Code of Conduct - Jaguar Land Rover

Code of Conduct
Statement from the
chief executive officer
T
he Jaguar Land Rover business is founded on two iconic
British brands known the world over. As we continue
our efforts to unlock the potential of these great brands
and build a sustainable business, we need to make every
effort to safeguard them against any potential reputational harm.
This Code of Conduct highlights some of the core values which
help define us as a responsible business. The Jaguar Land Rover
Code of Conduct reflects those company policies which we all
must follow in order to maintain our reputation, which is critical to
the success of our business.
Although this code sets out in writing what we should and
shouldn’t do as representatives of Jaguar Land Rover, it is important
that we follow the spirit as well as the letter of this code. The
overriding message is that when interacting with other employees,
customers, suppliers, dealers, government agencies or anyone else
outside of our business, we should act with integrity and behave in
a way which protects and where possible, enhances our reputation.
If in doubt about how you should act in a particular situation,
discuss the issue with your manager and consider whether you
would be proud to have your actions reported on by the media.
By complying with applicable laws, company policies and this
code, we can ensure that we are conducting ourselves consistent
with the highest ethical standards, and we can be assured that we
will continue to earn the trust of those around us – both within
and outside Jaguar Land Rover.
We all want to be part of a successful business. Jaguar Land Rover
constantly challenges itself to produce the most desirable and
most exciting vehicles in the world. We are all committed
to producing those vehicles to the highest possible standards.
It is just as important that we have that same focus when dealing
with each other, our customers, suppliers, dealers, government
agencies and other stakeholders, so that our reputation of
having the highest standards of conduct in the motor industry
is not tarnished.
Please carefully review this code of conduct and diligently apply
its contents as you go about your daily responsibilities. By following
this code, and working to the principles which it contains, we can
justifiably continue to be proud of our company and continue to
demonstrate our commitment to conducting ourselves with the
very highest level of integrity. Let’s be the best we can be.
Ralf Speth
CEO Jaguar Land Rover
03
This code is a summary of some of the basic Jaguar Land
Rover (JLR) policies and legal requirements that affect
our business.
The code translates our business values into actions. It
will help you recognise when a potential ethical or legal
issue exists.
This code is based on the company policies adopted
by our board of directors and you are encouraged to
review the relevant policy in its entirety if you want more
information on any topic contained in this code.
Neither this code nor the policies adopted by JLR is,
however, an exhaustive list of the issues which we may
encounter whilst going about our daily business. Our
operations outside of the UK are subject to local laws
and regulations and cultural issues. If in doubt about how
to act in response to a particular issue then seek advice.
Compliance with local law will always take priority over
any conflicting JLR policy.
JLR is committed to conducting business fairly and
honestly. This commitment to integrity requires each of
us to act ethically and to ‘do the right thing’. We are all
expected to act in a manner that protects and enhances
the company’s image.
If we become aware of any actions which may not be
in line with the company’s values then we have a duty to
let the right people know so that the situation can be
properly investigated.
The integrity of the JLR business is key to our success.
Anyone who does not follow this code or applicable
laws acts against the company’s best interests and may
be subject to disciplinary action up to and including
termination, as well as potential criminal penalties.
Every person working within JLR should read and
understand this code and apply its contents. It should be
a useful reference tool for those occasions where there
is any doubt how to act in response to an issue.
Contents
Living our values 4
our customers & communities 9
conflict of interests, gifts & entertainment 10
public & political interaction
12
transactions involving public bodies
13
working with suppliers 14
TRADING INTERNATIONALLY 16
use of company assets 18
accurate records & financial integrity 21
protecting our brands 23
abiding by this code 24
JLR CODE OF CONDUCT
What this code means to you
05
JLR CODE OF CONDUCT
Living our Values
Responsibility
We all have a responsibility to maintain the image of
JLR. We must be passionate about our products, strive
for perfection in the work we do and act with integrity
at all times.
We are committed to compliance with all applicable
laws and regulations which relate to the production,
marketing and sale of JLR vehicles.
As well as complying with the law it is essential that
each person working within JLR (including hourly and
salaried employees, agency workers, consultants and
other representatives) is aware of and understands this
code. Each manager and team leader within JLR has a
duty to ensure that all persons reporting to them are
aware of the code and understand the importance of
following the principles which it sets out.
In addition, we must all work to create an
environment of openness and communication. It
is imperative that those acting on our behalf feel
able to ask questions, to seek guidance and to
report potential violations of this code or the law
without fear or reprisal or recrimination. Each
manager and team leader has a duty to ensure such
an environment exists.
Each area of our business should identify its own
compliance priorities and design and implement
effective processes to ensure compliance with those
particular areas of the code and law which apply most
frequently to their daily work. Don’t assume someone
else will be monitoring compliance and developing
local processes – each of us should be aware of what is
required of us. If in doubt speak to your manager.
If you come across an issue which you believe is not
covered by this code but should be, please report it: it
may result in an important change to company policy
and this code of conduct.
Each year we will be asking those that work for
JLR to confirm they have reviewed this code and are
not aware of any violations of this code or the law.
Managers and team leaders should ensure that all
new employees and those acting for JLR are given a
copy of (or access to) the code and certify that they
have read and understood it, and will abide by its
contents and the law.
Reporting a problem
Although we have internal compliance, control and
audit functions to help identify violations of company
policy and the law, it is up to each one of us to ensure
we are acting with integrity.
If you become aware of a known or suspected
violation of company policy or the law then you
should report it promptly.
Reports can be made via a number of routes. You
can make reports to your manager, the JLR compliance
