KEY PRINCIPLES & SCOPE OF APPLICABILITY

In this Code of Conduct the following words and terms shall have the meaning set opposite them:

“Employee” means any employee of Hermes;

“Service Provider” means any self-employed individual that provides services on behalf of Hermes including (without limitation) individuals who are final mile couriers, operate myHermes ParcelShops and/or provide sub-depot operational services; and

“Supplier” means any organisation that provides services to Hermes including (without limitation) any sub-contractors of Hermes.

Hermes Parcelnet Limited (“Hermes”) is committed to the sustainable development of its business in a way that reconciles economic success with the social wellbeing of individuals that are employed by Hermes or are involved in the provision of services to Hermes.

Hermes’ Code of Conduct is therefore based on ethical, moral and legal principles which provide the framework for all it does.

Hermes’ Suppliers and Service Providers can expect it to comply with the law, observe ethical standards and act as a fair business partner. In turn Hermes expects its suppliers and service providers to apply the same high standards.

PART 1 – PRINCIPLES TO BE APPLIED BY HERMES AND ITS EMPLOYEES TOWARDS SERVICE PROVIDERS AND SUPPLIERS

Part 1 of this Code is directed at Hermes and its Employees. It sets out the principles which Hermes and its Employees will follow in the course of their relationship and interactions with Service Providers and Suppliers.

Hermes will ensure that it complies with Part 1 of this Code of Conduct.

1. DIGNITY AND RESPECT

Hermes and its Employees will treat Service Providers and Suppliers with dignity and respect.

Hermes and its Employees will not expose any Service Provider or Supplier to verbal, psychological, physical, sexual and/or bodily violence, duress or harassment.

Hermes will always give reasonable notice to any Service Provider before terminating its engagement with them (save where the termination is because of the Service Provider’s un-remedied or irremediable material breach of contract), and in any case Hermes will always terminate its engagement with any Service Provider in accordance with the applicable contract.

2. EQUAL OPPORTUNITIES

Hermes and its Employees will treat all Service Providers and Suppliers in accordance with all applicable equality laws and the Hermes Equal Opportunities Policy, including the principles set out below.

Hermes and its Employees will not discriminate on the grounds of colour, nationality (including citizenship), national or ethnic origin, race, religion, sex, pregnancy, marital status, social class, age, sexual orientation, disability, political views, membership or non-membership of a trade union or any other personal characteristic.

3. CHILD LABOUR / YOUTH EMPLOYMENT

(ILO CONVENTIONS 138 AND 182 AND THE UN CONVENTION ON THE RIGHTS OF THE CHILD)

Hermes will not use or engage the labour of anyone below the legal minimum age and will comply with all laws concerning the protection of children and young workers and the relevant International Labour Organisation(ILO) standards.

4. MODERN SLAVERY AND HUMAN TRAFFICKING

Hermes strictly prohibits modern slavery and human trafficking in its operations and supply chain.

Forms of Modern Slavery may include, but are not limited to, working under threat or penalty, being forced to work very long hours without rest breaks, being forced and/or coerced to accept wages that are below the level set by applicable national laws, depending on the employer for housing, food and other necessities, withholding of passports and limitations on movements of workers. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery and human trafficking is a crime and a violation of fundamental human rights.

Hermes and its Employees will not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of the above principles.

5. REMUNERATION

Service Providers are self-employed individuals.

However, Hermes will agree contractual charging rates with Service Providers (the “Rates”) that give Service Providers the ability to earn income that is at least equivalent to the hourly rates set out in the National Minimum Wage Regulations. Hermes will keep the Rates under regular

review and will make any adjustments needed to the Rates to ensure that Hermes complies with this Code of Conduct.

Hermes will provide Service Providers with a regular breakdown of their pay or charges (as the case may be) in a way that they can understand.

6. HEALTH AND SAFETY

Where appropriate, Hermes will ensure a safe and healthy working environment for Suppliers and Service Providers.

7. BRIBERY AND CORRUPTION

Hermes does not tolerate any form of bribery or corruption. All Employees must behave in such a way that no personal dependency, obligation or influence arises and that there is no appearance of such.

Hermes requires commercial conduct based on fairness and compliance with applicable laws.

