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Our policies

Business Values

At WHSmith we strive to be an outward-facing, customer-focused, store-responsive organisation that delivers on our promises. Living our four key values is an important part of achieving this aim. These values are as follows:

  1. Customer Focus – We will keep the customer at the heart of all that we do
  2. Drive for Results – We will act with tenacity to deliver ambitious and competitive results
  3. Accountability - We will take responsibility and deliver what we say we will
  4. Value our People - At WHSmith, our people are respected and valued in an honest, open environment
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Business Conduct

While we are primarily focused on delivering value to our shareholders, the Code of Business Conduct takes into account the interests of all stakeholders: investors, employees, customers, suppliers, competitors and the wider community - as well as the environment shared by everyone.

1. Shareholders

The Company is responsible to those who provide funding. We -

  1. Communicate accurately and timely to all concerned regarding our policies, achievements, risks and prospects.
  2. Seek to use financial resources entrusted to us in ways that maximise value over time.
  3. Provide financial reports that are accurate and timely.
  4. Work at all times to comply with the provisions of the Stock Exchange Listing Rules and aim to comply with corporate governance best practice.

2. Employees

The Company values its employees highly. We -

  1. Respect the dignity and rights of all employees.
  2. Provide healthy and safe work environments.
  3. Have a transparent remuneration policy that rewards the contribution of our people.
  4. Encourage employees to develop skills and progress their careers.
  5. Do not tolerate any sexual, physical or mental harassment of our employees
  6. Do not discriminate on the grounds of colour, ethnic origin, gender, sexual orientation, age, disability or religion.
  7. Do not employ underage employees.
  8. Encourage employees to report any suspicions of fraud or undesirable practice and we have introduced a process to facilitate this.

3. Customers

The Company’s customers are of paramount importance. We -

  1. Seek to be honest and fair in our dealings with our customers.
  2. Provide the quality and standard of service that customers have a right to expect
  3. Provide and promote a range of products responsive to customer needs that provide value for money.
  4. Provide products that are safe, fit for purpose, meet legal standards and are never described in a misleading manner.
  5. Treat all customer complaints seriously and provide a readily accessible source of advice and guidance regarding our products and services. 

4. Suppliers & Business Partners

The Company’s relations with its suppliers are based on mutual trust and respect. We -

  1. Seek to be honest and fair in our relationships with suppliers.
  2. Pay suppliers in accordance with agreed terms.
  3. Respect any confidential information.
  4. Respect copyright and intellectual property rights.
  5. Have a policy not to offer, pay or accept bribes or substantial favours.
  6. Have an ethical code of supply, communicated to our suppliers.
  7. Work with our suppliers to ensure the standards set out in the Ethical Code of Supply are met.
  8. Encourage our suppliers and business partners to at least meet the same standards of business conduct as those outlined in this Code.

5. Community & Environment

The Company seeks to be a good corporate citizen, respecting the laws of the countries in which we operate and contributing to the communities in which we operate. We –

  1. Aim to make the communities in which we work better places to live and do business.
  2. Seek to be sensitive to the local community’s culture and social and economic needs.
  3. Encourage our employees to be involved with local communities to their mutual benefit. Measure and, where appropriate, seek to reduce the environmental impacts of our business activities. We will optimise our use of energy and natural resources and reduce our generation of waste.

6. Lobbying and Political

The Company does not make political donations or support party political interests. However, We –

  1. Will continue to engage in policy debate on subjects of legitimate concern to the group, its staff and the communities in which it operates.
  2. Are a member of a number of trade associations, including the British Retail Consortium, which may participate in public policy activities in which it has a business interest from time to time. Where our views differ significantly from our trade associations on issues that are important to us we will make these known.
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Community Engagement Policy

As an employer of some 14,000 people in the UK and with retail stores and distribution centres in over 1,000 locations we recognise that WHSmith plays an important role in many communities throughout the UK.

In line with our Code of Business Conduct, we aim to make the communities in which we work better places to live and do business, seek to be sensitive to the local community’s culture and social and economic needs and encourage our employees to be involved with local communities to their mutual benefit. We will focus many of our community investment projects on supporting literacy and promoting a love of reading.

The WHSmith Trust, a registered charity, actively supports employees who volunteer for or raise funds for charitable organisations or schools in their local community. The Trust raises and distributes funds to charitable organisations in which members of staff are involved, and also supports projects to promote literacy.

We are committed to investing pre-tax profits in support of schools and charities, primarily in the local communities where we operate.  We will monitor and measure our investment.