office, human resources, internal control or business
protection functions, via the confidential helpline or
the incident reporting form on HR Online. Use the
route which you feel most comfortable with.
The company is committed to ensuring that
there will be no reprisals against individuals who, in
good faith, file reports – so please feel at ease to
report suspected violations of this code of the law
even if you are not 100% certain that such a violation
has occurred.
All reports will be handled as confidentially as
possible, whilst still enabling a thorough investigation
to be carried out.
You may request an update to any report you make
and, wherever possible, to be told the outcome of
your report.
06
Working Together
JLR’s greatest asset is the diverse group of committed
men and women who work for the company.
Our employees have the right to expect to work
in a safe environment, with good working conditions
and without the fear of harassment.
We recognise and respect each employee’s right to
decide whether they wish to join trade unions and
we are dedicated to keeping employees informed of
what is happening within the JLR business.
We expect human rights to be respected and we
will not tolerate the use of child labour or forced
labour in our worldwide operations or by our
business partners.
Opportunity for all
JLR is committed to equal opportunity for all
employees, and to fostering diversity in its work
force.
Our hiring policies and practices require that there
be no discrimination because of race, colour, religion,
age, gender, sexual orientation, gender identity,
national origin, disability, or veteran status, and other
factors that may be covered by local law.
Each of us is expected to follow these principles in
the way we work with one another.
JLR recognises that diversity in our work force
is a valuable asset, and we strive to provide an
inclusive work environment in which different
ideas, perspectives, and beliefs are considered and
respected.
Harassment
We all have the right to do our work without being
subject to harassment and abuse. Harassment can
include language or conduct that may be derogatory,
intimidating or offensive to others.
Don’t make jokes, use language, or participate
in activities that may be offensive to others.
Discourage others from engaging in such behaviour
and report them if they do.
As a precaution, always think about how
something could be perceived by others.
We will not tolerate any violence or threats of
violence in our places of work.
Working safely
JLR’s most valuable asset is its people. We are
committed to their safety and well being.
JLR is committed to ensuring full compliance with
all applicable health and safety laws and regulations
and, where appropriate, in implementing local
standards which go further than the law requires.
Each of us must take personal responsibility for
the protection of health and safety while at work
and be proactive and co-operative in ensuring we
maintain a safe working environment.
If at anytime you become aware of a possible
workplace safety issue, please report it immediately.
Substance abuse
Substance abuse poses a threat to all of us in
virtually every aspect of our lives, including the
workplace.
For the protection of all, it is imperative that the
workplace be free from substance abuse, including
use or possession of illegal or illicit drugs, and
alcohol abuse.
You may not use, possess, manufacture, distribute,
dispense, transport, promote, or sell illegal or illicit
drugs or drug paraphernalia while on company
business or on company premises.
You are prohibited from being at work or on
company business while under the influence of, or
impaired by, alcohol or illegal or illicit drugs.
JLR encourages anyone having substance abuse
problems to seek appropriate assistance.
09
JLR CODE OF CONDUCT
Our Customers and Communities
Building the best
We are very proud of our products. We want JLR
to be recognised as creating some of the most
exciting, technologically innovative and luxurious
performance vehicles desired the world over.
Our customers are why we exist and their
satisfaction is essential to our success. Our products
must therefore be of the highest quality and safety.
We have quality programs and initiatives in place
throughout our business which create and apply
our own high quality standards and each of us has
a duty to participate in those initiatives. We should
choose and monitor the quality of our suppliers
to ensure they are working with us to strive for
best-in-class quality.
It is critical that JLR builds safe products. Our
products should be designed not only to meet or
exceed applicable laws and regulations, but also to
advance the state-of-the-art in safety whenever
practicable.
If at anytime you become aware of a safety
concern with any of our products, please report it
immediately.
Reducing environmental impact
It is JLR’s policy that its operations, products, and
services should be undertaken in a manner that
responsibly protects health and the environment.
It is clear that the strong, profitable companies of
the future will be the ones that strive for sustainable
use of environmental resources.
JLR is focused on many initiatives that will reduce
our impact on the environment, such as improving
fuel economy, reducing vehicle and plant emissions,
reducing water consumption, conserving energy,
recycling and reusing those materials that are
non-renewable, and eliminating the use and creation
of toxic materials.
Each of us must play our part in reducing the
impact of the business on the environment. For
example, by appropriately turning off electronic
equipment at the end of a day or recycling our waste.
Our employees are our ambassadors and can
enhance JLR’s reputation by demonstrating a
responsible attitude to the environment to those
outside the company.
Our communications
JLR is focused on delivering great results for our
brands, in a way which sets the industry standards
for responsible marketing.
All our advertising, marketing materials and
promotions must comply with all internal policy,
applicable laws and regulations.
JLR advertising standards include policies to ensure
that adverts:
 are not misleading;
 do not make speed or acceleration the predominant message;
 encourage safe driving;
 are fair and non-disparaging of
competitor products.
Our global neighbours
We should all aim to be good neighbours and look at
ways of contributing to those local communities of
which we are part.
JLR aims to make a positive contribution to the
economic, social and environmental sustainability of
all areas of the world in which we operate.
11
Conflicts of interest
Each of us is expected to act in a way that
promotes JLR’s best interests. Personal
relationships with suppliers, dealers, and
customers must not affect your ability to act
in a manner that is best for the company.
Those relationships must not harm the company’s
reputation by creating even the appearance
of impropriety.
One good test is to ask yourself how others
might view your actions if they were disclosed to
JLR’s management, or reported in the media.
You should not take a personal gain or benefit
for yourself or your family while conducting
company business. For example:

