High standards and strong controls
We firmly believe in doing business the right way by operating with high standards of business and personal integrity.
Trainline is committed to the highest standards of corporate governance and has strong controls in place to ensure that the Company complies with these standards.
We expect all our Directors, employees and suppliers to act with honesty, integrity and fairness. All Trainline employees undergo training and awareness on fraud, anti-bribery, data protection, information security and inside information to ensure that staff remain up to date and alert to unethical practices.
Trainline policies and controls
Trainline is committed to protecting against fraud and corruption within Trainline and from external sources. Trainline maintains an open and honest corporate culture with preventative measures and systems in place for detection and investigation of fraudulent behaviour. Trainline ensures that there is a strong understanding and awareness of fraud and corruption issues within Trainline and has a whistleblowing policy in place to allow for staff members to report where they see any inappropriate behaviour occurring. The Executive Team encourages staff to raise any concerns about fraud and corruption immediately as they occur. It treats all such concerns raised seriously and in confidence.
A dedicated Fraud Management team exists as part of Trainline’s anti-fraud strategy. The primary role of this team is to prevent online credit card fraud in Trainline by using a sophisticated suite of automated and manual systems and processes. The Executive Team and other managers are responsible for ensuring that appropriate internal controls are properly maintained including compliance with PCI DSS.
The Audit and Risk Committee reviews Trainline’s anti-fraud and anti-corruption programme and receives regular updates on its effectiveness. Following each Audit and Risk Committee update the Chair of the Audit and Risk Committee discusses the outcome with the Board, which is ultimately responsible for the programme.
Trainline has a detailed policy in place to ensure appropriate treatment and documentation of all gifts and hospitality. The acceptance of any gift or hospitality must be properly approved, recorded and documented by Trainline staff. Employees are instructed to refuse to accept gifts or hospitality which could influence or appear to influence decisions that they make on behalf of the Company.
The Head of Compliance and Risk Management regularly reviews the Group Gift Register to ensure that the policy is being applied correctly. There are strict policies and sanctions in place against bribery or inducements in return for favours and against facilitation payments and bribes. This includes disciplinary action which could include dismissal for gross misconduct where an employee is found to have accepted, requested or offered a bribe.
Trainline maintains an open and honest culture throughout the organisation. Trainline takes every step possible to create a positive environment where its employees will be comfortable raising any concerns that they have without fear of reprisal if they become aware of any misconduct or malpractice within Trainline. Trainline maintains a process which can be managed through an employee’s line manager or through an external whistleblowing service provider.
Trainline does not propose or intend to make political donations.
We take our role in protecting and promoting human rights seriously and understand that societies in which human rights are respected and protected enhance the wellbeing of citizens and allow businesses to flourish. We operate to ensure that we as a Company, and our employees, contractors and suppliers, respect international human rights standards through our human rights policy. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains via our Supplier Code of Conduct, which underlines our no-tolerance approach to modern slavery and human trafficking. Where appropriate and according to the level of potential risk, we introduce contractual provisions in contracts that require contractors, suppliers and other business partners to comply with applicable anti-slavery and anti-trafficking laws. We expect our suppliers to hold their own suppliers to the same high standards.
We aim to create a working environment in which all individuals can make best use of their skills, free from discrimination or harassment. We treat any behaviour, including sexual and non-sexual harassment, that undermines this aim as totally unacceptable and it will not be tolerated under any circumstances. Trainline is committed to a culture that is free from bullying and harassment, where staff can freely report any issue that needs attention and access support via the escalation procedures we have in place.
Our procurement processes reflect our commitment to sustainability and governance. Suppliers are assessed to ensure they are fit for purpose and sustainable, and that they meet Trainline’s ethical standards, security requirements, and environmental and corporate responsibilities and comply with relevant legislation, wherever they are in the world.
Trainline is committed to maintaining a healthy and safe working environment. Our premises and facilities are inspected regularly, and every effort is made to maintain the highest standards. A health and safety risk assessment register is maintained and regularly updated by the Facilities team.
Trainline recognises that its day-to-day operations and other responsibilities can impact upon the environment in many ways. We are therefore committed to promoting good environmental performance, reducing pollution, actively recycling and minimising, so far as is reasonably practicable, adverse environmental impact. We also recognise the overall positive impact on the environment made by rail travel when compared to other travel modes, resulting in less pollution. We will encourage growth in rail travel by improving our retailing and information services to make buying and selling rail travel easy. To support the above policy, Trainline will work with employees, consultants, contractors, customers and suppliers to identify practicable ways of reducing our environmental impact.