FINANCIAL STATEMENTS
STRATEGIC REPORT
GOVERNANCE
• We continued to focus on providing a wide range of wellbeing support and guidance for our colleagues built around mental, physical, social and financial wellbeing. Our current offering includes the support of Mental Health First Aiders and our Employee Assistance Programme (“EAP”) called WeCare, which is available to all colleagues offering a broad range of wellbeing support, in addition to free access to our corporate version of the Headspace App, described as a “gym membership for the mind”. • We have policies and provide training to help ensure that our colleagues act ethically and do the right thing in the performance of their work. Our activities to help our colleagues feel proud to work at Just and our compliance policies work together to help mitigate against colleagues acting unethically. • Our Group whistleblowing policy, and our whistleblowing hotline, encourage colleagues to report any wrongdoing. All such reports are fully investigated and appropriate remedial actions are taken. • From early 2021 we began to plan a trial of new, hybrid ways of working. This commenced in September and incorporated feedback from colleagues across the organisation. At the heart of our approach is our belief that spending some time regularly in the office will help colleagues to collaborate, innovate, learn from one another and network, as well as sustaining the great culture we have built at Just. More broadly, we want to supplement the virtual and remote support colleagues have provided to each other over the past two years with real, in-person connections. We adopted an agile test and learn approach to introduce new ways of working for 2022 and beyond. 3. SOCIAL • We give back to the communities in which we operate and are committed to good corporate citizenship, supporting charity and community initiatives which are relevant to our business, colleagues, customers and other stakeholders. Our colleagues also benefit from participating in our social activities. The risk to the business from our social impacts is considered to be low. • During the year, Just raised funds for our corporate charity partner Re-engage, in line with our purpose of helping people achieve a better later life, with activities including a virtual “Around the World in 80 Days” sponsored challenge and gifting our apprenticeship levy to Re-engage to train a data analyst for its business. We recognised Dementia Action Week in May, providing training to colleagues to become dementia friends, and supported colleague fundraising (half matching their funds up to £500) for a number of charities close to colleagues’ hearts, including Cancer Research UK, Battersea Dogs and Cats Home, The Lucy Rayner Foundation and the Alzheimer’s Society. • We have been investing in our communities to help older adults get active for a happier, healthier life through our programme, Just Get Active. Further information about our community programme can be found on our website www.justgetactive.co.uk . • For further information about our social activities and the impacts, see our Colleagues and culture report on page 30. 4. HUMAN RIGHTS • While the Board considers that the risk of human rights violations is low, we have implemented effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or in any part of our business anywhere we operate. Our Modern Slavery Statement available on our Group website provides further information. We conduct due diligence on potential suppliers, impose obligations on those suppliers and monitor their compliance with those obligations. • We have a responsibility to protect our customers’ privacy when processing and using their data. We handle our customers’ sensitive personal data and are aware of the importance that this is used appropriately and is protected. All of our colleagues, including those who are not customer facing, are trained on data protection, and internal communications campaigns are used to remind staff of the importance of data privacy. Rigorous steps are taken to ensure the security of all the personal data we handle.
• Some of our customers may have additional or different needs and we want to ensure that they receive a fair outcome with the appropriate support being provided when needed. Our Group vulnerable customer policy defines our approach to ensuring vulnerable customers receive consistently fair treatment across our Group. Relevant training is provided to colleagues to help them identify the characteristics of vulnerability and provide appropriate support to our customers. Our policies and processes will be adapted if necessary, and where possible, to accommodate specific customer needs. 5. ANTI-CORRUPTION AND ANTI-BRIBERY • We have a Group financial crime policy which is a zero tolerance policy. This policy helps us to prevent and detect financial crime. • Our gifts and hospitality procedure supports the financial crime policy, by providing the rules and guidance to help prevent all colleagues receiving or providing an undue influence over the making of a business decision. • We have a comprehensive mandatory compliance training programme which covers the above policies as well as other important areas of compliance which all colleagues must complete on an annual basis. Completion is monitored by the Compliance team and reported to the Board, with repeated failure to complete the training being a disciplinary matter. NON-FINANCIAL RISK MANAGEMENT The Risk management report on page 58 sets out our approach to risk management. Our approach enables all colleagues to take more effective business decisions through a better understanding of risk. The Annual Report sets out our principal risks and uncertainties including non-financial risks and how we mitigate those risks. The Group Risk and Compliance Committee (“GRCC”) has considered various non-financial risks during the year. These include risks arising from people, operational processes and IT systems, conduct risk and the current and future business and operational impacts of COVID-19 on the Group. The GRCC also received regular reports on the status of the Group’s climate change project, which covers various workstreams including risk management and financial risks. The aim is to prevent non-financial risks frommaterialising and having a detrimental impact on our business (including our reputation), our colleagues, our customers, our suppliers and other stakeholders. Our Compliance teammanages the Group’s Policy Framework. Each Group policy has a policy owner and an executive sponsor, who review the policy at least annually and provide an attestation as to its adherence and any material breaches. Each Group policy is reviewed by the GRCC and approved by the Board. Material breaches of policies are recorded in our risk management system and escalated to the Group Chief Risk Officer. Any serious breaches are reported to the GRCC or Board. This on-going management of risks highlighted by breaches enables the business to take necessary action to mitigate the risk such as through training or improving a process or policy.
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