CORPORATE SOCIAL
RESPONSIBILITY POLICY

John Banks Group

1. Purpose

John Banks Group is committed to operating responsibly, ethically and sustainably. Corporate social responsibility (CSR) means considering the interests of our employees, customers, suppliers, communities and the environment when making business decisions, while maintaining a commercially sound and legally compliant business.

This policy sets out the principles by which the Group conducts its activities and explains how those principles are embedded in its governance, employment practices, customer service, supply chain, environmental management and community engagement.

2. Scope

This policy applies across John Banks Group, including John Banks Limited and John Banks Ipswich Limited, at all sites and to all directors, officers and employees. Relevant standards also apply to agency workers, contractors, consultants and suppliers where appropriate to their relationship with the Group.

This policy supports, and should be read alongside, the Group's Code of Conduct, Equality, Diversity and Inclusion arrangements, Dignity at Work and Anti-Harassment policies, Whistleblowing Policy, Health and Safety Policy, Environmental Policy, Data Protection and Information Security policies, Anti-Bribery and Corruption Policy, Anti-Money Laundering Policy, Fraud Prevention procedures, Modern Slavery Statement, Treating Customers Fairly Policy and relevant FCA compliance procedures.

3. Our CSR principles

Act lawfully, honestly, fairly and with integrity.

Treat people with dignity and respect and promote an inclusive workplace.

Deliver fair value and good outcomes for customers.

Protect health, safety, wellbeing, personal information and confidential information.

Reduce adverse environmental impacts and use resources responsibly.

Work with reputable suppliers that share appropriate ethical standards.

Support the communities in which the Group operates.

Set proportionate objectives, monitor performance and pursue continual improvement.

4. Governance, ethics and accountability

The Board is responsible for oversight of this policy. The Chief Executive Officer and senior management are responsible for integrating its principles into business planning, operational controls and decision-making. Departmental and site managers must promote these standards and address concerns within their areas of responsibility.

The Group will:

maintain proportionate controls designed to prevent bribery, corruption, fraud, tax evasion, money laundering and other financial crime;

identify and manage conflicts of interest, gifts and hospitality in accordance with Group policy;

maintain accurate business and financial records and cooperate with lawful audit and regulatory requirements;

consider material social, environmental, employee, customer and reputational factors when making significant decisions;

encourage concerns to be raised promptly through management, the People Team or the confidential routes described in the Whistleblowing Policy; and

prohibit retaliation or victimisation against anyone who raises a genuine concern in good faith.

5. Our people

The Group recognises that its employees are central to its success. We seek to provide a fair, inclusive and supportive working environment in which individuals understand their responsibilities, can develop their skills and are treated with dignity.

We are committed to:

fair, objective and transparent recruitment, development, appraisal and reward practices;

equal opportunities and compliance with the Equality Act 2010, including reasonable adjustments for disabled employees and applicants;

taking reasonable steps to prevent sexual harassment and addressing risks involving colleagues, customers, contractors and other third parties;

preventing bullying, harassment, discrimination, retaliation and victimisation;

supporting physical and mental wellbeing, while managing attendance fairly and sensitively;

providing role-appropriate induction, training, supervision, feedback and opportunities for professional development;

consulting and communicating with employees on matters that affect them, where appropriate;

paying employees correctly and complying with applicable working-time, holiday, pension and employment requirements; and

respecting freedom of association and the right of employees to raise workplace concerns.

Employees are expected to act professionally, respect colleagues and customers, complete required training, follow Group policies and report conduct or conditions that may place people, customers, the business or the environment at risk.

6. Customers and responsible trading

We aim to build lasting customer relationships by providing suitable products and services, clear information, fair value, reliable service and accessible support. We will act honestly, openly and professionally throughout the customer journey.

In particular, the Group will:

support the delivery of good customer outcomes and comply with applicable FCA requirements through the Group's appointed representative arrangements;

identify and respond appropriately to customers in vulnerable circumstances, including making reasonable adjustments and offering suitable communication channels;

ensure financial promotions and material product information are clear, fair and not misleading;

explain relevant costs, commissions, exclusions and limitations where required and support informed customer decisions;

monitor customer outcomes, complaints, cancellations and other management information to identify potential harm or recurring concerns;

handle complaints promptly, fairly and in accordance with applicable procedures;

avoid misleading environmental or sustainability claims about vehicles, products or business activities; and

protect customer information in accordance with data protection and confidentiality requirements.

7. Suppliers, contractors and human rights

The Group seeks to develop constructive relationships with suppliers and contractors based on quality, reliability, value, legal compliance and responsible business conduct. Local and regional suppliers may be considered where they can meet the Group's commercial, operational and compliance requirements.

We expect relevant suppliers and contractors to:

comply with applicable employment, equality, health and safety, environmental and human-rights laws;

prohibit forced labour, servitude, human trafficking and unlawful child labour;

maintain appropriate anti-bribery, fraud-prevention and ethical-business controls;

protect personal, confidential and commercially sensitive information;

manage environmental impacts and waste responsibly; and

cooperate with reasonable due diligence, information requests and remedial action where a material concern is identified.

The Group will conduct proportionate, risk-based supplier due diligence. Serious or repeated breaches may result in corrective action, suspension or termination of the relationship, subject to contractual terms and the circumstances. The Group will publish and review its Modern Slavery Statement annually where required by law.