Any indications of bribery or corrupt behaviour of Hermes or any Employee can be reported to the Company Secretary of Hermes by email to company.secretary@hermes-europe.co.uk in addition to the contacts set out at the end of this Code of Conduct.

8. INFORMATION / COMMUNICATION

This Code of Conduct will be made accessible to all Employees, Service Providers and Suppliers and be displayed in appropriate locations.

Hermes will make arrangements so that this Code of Conduct may be explained to Employees, Service Providers and Suppliers as and when needed.

9. SANCTIONS AND REMEDIAL MEASURES

Hermes undertakes to take immediate and appropriate action in the event that any of its Employees is found to have breached the terms of Part 1 of this Code of Conduct.

10. REPORTING CONCERNS / BREACHES

Where individuals have a concern about a breach or potential breach of Part 1 of this Code of Conduct, they may report their concerns on a confidential basis as set out below.

Hermes will investigate any such complaints in accordance with its established procedures.

Individuals who report a concern are encouraged to provide their name and contact details so that the issues that they raise can be investigated most effectively. If an individual does not

provide their name and contact details, it may be more difficult for Hermes to investigate the matter effectively and/or to provide a means of redress.

Hermes will not tolerate any retaliation against any person who reports a concern in good faith under Part 1 of this Code.

Employees

Where any Employee is concerned about a breach or potential breach of Part 1 of this Code of Conduct, they may report their concerns on a confidential basis through the Hermes Speak Up Hotline. The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available.

Service Providers

Where any Service Provider is concerned about a breach or potential breach of Part 1 of this Code of Conduct, they may report their concerns on a confidential basis by following the procedure set out in the Service Provider Complaints Statement. A copy of the Service Provider Complaints Statement is attached at Appendix 1.

However, where the complaint relates to a serious alleged breach or potential breach of human rights (which could include an alleged breach or potential breach of Part 1, section 3 of this Code (Child Labour/Youth Employment) or Part 1, section 4 of this Code (Modern Slavery and Human Trafficking)) it should be reported on a confidential basis through the Hermes Speak Up Hotline. The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available. The complaint will then be referred to an independent external Ombudsman appointed by Hermes. The Ombudsman will consider the matter in accordance with the Ombudsman Investigation and Recommendations Procedure attached at Appendix 2.

Suppliers

Where any Supplier is concerned about a breach or potential breach of Part 1 of this Code of Conduct, they may report their concerns on a confidential basis to the Company Secretary of Hermes by email to company.secretary@hermes-europe.co.uk.

Employees or workers of a Supplier or Service Provider

Where any employee or worker of a Supplier or Service Provider is concerned about a breach or potential breach of Part 1 of this Code of Conduct, they may report their concerns through the Hermes Speak Up Hotline. The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available.

Where the complaint relates to a serious alleged breach or potential breach of human rights (which could include an alleged breach or potential breach of Part 1, section 3 of this Code (Child

Labour/Youth Employment) or Part 1, section 4 of this Code (Modern Slavery and Human Trafficking)) it will be referred to an independent external Ombudsman appointed by Hermes. The Ombudsman will consider the matter in accordance with the Ombudsman Investigation and Recommendations Procedure attached at Appendix 2.

PART 2 – PRINCIPLES TO BE FOLLOWED BY SERVICE PROVIDERS AND SUPPLIERS

Part 2 of this Code is applicable to Service Providers and Suppliers only. It sets out the principles which Service Providers and Suppliers must follow whilst they are engaged by Hermes. Service Providers and Suppliers must ensure that they comply with Part 2 of this Code of Conduct.

Compliance with Part 2 of this Code of Conduct is a condition of providing services to or on behalf of Hermes, and Hermes will audit its Service Providers and Suppliers to ensure such compliance.

Hermes or its authorised third parties may monitor and audit compliance with the principles of this Code of Conduct at any time. Service Providers and Suppliers must fully co-operate with Hermes or its authorised third parties (including the independent external Ombudsman) in order to facilitate such monitoring and/or auditing, including in respect of any third parties providing services to the relevant Service Provider or Supplier.