do not engage with a supplier, customer or
competitor in which you or a family member is an
employee or has a financial interest;

do not use any non-public information or
property which you come across whilst working
for JLR for your personal advantage or to enable
others to profit from it. For example you must
not, and must not advise or encourage others to,
buy or sell shares in any company if you learn of
confidential information which may be viewed as
influencing whether or not such buying or selling
takes place. This is known as “insider trading”
and in many countries is a criminal offence. If in
doubt about whether information you have come
across whilst working for JLR is inside information
or “price sensitive” then speak to the JLR legal
department;

do not give preferential treatment to any
supplier, customer or competitor and avoid any
situation where preferential treatment may be
inferred by others;

you may not have any financial or
investment interest in any customer, supplier or
competitor of JLR, save that you may hold up to
1% of any class of publicly traded securities in
such businesses;

you must notify your human resources
representative where your spouse or partner,
your siblings or your children have any financial
or investment interest in any customer, supplier
or competitor of JLR or hold greater than 1% of
any class of publicly traded securities in such
businesses.
Employees must not engage in any activity
which is in competition with the business of
JLR nor work for or provide consultancy to any
customer, supplier or competitor of JLR without
the prior written approval of the relevant human
resources committee.
In addition, managers at LL5 level or above must
obtain the prior written approval of the relevant
human resources committee before accepting any
position as director, officer or consultant of any
non-profit or charitable organisation or any entity
mainly funded by public monies.
Gifts and favours
Accepting gifts or favours from a business
contact, such as a supplier or dealer, can cloud
your judgment when making decisions for the
company, or give the appearance that the supplier
or dealer is “buying” favourable treatment.
Only consider accepting a gift that is freely
offered if it is of nominal value, involves a
normal sales promotion and there is a legitimate
business purpose.
Never accept gifts of packaged alcohol, cash,
gift vouchers, loans, discounts (unless generally
available to all employees) or tickets to events
where the supplier is not in attendance. Politely
decline any inappropriate gift.
Please consult the relevant company policy
before accepting any gift or favour. In addition,
your local HR contact can provide further
details of what is an acceptable gift and what is
considered “nominal value”.
Similarly, giving gifts can create the appearance
of impropriety and/or preferential treatment.
Be sure that any gifts or favours provided on
behalf of JLR are part of a company-approved
programme, are of limited value and involve
normal sales promotion.
Entertainment
Socialising with suppliers, dealers, and other
business contacts can be helpful in cultivating
a good working relationship, but there are
limitations on what types of entertainment
and social events are acceptable.
You must always remember to act in a way
that promotes JLR’s best interests and that
protects the company’s reputation.
Social activities with business associates
must be appropriate and limited. You should
only accept invitations that are businessrelated and freely offered. You should never
accept an invitation that would create an
appearance of impropriety or impartiality.
The relevant company policy contains
restrictions on the number and type of
entertainment and events you may accept
or attend and you should refer to that
policy before accepting any invitations of
entertainment or to social events.
JLR CODE OF CONDUCT
Conflicts of Interest, Gifts & Entertainment
13
JLR CODE OF CONDUCT
Public & Political Interaction
Public Relations
JLR interacts with many individuals and
organisations outside our normal trading
partners. For example, we routinely enter
into dialogues with regulators, legislators and
government bodies as well as non-government
organisations, public interest groups, political
figures, journalists and
industry associations.
In order to ensure a consistent and accurate
message is given about our brands, (including
our financial performance), no person working
for JLR should contact or enter into discussions
or communications with such persons or
organisations without the express consent of
the JLR public relations or marketing teams.
In addition, any correspondence received
from such individuals or organisations should be
passed to your manager who should then liaise
with the JLR public relations team and/or legal
department, as appropriate. Any legal enquiries
must be forwarded to the legal department
without delay.
Charitable donations
JLR and those that work for it are involved in
many charitable activities across the globe.