Reviewed by WH Smith PLC Group Board: 2019

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Employee Policies

WHSmith aims to achieve a working environment in which:

  1. Those who work for us are proud of the Company and feel responsible for its success
  2. Everyone is respected, treated fairly, listened to and involved
  3. People achieve real satisfaction from their accomplishments and business friendships and enjoy their place of work

This will be achieved through a climate and style of leadership which is direct, open to new ideas, offers personal accountability and recognises individual and team achievements. Within the Company everyone contributes to its success. In return, we will aim to provide a good career at whatever level by:

  1. Promoting an equal opportunities culture that encourages diversity
  2. Recruiting the right people for the right job
  3. Rewarding people fairly
  4. Investing in training and developing them for their job and future career progression
  5. Providing a safe working environment
  6. Communicating and involving
  7. Always being fair and allowing each individual a sense of dignity
  8. Providing a range of working pattern options
  9. Not letting each other down
  10. Ensuring that work is enjoyable and rewarding
  11. Providing an environment that will challenge individuals whilst providing the support to face those challenges.

Our employee policies are continually under review to ensure that we treat and reward our people fairly and competitively in line with best practice. For this reason we have not posted all of the individual policies, however if you have a specific request, please contact us and we will send you a copy of the policy you require.


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Environmental Policy

WHSmith is aware of its responsibilities regarding the impact of its operations on the environment. We recognise that effective environmental management practice is not only important in caring for our environment, but also makes good business sense. The following policy reflects our concern and demonstrates our commitment to environmentally responsible business activities.


To implement the policy WHSmith will -

  1. Conduct its business in a responsible manner in order to reduce adverse environmental impacts arising from its activities.
  2. Support the principle of sustainable development in all business activities.
  3. Encourage re-use and re-cycling and otherwise minimise waste production.
  4. Aim to achieve the most efficient use of materials and energy.


To implement the policy WHSmith will -

  1. Work with our business partners to progress environmental initiatives.
  2. Make senior managers within each area of our business activity accountable.
  3. Raise environmental awareness amongst all our people by effective communication and support.
  4. Integrate environmental objectives into our strategy of both traditional and new ways of doing business.
  5. Develop environmental targets and monitor performance against those targets.
  6. Ensure that environmental issues are considered during the decision making process.
  7. Share environmental information with shareholders, customers, employees and other relevant audiences.
  8. Keep informed of best practice and be represented on industry action groups.
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Ethical Trading Code of Conduct and Human Rights Policy

WHSmith is committed to ensuring good standards among its suppliers and engaging with the supply base to bring about improvement. WHSmith will only work with reputable suppliers and manufacturers who are committed to working towards compliance with the conditions set out in this code. A process of self-evaluation, independent audit and training is in place to ensure that continuous improvement is made.

Employment is freely chosen

  1. There is no forced, bonded or involuntary prison labour.
  2. Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice.

Freedom Of Association And The Right To Collective Bargaining Are Respected

  1. Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
  2. The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
  3. Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
  4. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

Working Conditions Are Safe And Hygienic

  1. A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
  2. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
  3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
  4. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
  5. A member of senior management shall assigned responsibility for health and safety.

Child Labour Shall Not Be Used

  1. There shall be no new recruitment of child labour.
  2. Where child labour is found, the employer shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; "child" and "child labour" being defined below.
  3. Children and young persons under 18 shall not be employed at night or in hazardous conditions.
  4. The policies and procedures relating to the employment of children shall conform to the provisions of the relevant ILO standards.

Living Wages Are Paid

  1. Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
  2. All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.
  3. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

Working Hours Are Not Excessive

  1. Working hours comply with national laws and benchmark industry standards, which ever affords greater protection.
  2. In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7-day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

No Discrimination is Practised

  1. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Regular Employment is Provided

  1. To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.
  2. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

No Harsh Or Inhumane Treatment is Allowed

  1. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Environmental Impact is Managed

  1. Suppliers should measure and where appropriate, seek to reduce the environmental impacts of their business activities. In addition to complying with local laws, steps should be taken to optimise the use of energy and natural resources and reduce the generation of waste.


Child - Any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply.

Young person - Any worker over the age of a child as defined above and under the age of 18. Child Labour: Any work by a child or young person younger than the age(s) specified in the above definitions which does not comply with the previsions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the child’s or young person’s education, or to be harmful to the child’s or young person’s health or physical, mental, spiritual, moral or social development.

The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this Base Code address the same subject, to apply that provision which affords the greater protection.