Hermes expects its Service Providers to ensure that the standards set out in this Code of Conduct, and the complaints procedure set out in section 10 below, are passed on to their employees, workers and their suppliers.

1. COMPLIANCE WITH LAWS

Suppliers and Service Providers must comply with all laws that apply to the employment of employees and engagement of workers, including with respect to the right to work in the UK.

2. DIGNITY AND RESPECT

Service Providers and Suppliers must treat their employees, workers and/or suppliers with dignity and respect.

Service Providers and Suppliers must not subject their employees, workers or suppliers to verbal, psychological, physical, sexual and/or bodily violence, duress or harassment.

3. EQUAL OPPORTUNITIES

Services Providers and Suppliers must act in accordance with all applicable equality laws and the principles set out below.

Service Providers and Suppliers must not discriminate on the grounds of colour, nationality (including citizenship), national or ethnic origin, race, religion, sex, pregnancy, marital status,

social class, age, sexual orientation, disability, political views, membership or non-membership of a trade union or any other personal characteristic.

4. CHILD LABOUR / YOUTH EMPLOYMENT

(ILO CONVENTIONS 138 AND 182 AND THE UN CONVENTION ON THE RIGHTS OF THE CHILD)

Service Providers and Suppliers will not use or engage the labour of anyone below the legal minimum age and will comply with all laws concerning the protection of children and young workers and the relevant International Labour Organisation(ILO) standards.

5. MODERN SLAVERY AND HUMAN TRAFFICKING

Hermes strictly prohibits modern slavery and human trafficking in its operations and supply chain.

Forms of Modern Slavery may include, but are not limited to, working under threat or penalty, being forced to work very long hours without rest breaks, being forced and/or coerced to accept wages that are below the level set by applicable national laws, depending on the employer for housing, food and other necessities, withholding of passports and limitations on movements of workers. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery and human trafficking is a crime and a violation of fundamental human rights.

Service Providers and Suppliers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of the above principles.

6. REMUNERATION

Service Providers and Suppliers must comply with the National Minimum Wage Regulations with regards to their employees and workers.

Service Providers and Suppliers must agree contractual charging rates with their suppliers that allow their suppliers to meet their obligations under the National Minimum Wage Regulations.

Every Service Provider and Supplier will pay charging rates to self-employed individual suppliers that are agreed between both parties in a way that is fair on an objective basis and does not involve any abuse of bargaining power by the Service Provider or Supplier.

Service Providers and Suppliers must provide their employees, workers and/or suppliers with a regular breakdown of their pay or charges (as the case may be) in a way that they can understand.

7. HEALTH AND SAFETY

Suppliers and, where relevant, Service Providers must ensure a safe and healthy working environment in the locations for which they are responsible.

It is a condition of working with Hermes that Suppliers and, where relevant, Service Providers must properly assess and address any risk to health and safety of their employees, workers, suppliers and members of the public.

8. BRIBERY AND CORRUPTION

Hermes does not tolerate any form of bribery or corruption. All Service Providers and Suppliers and their personnel must behave in such a way that no personal dependency, obligation or influence arises and that there is no appearance of such.

Hermes requires commercial conduct based on fairness and compliance with applicable laws from its Service Providers and Suppliers.

9. SANCTIONS AND REMEDIAL MEASURES

Suppliers and Service Providers must take immediate steps to remedy any relevant breach of this Code of Conduct. This does not affect any contractual right of Hermes to terminate its contract with a Supplier or Service Provider in appropriate circumstances.

10. COMPLAINTS PROCEDURE

Where individuals have a concern about a breach or potential breach of Part 2 of this Code of Conduct, they may report their concerns on a confidential basis as set out below.

Hermes will investigate any such complaints in accordance with its established procedures.

Individuals who report a concern are encouraged to provide their name and contact details so that the issues that they raise can be investigated most effectively. If an individual does not provide their name and contact details, it may be more difficult for Hermes to investigate the matter effectively and/or to provide a means of redress.

Hermes will not tolerate any retaliation against any person who reports a concern in good faith under Part 2 of this Code.

Employees

Where any Employee is concerned about a breach or potential breach of Part 2 of this Code of Conduct, they may report their concerns on a confidential basis through the Hermes Speak Up Hotline. The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent, anonymous and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available.