It’s our strong belief that we should all play an
active role in our communities, both local and
worldwide.
Given the number of charities and the need
to assess the impact of any donations and
potential tax consequences, JLR can only make
contributions to a limited number of charitable
causes which have been formally approved.
As a result, no one is authorised to make
any charitable contributions on behalf of JLR
without the necessary approval.
Political involvement and contributions
Government sales
JLR’s preferred approach is to use its dealers or
its own personnel when selling vehicles and parts
directly to governments or government agencies.
However, it is sometimes necessary to use
outside sales agents for these transactions.
Regardless of who is arranging the sale, you
must follow the procedures outlined in the
company’s policy on government sales. Amongst
other things the integrity of the agent must
be investigated and the approval of senior
management is required.
In addition to the sale of vehicles and parts,
from time to time, JLR enters into other types
of contracts with governments or government
agencies. These include contracts for research,
development, joint projects, or joint ventures.
If you are planning to enter into a contract with a
government on behalf of the company, be aware
that many countries have specific requirements
and be sure to involve the legal department.
JLR encourages you to participate as an
individual citizen in political and government
affairs. JLR respects your right to use your own
time and resources to support the political
activities of your choice.
JLR itself operates under legal limitations on
its ability to engage in political activities, and
even where there are no legal restrictions, the
company does not typically make contributions
to political candidates or political parties or
permit campaigning on its property by political
candidates (including those who work for JLR)
or persons working on their behalf.
Anti-bribery
JLR has a long-standing policy not to engage in
any act that could possibly be construed as
giving or receiving a bribe (or “kick-back” or
“facilitating payment”). This is especially true
when dealing with government officials. Not
only is it against JLR policy, but it is also against
the law. Most countries have laws that prohibit
bribing local or foreign officials. This is true even
in countries where it may seem that payments to
government officials are considered a normal part
of doing business.
Even in situations where agents are engaged
to sell JLR’s products, the company must take
measures to guard against using agents that give
bribes. In some instances JLR can be held liable
for the actions of the agents it hires.
Never give anything of value to a government
official (including political parties, royalty,
employees of public bodies) in order to obtain or
retain business, or to gain preferential treatment.
This includes, for example, offering or promising
to give gifts, entertainment, travel, or special
purchase terms on vehicles, regardless of whether
something is actually given. An offer or a promise
in itself can be considered to be a bribe.
Do not discuss or offer employment to
anyone who is currently working in a government
position that has any business with JLR or who
has authority over any business with JLR. If the
person has already left government employment
then there may still be restrictions on employing
them. Consult the legal department for guidance.
JLR CODE OF CONDUCT
Transactions involving public bodies
15
Competition laws
It is of paramount importance that JLR
complies with all applicable laws in the
countries in which it does business. This
includes compliance with competition, or
anti-trust, laws.
These laws, which exist in nearly all of the
countries in which we do business, are intended
to promote vigorous, open and fair competition.
Fair competition is vital to JLR’s success.
Although JLR must compete vigorously and
aggressively to maintain its brand image and
market share, it must do so fairly and without
any anti-competitive understandings or
agreements with its competitors. We must
deal honestly with our dealers, customers,
suppliers and employees and not misrepresent
facts, or engage in unethical business practices
to gain an advantage.
Violations of competition laws, such as
agreements among competitors to fix prices
or share markets, are prosecuted as serious
crimes. Employees and others acting on
JLR’s behalf who participate in such activities
are subject to large fines and imprisonment
in certain jurisdictions. In addition, JLR and
the Tata Group could be obligated to pay
very large fines and damages as a result of
anti-competitive practices in addition to the
significant reputational impacts that can occur.
Competitors
Those working for JLR must ensure they
understand and comply with all competition
laws relevant to their market. By way of
example, some of the core requirements of
competition law are as follows:
JLR CODE OF CONDUCT
Working with suppliers, customers & competitors