8. Health, safety and wellbeing

The Group is committed to providing and maintaining, so far as is reasonably practicable, safe and healthy working conditions for employees and others affected by its activities. Health and safety is a shared responsibility and must form part of everyday operational planning and decision-making.

The Group will maintain:

a current Health and Safety Policy and suitable site and activity risk assessments;

safe systems of work, appropriate equipment, personal protective equipment and competent supervision;

arrangements for reporting and investigating accidents, near misses, unsafe conditions and occupational-health concerns;

role-appropriate training, including mandatory online learning through the Group's approved training platform and practical instruction where required;

controls for workshop, vehicle-movement, manual-handling, hazardous-substance, fire and contractor risks; and

procedures for emergency preparedness, first aid and welfare.

No employee will be expected to undertake work for which they have not received appropriate instruction, training, equipment or authorisation. Employees must stop and report work that they reasonably believe presents a serious and imminent danger.

9. Environment and sustainable operations

As an automotive retailer and repairer, the Group recognises the environmental impacts associated with buildings, energy, transport, vehicle preparation and repair, water use, packaging and waste. We will comply with applicable environmental obligations and seek practical, proportionate improvements.

Our environmental priorities include:

monitoring energy and fuel consumption and identifying opportunities to reduce greenhouse-gas emissions;

supporting customers with accurate information about lower-emission, hybrid and electric vehicles where available;

preventing pollution and managing oils, fuels, batteries, tyres, refrigerants, chemicals and other hazardous materials through authorised processes;

separating recyclable workplace waste and using appropriately licensed waste carriers and treatment routes;

reducing avoidable paper, packaging, water and single-use material consumption;

considering energy efficiency and environmental impact when maintaining or improving premises and equipment;

maintaining records required for environmental, waste and energy reporting; and

providing employees and relevant contractors with information and training on their environmental responsibilities.

Environmental claims must be accurate, specific and capable of substantiation. Commercial requirements, customer safety, manufacturer standards and product quality will be considered alongside environmental objectives.

10. Data, privacy, technology and responsible AI

The Group will process personal information lawfully, fairly, transparently and securely. Access to customer, employee and business information must be limited to legitimate business purposes and appropriate safeguards must be maintained against loss, misuse, unauthorised access and cyber threats.

Technology, automation and artificial intelligence must be used responsibly and subject to appropriate human oversight. Employees must not enter personal, confidential or commercially sensitive information into unauthorised systems. Decisions with a significant effect on an individual must not be delegated to automated tools without appropriate review and compliance with Group policy and applicable law.

11. Communities and charitable activity

The Group values its long-standing relationship with the communities in Cambridge, Bury St Edmunds, Ipswich, Colchester and the surrounding areas. We aim to contribute positively by:

providing employment, apprenticeships, training and career-development opportunities;

supporting appropriate local charities, community organisations and events through fundraising, donations, sponsorship or volunteering;

encouraging responsible road use, road safety and inclusive access to mobility;

seeking to minimise unreasonable disturbance or adverse effects on neighbouring communities; and

considering community benefit alongside commercial value when selecting suitable local initiatives.

Charitable support must be transparent, appropriately authorised, consistent with the Group's values and free from improper influence or conflicts of interest. Support may vary according to business circumstances and does not create an ongoing funding commitment.

12. Monitoring and continual improvement

The Group will use proportionate management information to assess whether this policy is being implemented effectively. Measures may be refined as systems and reporting mature.

Material concerns, significant incidents and agreed improvement actions will be escalated to the appropriate senior manager or the Board. The Group may report relevant progress through its annual accounts, statutory statements, website or other stakeholder communications where appropriate and required.

13. Speaking up and reporting concerns

Employees should raise suspected breaches of this policy promptly with their line manager, another appropriate manager, the People Team or through the reporting arrangements in the Whistleblowing Policy. Customer concerns should be handled under the Group's complaints procedure. Data incidents, safety events and environmental incidents must be reported through the relevant specialist procedure without delay.

Concerns will be considered sensitively and, where appropriate, investigated. Confidentiality will be respected so far as reasonably possible. The Group will not tolerate retaliation or victimisation against anyone who raises a genuine concern in good faith.

14. Responsibilities

The Board approves this policy and oversees material CSR risks and performance.

The Chief Executive Officer sponsors implementation and ensures appropriate senior ownership.

Directors and senior managers integrate CSR considerations into strategy and significant decisions.

Site and departmental managers implement relevant controls, communicate expectations and address non-compliance.

The People Team supports employment, equality, wellbeing, training and speaking-up arrangements.

Compliance, Finance, Health and Safety, IT and operational functions maintain controls within their specialist areas.

All employees must follow this policy, complete required training and report concerns promptly.

15. Breaches

A failure to comply with this policy or an associated Group policy may result in investigation and, where appropriate, disciplinary action up to and including dismissal. Breaches by contractors or suppliers may lead to remedial requirements or termination of the relationship. Suspected criminal or regulatory matters may be reported to the relevant authority where required or appropriate.

16. Review and approval

This policy will be reviewed at least annually and earlier where there is a significant change in law, regulation, Group structure, operations or identified risk. Supporting objectives and actions may be updated separately without reducing the principles contained in this policy.