Service Providers

Where any Service Provider is concerned about a breach or potential breach of Part 2 of this Code of Conduct, they may report their concerns on a confidential basis by following the

procedure set out in the Service Provider Complaints Statement. A copy of the Service Provider Complaints Statement is attached at Appendix 1.

However, where the complaint relates to a serious alleged breach or potential breach of human rights (which could include an alleged breach or potential breach of Part 2, section 4 of this Code (Child Labour/Youth Employment) or Part 2, section 5 of this Code (Modern Slavery and Human Trafficking)) it should be reported on a confidential basis through the Hermes Speak Up Hotline. The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available. The complaint will then be referred to an independent external Ombudsman appointed by Hermes. The Ombudsman will consider the matter in accordance with the Ombudsman Investigation and Recommendations Procedure attached at Appendix 2.

Suppliers

Where any Supplier is concerned about a breach or potential breach of Part 2 of this Code of Conduct, they may report their concerns on a confidential basis to the Company Secretary of Hermes by email to company.secretary@hermes-europe.co.uk.

Employees or workers of a Supplier or Service Provider

Where any employee or worker of a Supplier or Service Provider is concerned about a breach or potential breach of Part 2 of this Code of Conduct, they may report their concerns through the Hermes Speak Up Hotline. The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available.

Where the complaint relates to a serious alleged breach or potential breach of human rights (which could include an alleged breach or potential breach of Part 2, section 4 of this Code (Child Labour/Youth Employment) or Part 2, section 5 of this Code (Modern Slavery and Human Trafficking)) it will be referred to an independent external Ombudsman appointed by Hermes. The Ombudsman will consider the matter in accordance with the Ombudsman Investigation and Recommendations Procedure attached at Appendix 2.

CONTACTS

Any questions regarding content of this Code of Conduct should be asked using the following email address:
codeofconductenquiry@hermes-europe.co.uk

RESPONSIBLE FOR CONTENTS

Published by:
Hugo Martin, Company Secretary
04 October 2016

APPENDIX 1

Service Provider Complaints Statement

1. Introduction and General Principles

1.1 The Hermes Code of Conduct sets out a Complaints Procedure under which Service Providers (as defined in the Code) may raise concerns about a breach or potential breach of the Code on a confidential basis.

1.2 Hermes has appointed a Service Provider Complaints Panel (the “Panel”) to consider such complaints.

1.3 The timescales set out in this procedure are intended as guidelines only. The Panel will conduct all stages of this procedure in a reasonable and timely manner taking account of the complexity of the issues.

1.4 The Panel will act reasonably and proportionately in performing its role under this procedure.

1.5 As set out above, the Panel will consider complaints from Service Providers in relation to a breach or potential breach of the Hermes Code of Conduct. Hermes may also, at its discretion, require the Panel to consider other material issues that may arise from time to time in relation to Service Providers or third parties.

2. Raising a Complaint – the Process

2.1 Step 1

If a Service Provider wishes to raise a complaint, they should raise it initially with the relevant Hermes Manager. In the case of a Courier, this will normally be their Field Manager. In the case of a Sub Depot Controller, this will normally be their Depot Manager.

Where the complaint relates to the Service Provider’s Manager, the Service Provider may proceed straight to Step 2 below.

2.2 Step 2 (Couriers only)

In the case of a Courier, any complaint must also be raised with the Courier Helpdesk team, who may be contacted on 0800 174 904 or 0113 397 6508.

2.3 Step 3

A Service Provider may then raise a complaint with the Panel by fully completing the Service Provider Complaints Form and submitting it to serviceprovidercomplaints@hermes-europe.co.uk

3. Exception for Serious Human Rights Concerns

3.1 As set out in the Hermes Code of Conduct, where the complaint relates to a serious alleged breach or potential breach of human rights (which may include an alleged breach or potential breach of the following parts of the Hermes Code of Conduct: Part 1, section 3 (Child Labour/Youth Employment); Part 1, section 4 (Modern Slavery and Human Trafficking); Part 2, section 4 (Child Labour/Youth Employment); Part 2, section 5 (Modern Slavery and Human Trafficking)) it should not be reported under the policy set out in this Service Provider Complaints Statement. Instead, it should be reported on a confidential basis through the Hermes Speak Up Hotline.

