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. The Company has established an Anti-fraud, Bribery and Corruption Policy, together with other relevant policies and appropriate sanctions in place, to take a zero-tolerance approach 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.


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.


Our policy on bribery defines it as offering, promising, giving, accepting or requesting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. Examples of advantages include money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.


Corruption is the abuse of entrusted power or position for private gain.


Facilitation payments, also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example, by a government official).


Internal control systems and procedures have been implemented, including the appropriate segregation of duties to ensure, as far as possible, that errors, fraud, bribery and corruption are prevented. The appropriate financial record keeping practices are in place which evidence the business reason for making all payments to third parties, as a means of preventing the facilitation of, or concealing, improper payments. Within the relevant polices there are clear guidelines on how to recognise and deal with bribery and corruption issues, and what are considered to be acceptable and unacceptable behaviours. As and when Executive team leaders are notified of potential breaches of the Anti-fraud, Bribery and Corruption Policy, these are assessed and escalated through established channels, where appropriate.


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.


Ultimately, Trainline seeks to promote a culture of honesty and openness, in which individuals feel empowered to raise any concerns they may have. Specific training is provided to all the relevant teams at Trainline on the Anti-fraud, Bribery and Corruption Policy, which is refreshed on an annual basis.

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.

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. The Company’s Whistleblowing Policy is made available to all employees and clearly signposted. This policy sets out how colleagues can report concerns and explains the protection and support that will be given to those who speak up.


Trainline maintains an external independent whistleblowing service provider, Safecall, to all our global employees, which can be contacted 24/7, and anonymously if preferred. Trainline’s suppliers and third parties are provided with Safecall’s contact details during the onboarding process, and via the Company’s Supplier Code of Conduct, found here:  Supplier code of conduct (trn-13455-s3.s3.eu-west-2.amazonaws.com)


The Company has established structures in place to process whistleblower reports, with the Company’s Audit & Risk Committee receiving reports throughout the year on whistleblowing arrangements and activities.


In accordance with the statutory protection under the UK Public Interest Disclosure Act 1998, retaliation in any form against individuals who raise concerns is not tolerated, and Trainline will take any necessary action to protect employees’ from harassment or victimisation.


Genuine concerns raised in good faith do not result in any adverse consequences for speaking up, even if mistaken about those concerns. Any employee that feels they are being retaliated against, is encouraged to report it immediately. Any individuals found to be deliberately retaliating against a whistleblower will be investigated in accordance with the Company’s Disciplinary Policy.

Trainline is a politically neutral business. We do not have any active political party affiliations, nor do we seek to promote a particular political party, and we do not make political donations. Through the normal course of business, we engage with governments, regulators, public interest groups, rail industry associations and other rail-related bodies in the jurisdictions in which we operate. We do this to inform them of our position on issues that affect our customers, our business and by extension our colleagues.


We annually disclose any political donations or political expenditure incurred in the financial year within the Directors’ Report section of our Annual Report. Trainline does not propose, or intend, to make political donations or incur political expenditure.

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, human trafficking, forced or compulsory labour and child labour 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.

Modern Slavery Act statement

We aim to create a working environment in which all individuals have equal opportunity and 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.

Supplier Code of Conduct

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.