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Forest Sourcing Policy

WHSmith offers a wide range of wood and paper products that come from a large number of forest sources. We must ensure that these forests continue to be available for future generations: this is important to our customers and our staff. This Policy applies to all of our own-brand products containing solid wood and or/paper (such as books and cards bearing the WHSmith logo). It is our ultimate objective that all virgin (i.e. non-recycled) material used in our products be from known, legal, well-managed and credibly certified forests. Certification seeks to provide evidence of legality and sustainability and many schemes have been set up around the world. We believe that any credible forest certification scheme should:

  1. Be independent and recognised by environmental groups;
  2. Be able to trace wood and pulp from the forest through to consumer products;
  3. Provide a simple logo that is recognised worldwide.

The scheme that we consider to best meet these requirements is that provided by the Forestry Stewardship Council (FSC).

However, the issues are complex and it will take us time to get to this position. As a minimum we expect our suppliers to know where forest material used in their products comes from and be able to provide evidence that it has been legally harvested.

WHSmith will work to:

  1. Eliminate any forest material that has been illegally harvested;
  2. Eliminate any material from forests with high conservation value that have not been independently certified;
  3. Eliminate material arising from inappropriate clearance or conversion of natural forests to plantations;
  4. Continually increase the proportion of material that comes from recycled post-consumer waste or from credibly certified, well managed forests, such as those certified by the Forestry Stewardship Council (FSC).

To implement this policy we will:

  1. Communicate this policy and associated targets to our suppliers of paper and wood based products and other interested parties;
  2. Work with suppliers to ensure that all forest material has been legally harvested;
  3. Work in partnership with key suppliers to increase the amount of credibly certified forest material used in their products;
  4. Integrate our requirements into the purchasing decisions of our business functions; we will not accept forest sources from any species on the CITIES list.
  5. Set ourselves challenging but realistic annual targets to increase the percentage of FSC and post-consumer recycled waste used in our products.
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Health and Safety at Work

Statement of General Policy

WHSmith is committed to maintaining the health and safety of all its customers, employees, suppliers and contractors by providing a safe place to work and shop. This policy applies to all areas or our business.

Board Commitment

The Board reviews our Health and Safety policy and performance on a regular basis and is committed to ensuring that the business undertakes all reasonably practicable measures in meeting this commitment.

Health and Safety Responsibilities

Every employee has a duty to take care of themselves and others who may be affected by what they do whilst at work. All employees are duty bound to co-operate with the Company's arrangements for maintaining health and safety standards, as well as with responsibilities specified within their terms of employment. Employees are also required to report any workplace accidents and unsafe conditions that they identify.

Managers and Supervisors have additional responsibilities to manage health and safety issues under their direct control. This involves ensuring that suitable health and safety arrangements are in place locally, and that individual responsibilities are clearly allocated. Advise and assistance is also available from the appropriate specialist support functions, including the Group Risk Department.

Health and Safety Arrangements

As part of these Health and Safety Arrangements, the Business will:

i. Provide information about our health and safety arrangements;

ii. Monitor the workplace to ensure that risks are appropriately controlled;

iii. Provide access to suitable training and supervision;

iv. Monitor accidents;

v. Provide access to competent health and safety advise; and

vi. Consult with staff on health and safety issues

This Policy will be reviewed annually.

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Marketing Code of Practice

We take the responsibility for the products we sell seriously and we are committed to listening to our customers. Our Marketing Code of Practice sets out the standards we will follow in our promotional activity, marketing and advertising.

Our central aim at WHSmith is to offer our customers choice, whilst also respecting customer views. Customers often have strongly differing views about the products we sell, so we aim to strike the right balance to meet the needs of all our customers. As part of our commitment to promote and retail all products in a responsible manner, we will:

  1. Be honest and fair in our dealings with our customers.
  2. Provide and promote a range of products responsive to customer needs that provide choice and value for money.
  3. Sell products that are safe, fit for purpose, meet legal standards and are never described in a misleading manner.
  4. Always take into account the level of knowledge, sophistication and maturity of the people we are marketing to, particularly children.
  5. Investigate any customer complaints about our products and react according to the findings of our investigation.
  6. Provide a readily accessible source of advice and guidance regarding our products and services.

These principles inform the design and development of products as well as the way that we retail and market products. This includes the way a product is positioned and promoted in store.

This Marketing Code of Practice provides the basis for internal guidelines that specify how our buying and marketing teams should implement the Code in the course of their work.