do not enter into discussions or
agreements with competitors which relate to
cost or pricing information (including sales
incentives, rebates, tender responses, profit
margins, costs and discounts, credit terms and
estimated market volumes);
Customers and dealers

do not discuss or enter into agreements
which have the effect of limiting production or
supply or which divide customers or territories
or to boycott any customer;

do not discuss or enter into joint
venture, collaboration, joint research or other
joint activities with a competitor unless you
have obtained the prior approval of the legal
department.
Trade associations and professional societies
perform necessary and legitimate functions.
However, you must not use them for contacts
or communications with competitors which
involve discussions about price or other
competitively sensitive matters. Trade
associations should not be used to agree a
”common approach” to a customer or to
devise an “industry understanding” to issues
such as pricing, discounts or promotions.
In any situation where you believe a
competitor raises an issue which may be
anti-competitive then politely object, stop
the conversation and report it to your manager.
Managers should inform the legal department
so that JLR can take any appropriate steps to
disassociate itself from any anti-competitive
behaviour.
JLR is committed to complying with
competition laws that apply to dealers,
customers and other independent businesses
that deal in JLR vehicles and parts. This
means that these businesses have the
right to determine their own policies, and
practices, and to select their own suppliers
and customers without any restriction by JLR.
Examples of actions which must not be taken
without legal department approval include:

do not appoint or terminate a dealer
or supplier at the urging of other dealers or
suppliers;

do not restrict a dealer’s ability to set its
own retail prices;

do not ask a supplier to buy our
products in order to become or continue to be
a supplier to JLR;

do not restrict resale by dealers of other
customers or limit their ability to sell whenever,
wherever or to whomever they choose;

do not propose sales at unprofitable or
marginally profitable prices or at prices which are
lower in some geographic areas than others;

do not require a customer to buy all or
a specified portion of its needs from JLR, or
prohibit a customer from buying from another
company;

do not charge different prices for
identical goods or offer different levels of
merchandising or promotional assistance to
dealers or other customers;