3.2 The Speak Up Hotline number is 0800 374199 (but some operators may charge to mobiles). The reverse charge number is 01249 661808. This service is completely independent and confidential and is available 24/7; 365 days a year. Translation services are readily and freely available. The complaint will then be referred to an independent external Ombudsman appointed by Hermes. The Ombudsman will consider the matter in accordance with the Ombudsman Investigation and Recommendations Procedure.

4. Initial Consideration of the Complaint – Stage 1 of the Panel Process

4.1 On receipt of a complaint:

4.1.1 the Panel will consider whether the complaint falls within the scope of the Panel’s authority;

4.1.2 where the Panel considers that a complaint relates to a serious alleged breach or potential breach of human rights, it will refer the complaint without delay to the independent external Ombudsman appointed by Hermes for consideration under the Ombudsman Investigation and Complaints Procedure;

4.1.3 where the complaint has not been raised anonymously (and has not been referred to the independent external Ombudsman under 3.1.2 above) the Panel will respond to the person raising the complaint within 1 week to acknowledge the complaint and confirm next steps.

5. Further Consideration and Investigation – Stage 2 of the Panel Process

5.1 Where a complaint progresses to Stage 2 of the Panel Process, it will be considered further by the Panel.

5.2 The Panel may consider it appropriate to carry out an investigation into the complaint. The amount of any investigation required will depend on the nature of the allegations and will vary from case to case.

5.3 Where an investigation takes place, the Panel will normally seek evidence from the person who raised the complaint, as well as from Hermes. It may involve interviewing and obtaining evidence from the person who raised the complaint and any witnesses, and/or reviewing relevant documents. In exceptional cases, it may involve a field visit.

5.4 Hermes will act reasonably in co-operating with any investigation conducted by the Panel, including providing relevant documents, information and evidence. The Panel should also request (but cannot compel) the same standards of co-operation from the person who raised the complaint, save where the complaint has been raised anonymously.

5.5 Where it is considered appropriate to meet with the person who raised the complaint or any other witness as part of an investigation, the Panel may delegate this task as it considers appropriate (for example, to a member of the Hermes Human Resources team) and shall make such arrangements for the meeting as it considers to be fair and reasonable.

5.6 The Panel will aim to complete Stage 2 of this procedure within a 2 week period.

6. Final Decision and Recommendations – Stage 3 of the Panel Process

6.1 Once the Panel has completed its consideration of a complaint under Stage 2 of the Panel Process, it will make its final decision and will aim to do so within a 1 week period.

6.2 The final decision will include the following:

6.2.1 a summary of the allegations;

6.2.2 a summary of the steps taken following receipt of the complaint, including any steps taken to investigate the complaint;

6.2.3 the Panel’s findings, including whether the complaint is upheld, upheld in part or not upheld;

6.2.4 any recommendations to Hermes, taking into account the standards set out in the Hermes Code of Conduct.

6.3 Following the conclusion of a specific case, the Panel may also wish to make recommendations to Hermes in relation to amendments to this procedure for use in future cases.

7. Confidentiality

7.1 Unless a good case is made for information to be withheld, information and evidence received by the Panel may be shared with the person raising the complaint and/or Hermes.

7.2 Where information is sensitive, the preferred course is to agree appropriate conditions of confidentiality.

APPENDIX 2

OMBUDSMAN INVESTIGATION AND RECOMMENDATIONS

PROCEDURE

1. INTRODUCTION AND GENERAL PRINCIPLES

1.1 The Hermes Code of Conduct sets out a Complaints Procedure under which Service Providers (or any employee, worker or third party supplier of a Service Provider or Supplier) may raise concerns about a breach or potential breach of the Hermes Code of Conduct on a confidential basis. The Code of Conduct states that where the concern relates to a serious alleged breach or potential breach of human rights (which may include an alleged breach or potential breach of the following parts of the Hermes Code of Conduct: Part 1, section 3 (Child Labour/Youth Employment); Part 1, section 4 (Modern Slavery and Human Trafficking); Part 2, section 4 (Child Labour/Youth Employment); Part 2, section 5 (Modern Slavery and Human Trafficking)) it will be referred to an independent external Ombudsman.

