adverse human rights impacts

Respecting in. We reject modern slavery in all its forms,

including servitude, forced or compulsory
if they occur. We are vigilant in our communities
and will report suspected human rights abuses.

human rights labour and human trafficking. This includes

providing a fair living wage for all our staff. We conduct due diligence on our clients, partners,
contractors and suppliers to ensure they follow
Our approach is informed by the United the same approach.
Nations Global Compact and the Guiding
Principles on Business and Human Rights.
35 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
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Speak Up
If you have a question about how we
conduct our business or suspect a
breach of Our Code, don’t keep it to
yourself. Speak to your line manager,

Our Code.
another manager or a colleague in legal,
human resources, health and safety or
other supporting function, as appropriate.

Alternatively contact the confidential

Speak Up helpline. Click here or

My pledge:
search ‘Speak Up, Mott MacDonald’.
36 I Mott MacDonald I Our Code Delivering with PRIDE Contents Executive chair’s Delivering Respecting Conducting our Protecting our Delivering value
message with PRIDE our people business with integrity assets and reputation to society

To develop Our Code we ran a number of listening sessions

with colleagues globally that helped shape our thinking and
are reflected in Our Code. Thank you to all those who either
assisted with the listening sessions or otherwise contributed
to the development of Our Code, some of whom are pictured.
mottmac.com

Our Code sets out our Our Code is key to how we Together Our Code and
standards and expectations achieve and sustain success PRIDE values help us all
on the issues that matter as a responsible business. understand what doing
to us; it is a guide for making things right means at
good choices and living our Mott MacDonald.
PRIDE values.

October 2022 – v2