within the EU do not take any measures
which make it more difficult to export or
import goods from one country within the EU
to another within the EU.
16
16
JLR CODE OF CONDUCT
Trading Internationally
Trade across borders
In all countries in which JLR does business, there is
extensive government regulation of the importation
and exportation of goods and services across their
respective boundaries.
These international trade laws and regulations
cover: revenue collection, including import duties,
taxes, transfer pricing, and value-added taxes (VAT);
restrictions and conditions on what goods may be
imported or exported; and commercial activity with
certain persons, entities, and countries.
Failure to comply with the applicable laws and
regulations in this area exposes JLR, and in some
instances the individuals involved, to severe civil or
even criminal penalties, and also damages our brand.
Anyone involved in the import or export of goods
across borders must comply with all applicable laws and
regulations, maintain full records of import and export
transactions including transportation documentation
and customs documentation.
Export controls and trade sanctions
Various countries worldwide, as well as the United
Nations and the European Union and their member
states, have regulations that restrict exports and
transactions with certain countries, entities, and
individuals.
These trade restrictions limit or prohibit transactions
with certain designated individuals and entities, such
as terrorist groups and drug traffickers, as well as with
certain sanctioned countries, for example North Korea.
There are also specific restrictions which apply to US
citizens, so ensure you timely review any potential issue
with the JLR legal office.
It is JLR’s policy to comply with all applicable export
laws and regulations.
If your role involves you selling goods outside of the
United Kingdom then you should ensure that you are
aware of any export restrictions which may prohibit
sales to your customer or your personal involvement
in the transactions. If in doubt speak to the JLR Export
Controls Manager.
Money laundering
Money laundering is the use of transactions by
criminals, terrorists, or others to conceal the source of
funds which have been obtained by criminal activities.
Money laundering typically involves the use of a
number of transactions to pass funds through third
party bank accounts and, for example, the purchase of
a JLR product may be one of those transactions.
Where JLR receives monies direct from customers
then we should ensure we have determined the
identity of the customer. If there is any suspicion that
a transaction may involve illegal funds (e.g. the use of
large sums of cash, money orders or traveller’s cheques)
then you must seek guidance from the JLR compliance
or legal functions.
Use of our physical assets
Each of us is responsible for protecting the assets
of JLR and ensuring that they are used for business
purposes.
Resources such as computers (including internet
and email), telephones, photocopiers and similar
technologies are provided to enable you to
perform your work in support of the JLR business.
All electronic data stored on JLR computers or
similar assets are the property of JLR. You should
have no expectations of privacy when using JLR
computers or other JLR resources.
Ensure that you do not give your password or
security information to anyone else and ensure
that appropriate safeguards have been put in
place before allowing a third party access to JLR’s
IT system.
You must not access, reproduce, display,
distribute or store any materials that are sexually
explicit, obscene, defamatory, harassing, illegal,
discriminatory or otherwise inappropriate or
which may be offensive to others. You must
not download software not distributed by JLR’s
IT function.
JLR has the right to monitor or access
documents on its systems at any time, within the
limits of existing laws and agreements. In some
countries, local laws may give personnel limited
privacy rights for personal data.
Protecting our physical assets
In addition, each of us should be vigilant in
identifying and reporting any theft, misuse or
improper use of JLR assets. If you suspect any
asset is not being used for business purposes or
you believe you have experienced or witnessed a
theft or damage to assets then report it straight
away to JLR’s company protection function.
Company vehicles
JLR CODE OF CONDUCT
Use of company assets & protecting data
Whether through the company’s vehicle lease
programme or otherwise, many employees and
other permitted users will be driving
company-owned vehicles. It is imperative that
these vehicles are driven carefully and safely at all
times, and that all traffic laws are obeyed. Vehicle
users are required to have a valid driving licence
and must wear seatbelts at all times, and must
Keeping things secret
ensure all passengers do as well. Use of vehicles
while under the influence of, or impaired by,
alcohol or drugs is strictly forbidden and may
result in disciplinary procedures, up to and
including dismissal and possible criminal charges.
Privacy
Each of us, our customers, suppliers, dealers
and others that interact with JLR has legitimate
expectations that JLR will handle their personal
information responsibly.
We must comply with all applicable data
protection and privacy laws and ensure that
any personal data is obtained properly, kept
securely and is used only for those business
purposes for which the data was obtained.
There are rules on sending personal data
between certain countries and you must be aware
of any restrictions applicable to your activities.