Hermes has appointed an independent external Ombudsman to consider such complaints. The Ombudsman is Anna Triponel.

1.2 The timescales set out in this procedure are intended as guidelines only. The Ombudsman will conduct all stages of this procedure in a reasonable and timely manner taking account of the complexity of the issues.

1.3 The Ombudsman will act reasonably and proportionately in performing the Ombudsman’s role under this procedure.

2. STAGE 1 – INITIAL CONSIDERATION AND ACKNOWLEDGMENT

2.1 On receipt of a complaint, the Ombudsman will:

2.1.1 consider whether the complaint relates to a serious alleged breach or potential breach of human rights;

2.1.2 where the complaint has not been raised anonymously, respond to the person raising the complaint within 1 week to acknowledge the complaint, to provide a copy of this procedure and confirm next steps;

2.1.3 notify the Hermes Company Secretary that a complaint has been raised, the nature of the complaint and next steps; and

2.1.4 Where the Ombudsman considers that the complaint relates to a serious alleged breach or potential breach of human rights, the next steps will involve further consideration of the complaint by the Ombudsman under Stage 2 of this procedure. Where the Ombudsman does not consider that

the complaint relates to a serious alleged breach or potential breach of human rights, the Ombudsman will refer the complaint to be considered under the Hermes Service Provider Complaints Statement by the Hermes Service Provider Complaints Panel.

3. STAGE 2 – FURTHER CONSIDERATION AND INVESTIGATION

3.1 Where a complaint progresses to Stage 2 of this procedure, it will be considered further by the Ombudsman.

3.2 The Ombudsman may consider it appropriate to carry out an investigation into the complaint. The amount of any investigation required will depend on the nature of the allegations and will vary from case to case.

3.3 Where an investigation takes place, the Ombudsman will normally seek evidence from the person who raised the complaint, as well as from Hermes. It may involve interviewing and taking statements from the person who raised the complaint and any witnesses, and/or reviewing relevant documents. In exceptional cases, it may involve the Ombudsman undertaking a field visit.

3.4 Hermes will act reasonably in co-operating with any investigation conducted by the Ombudsman, including providing relevant documents, information and evidence. The Ombudsman should also request (but cannot compel) the same standards of co-operation from the person who raised the complaint, save where the complaint has been raised anonymously.

3.5 Where the Ombudsman wishes to meet with the person who raised the complaint or any other witness as part of an investigation, the Ombudsman shall make such arrangements for the meeting as he or she considers to be fair and reasonable.

3.6 The Ombudsman will aim to complete Stage 2 of this procedure within a 4 week period.

4. STAGE 3 – FINAL STATEMENT

4.1 Once the Ombudsman has completed his or her consideration of a complaint under Stage 2 of this procedure, the Ombudsman will produce a Final Statement and will aim to do so within a 2 week period.

4.2 The Final Statement will include the following:

4.2.1 a summary of the allegations;

4.2.2 a summary of the steps the Ombudsman has taken following receipt of the complaint, including any steps taken to investigate the complaint;

4.2.3 the Ombudsman’s findings, including whether the complaints are upheld, upheld in part, or not upheld;

4.2.4 any recommendations to Hermes in order to ensure that Hermes achieves and sustains the standards set out in the Hermes Code of Conduct; and

4.2.5 where appropriate, a date by which the parties will be asked to submit an update on measurable progress towards meeting the recommendations (if any) to the Ombudsman.

4.3 Following the conclusion of a specific case, the Ombudsman may also wish to make recommendations to Hermes in relation to amendments to this procedure for use in future cases.

4.4 Hermes agrees to follow all recommendations made by the Ombudsman under Stage 3 of this procedure in order to achieve and sustain the standards set out in the Hermes Code of Conduct.

5. CONFIDENTIALITY

5.1 Unless a good case is made for information to be withheld, information and evidence received by the Ombudsman may be shared with the person raising the complaint and/or Hermes.

5.2 Where information is sensitive, the preferred course is to agree appropriate conditions of confidentiality.