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Our Quality Commitment to Our Customers

At WHSmith we believe in putting the customer first which means we have to maintain and improve the high standards our customers have come to expect. This is not only important for delivering customer satisfaction but also makes good business sense.

This policy reflects our commitment to deliver quality products and services to our customers.

WHSmith will:

  1. Pursue a commitment to constantly improve the design, quality and safety of all our products to ensure suitability for customer use and market position.
  2. Comply fully with the minimum standards required by law for every product line we sell.
  3. Take appropriate actions on the feedback we receive from our customers to continually improve our overall product offer.
  4. Pursue a commitment to reduce avoidable costs associated with product quality and safety.


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Bribery Ethics Statement

WH Smith is one of the United Kingdom's leading stationers and booksellers.  We pride ourselves on our values and our commitment to acting with integrity throughout the organisation. WH Smith does not accept corruption in any form, and we will not tolerate it in our business or in those we do business with.

Our Code of Conduct sets out in detail how our colleagues should behave and what they should do if they are confronted with corruption.  We expect that all of them will embrace the Code and use it in all aspects of their day-to-day work.

In turn, we expect our suppliers and other business partners to act at all times in a professional and ethical manner. To that end, they shall: comply with all relevant laws, including, but not limited to, the Bribery Act 2010; not take any action or permit the taking of any action by a supplier or third party which may render WH Smith liable for a violation of any relevant law; not use money or other consideration paid by WH Smith for any unlawful purposes, and; upon request, be required to have their own subcontractors, consultants, agents or representatives execute a similar written anti-corruption compliance statement, and to confirm to WH Smith that such action has been taken.

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Tax Policy

The Business

WH Smith PLC is made up of two core businesses:

- WH Smith Travel operates mainly in airports, railway stations, motorway service areas, hospitals and work places. It sells a range of products to cater for people on the move or in need of a convenience offer. In addition to a significant presence in the UK, we now have 315 units outside the UK.

- Additionally on 30 November 2018, the Group completed its acquisition of InMotion Entertainment Group, a US airport-based electronics retailer, which has 112 units in the US.

- WH Smith High Street operates from 597 High Street stores, located in almost all the UK’s most significant high streets. It sells a wide range of stationery, books, newspapers, magazines and impulse products.

- WH Smith employs approximately 14,700 people.


WH Smith’s tax strategy supports the Group’s business strategy and commercial activity. Our principles seek to ensure:

1) The accurate and timely compliance with tax law;

2) Paying the right amount of tax, at the right time; and

3) Engaging proactively and openly with tax authorities.


We apply these principles through the following mechanisms:


The management of the Group’s tax affairs is delegated to the Group Tax Director, who is supported by a team of professionals whose members have the necessary experience, skills and qualifications to manage the Group’s tax affairs. The Group Tax Director reports the Group’s tax position to the Group Audit Committee on a regular basis.

The Chief Financial Officer (‘CFO’) is the Board member with executive responsibility for tax matters.

The ultimate responsibility for the Group’s tax strategy and compliance rests with the Board who ensures that the appropriate framework is in place to oversee the identification and management of tax risk. The Board is regularly appraised of all significant tax developments and participates in all material tax related decisions.

Tax Risk Management

The Group seeks to identify, evaluate, monitor and manage tax risks. Appropriately qualified professionals review the Group’s activities and processes to identify the key risks for different taxes and to ensure mitigating controls are put in place. These key risks are monitored for business and legislative changes which may impact them. Changes to processes or controls are made when required.

The Group Tax Department seeks to observe all applicable laws, rules, regulations and disclosure requirements in effectively managing the Group’s tax risk.

The Group’s aim is to pay the right amount of tax and at the right time.

Attitude to Tax Planning and Level of Risk

As a responsible tax payer the Group aims to support the commercial needs of the business by ensuring that the Group’s affairs are carried out in the most tax efficient manner and remain compliant with all relevant laws. All transactions must have a primary business purpose that is not tax driven.

The Group may seek to use reliefs and incentives where these comply with all applicable tax rules and regulations.

Relationship with Tax Authorities

The Group seeks to have an open and honest relationship with tax authorities and proactively engages with them on issues where there is potential for the tax treatment to be uncertain. When submitting tax computations and returns to tax authorities, we disclose all relevant facts.

The Group Tax Director maintains a dialogue with the Group’s Customer Relationship Manager at HMRC and a formal ‘Business Risk Review’ meeting takes place regularly.

Note: WH Smith regards this publication as complying with the duty under paragraph 16 (2), Schedule 19, Finance Act 2016.

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