The JLR legal function can provide guidance.
In addition, ensure that appropriate security
measures are taken when sending personal
data outside of JLR and ensure JLR assets
containing personal data (e.g. briefcases, laptops)
are not left unattended when you are away from
JLR’s sites or your home.
Any third parties who gather personal data on
our behalf must also be made aware of the JLR
policy and agree to abide by it.
Information and records management
There are a number of laws and regulations which
require JLR to retain certain information and
records for defined periods of time.
For example, records relating to pending
litigation or official investigations must not
be destroyed and, in fact, the destruction or
falsification of records in such circumstances
may constitute a criminal offence with serious
consequences for JLR and the employee
concerned.
The company has developed additional policies
to ensure that business records are properly
managed. You must be aware of the contents of
the JLR Information and Records Management
Policy and you must comply with its contents.
Given the highly competitive industry we are
in, certain JLR information is obviously secret or
confidential in nature.
Confidential information may include drawings,
designs of vehicles and parts, trade secrets,
business plans or outlooks, financial data, price
and customer details, new products, agreements
with suppliers, internal communications and
information relating to legal proceedings or
disputes.
You must not disclose JLR’s confidential
information outside of the company except on a
need to know basis in order to perform your
duties on behalf of JLR.
If you leave JLR, then you must be aware
that the restrictions on disclosing confidential
information continue to apply while the
information is not generally available to the public.
Most of us will as part of our jobs also receive
the confidential information of other companies,
for example, suppliers and customers. You must
ensure that you do not disclose that information
to anyone else without the consent of the owner
of that information.
Careful communications
You are responsible for ensuring that your
communications are clear, correct and appropriate.
Responsible and appropriate communications
are essential not only to conducting our business,
but also to JLR’s reputation.
Copies of communications may be used as
evidence in a courtroom, in submissions to
government agencies that regulate our business
and in the development of articles by the media.
Communications include such things as written
memoranda, handwritten notes, drawings, e-mail,
computer files, voice mail and photographs.
Make sure that in written correspondence
you state the facts clearly to ensure the
communication is not misunderstood and do not
exaggerate or include unsupported assumptions
or suspicions in your communications.
Ensure communications are only sent to those
who have a need to receive them and avoid email
chains with unnecessary recipients.
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Accurate records
Accurate and complete business records enable
management to make proper and informed
decisions.
Additionally, JLR is required to provide certain
information to various government agencies, and
incorrect information could potentially subject the
company to legal penalties.
All records, therefore, must be complete, accurate,
and up-to-date. This means not only financial
records, but also such data as sales records, business
metrics, performance-related records, test records,
and engineering records.
Falsification, deliberate concealment, or deliberate
manipulation of records will not be tolerated.
Integrity of financial records
It is essential that all financial records be accurate
and complete both to fulfil the requirements
of government authorities but also to give JLR’s
directors an accurate picture of the financial position
of JLR at any given time.
JLR’s internal controls and internal audit framework
ensures that effective and robust process and
procedures are in place to ensure the integrity of
financial records. If you suspect or discover that any
financial information is not accurate or has been
wrongly recorded then you must report it.
JLR recognises that errors can occur but we must
all work to minimise any errors and handle them
properly once discovered.
JLR CODE OF CONDUCT
Accurate records & financial integrity
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JLR CODE OF CONDUCT
Protecting our brands
Our intellectual property
JLR’s various types of intellectual property are
highly valuable assets. They are key to our global
strategy of using innovation to sell world-class
products that are both unique and technologically
superior.
Our trademarks, for example, include our brand
names and logos, which identify our products to
customers and which are used on our websites and
domain names. They must be protected to prevent
others from associating their products or services
with our name.
In addition, the designs of our vehicles, the
parts and technologies we develop and our
manufacturing processes are all examples of
intellectual property which require legal protection
to prevent them from being copied.
New ideas and inventions may be protected by
formal patents whilst copyright laws will protect
our communications, advertising materials and
designs.
It is JLR’s policy to secure and protect its
intellectual property rights and to take appropriate
action against those who infringe on our rights. Just
as we expect others to respect JLR’s intellectual
property rights, we are committed to respecting
the intellectual property rights of others.
Each of us must ensure that we:

understand the processes in place to
protect the intellectual property we create;

promptly submit inventions to the JLR
patents function within the legal office;

do not disclose trade secrets, inventions
or confidential information to those outside JLR
unless on a need to know basis as part of doing our
jobs and protected by a confidentiality agreement
or the terms of a development or supply
agreement approved by the JLR legal office;
 promptly report any suspected
unauthorised uses of our intellectual property to
JLR’s legal function so that we can take steps to
protect our assets and brands;

do not use any names, logos or “get up” of
third parties without their express consent;

do not create any materials which may
confuse others into thinking they are associated
with another person or organisation;

do not use a new trademark, slogan or logo
until it has been cleared for use by the JLR legal
function;

do not copy software onto another
computer or allow others access to any software
without checking that a licence is in place which
permits such activities.
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JLR CODE OF CONDUCT
Abiding by this code
A consistent message
It is important that the reputation of JLR and its
brands is maintained by all those who represent JLR
- not just our employees.
Where we instruct agents to act on our behalf,
either as consultants, temporary workers or to help
sell our vehicles and parts, then this code must be
brought to their attention, and we should ask them
to comply with it in all respects.
In particular, when dealing with sales agents we
need to ensure that we know who we are dealing
with and satisfy ourselves that they will conduct
themselves with the same level of integrity we
insist upon for ourselves.
Confirming our own compliance
Compliance with this code is crucial to the success
of Jaguar Land Rover. It ensures we can all be
proud of our brands, our products and the way our
company operates. It helps us to be the best we
can be.
Each year all of us will be asked to confirm that
we have read and understood the code and that
we are complying with it. This certification process
will also give you an additional opportunity to raise
any concerns you may have so that they may be
properly reviewed.
Please use the annual certification as an
opportunity to refresh yourself of the contents
of this code, and to evidence your continued
commitment to drive the success of our company.
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COPYRIGHT © 2010. JAGUAR CARS LIMITED AND LAND ROVER
DESIGNED AND PRODUCED BY FP CREATIVE LTD