Contributing to national and local economies
Public transport is vital to building a strong and sustainable economy. Our services have continued to ensure that millions of people are able to get to work and access key services. Over the past year Go-Ahead has made a significant contribution to the UK economy through the 27,000 people we employ, the £77.6m generated by our rail operations for the government, and £34.1m paid in corporation tax. We are also pleased to have introduced the voluntary Living Wage as a minimum, irrespective of age, across the entire Group.
Being part of the local community underpins Go-Ahead’s devolved management approach and enables our bus and rail companies to be more responsive to the different needs that different passengers have.
We have long-standing partnerships with community organisations in the areas where our companies provide transport services. Our operating companies make a big contribution to their local communities and have built mutually beneficial relationships over time; such as the ten-year partnership between rail company Southern and the Sussex Community Rail Partnership or Go South Coast’s Alzheimer Society’s dementia friends initiative credentials gained over the past several years.
Activities such as these demonstrate the importance of measuring the impact of our community activities across the Group so we can further develop our community investment programmes.
Greenhouse gas emissions
We report on greenhouse gas (GHG) emissions in accordance with the GHG Protocol Corporate Accounting and Reporting Standard and the UK Government’s Environmental Reporting Guidance methodologies together with the emissions conversion factors from DEFRA/ DECC GHG conversion factors for Company Reporting 2015. In line with this guidance, we have reported the emissions sources* that are required. These sources fall within businesses included in our consolidated financial statements.
Emissions are expressed in terms of equivalent carbon dioxide (CO2e). Our relative performance metric is kilogrammes of CO2e emissions per passenger journey.
Overall, CO2 emissions in absolute terms have increased as a result of business acquisitions but CO2 emissions per passenger journey have decreased largely due to improved efficiency in the use of traction electricity.
* Emissions from air conditioning equipment in our premises and vehicles are not included in this analysis due to the difficulty in obtaining this data .These emissions account for less than 0.5% of our total GHG emissions and are therefore not considered material
|Kgs CO2 per passenger journey||0.82||0.84||0.85|
|Scope 1||CO2e tonnes ('000)||CO2e tonnes ('000)
||CO2e tonnes ('000)|
|Passenger journeys (m)||1,297.23||1,241.20||1,152.6|
|Gas (buses) kwhs (m)||6.3||6.9||1.3||7.3|
|Gas (premises) kwhs (m)||51.0||9.4||54.5||10||42.3||9.2|
|Bus diesel (10% bio-diesel blend) ptrs (m)||130.3||340.2||127.6||329.8||128.1||333.4|
|Rail diesel ptrs (m)||18.6||55.1||18.4||53.5||17.7||51.8|
|Traction electricity kwhs1 (m)||1,368.9||564.1||1,169.3||540.4||1,002.1||495.3|
|Site electricity kwhs (m)||104.8||43.2||100.3||39.4||85.1||42.1|
|Electric buses kwhs (m)||0.07||0.03||n/a||n/a|
|Electricity - transmission and distribution losses within the grid||54.9||44.6||47.0|
|Outside of scopes|
|Biogenic content of bio-diesel2||7.9||11.0||8.0|
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1. Traction electricity consumption data relates to the period from 1 April 2015 to 31 March 2016. This provides the most accurate figure for consumption.
2. The biogenic content of bio-diesel is considered outside scope as there is no conversion factor for our baseline year. Emissions from this source are reported for 2015/16 but are excluded from the calculation of our relative performance metric as comparative data is not available. We define our organisational reporting boundary by applying the financial control approach with a materiality threshold set at 5%.
Carbon Trust Standard triple accreditation
Go-Ahead has become the first transport group to receive the triple award accreditation from the Carbon Trust for achievements in carbon, water and waste reduction.
We have a reputation as a leading organisation when it comes to environmental responsibility and sustainability. We believe that our approach can give us competitive advantage as well as saving money and reducing our impact on the environment.
In 2008, we became the first public transport company in the UK to be officially certified by the Carbon Trust Standard for carbon after taking action on climate change. We were also the first in the sector to be recertified in 2011.
Watch our video to find out more about Go-Ahead initiatives to reduce carbon emmissions, water and waste:
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Go-Learn education programme
Go-Learn is Go-Ahead’s online education programme aimed at helping children and young people improve their knowledge of public transport to become confident and informed travellers.
The material assists youngsters aged from four to 14 to develop skills and confidence for independent travel. Mapped against the National Curriculum, the resources can be used by parents and teachers to support literacy, numeracy, citizenship and elements of personal, social and health education.
Sarah Clayton, head teacher at St Joseph’s school in Brighton said: "Equipping young people with the skills they need to use public transport safely and responsibly should be on every school’s agenda. The Go-Learn materials give teachers a range of useful tools which will get young people thinking about how bus and trains work and will really capture their interest."
Go-Learn complements the work already carried out by Go-Ahead's bus and rail companies, many of which work with local schools. Plymouth Citybus’s ‘Dennis Dart’ programme is well established in many of the city’s primary schools promoting road safety and encouraging safe bus use. Similarly, train operator GTR uses locally-branded Go-Learn material with its Thameslink and Southern routes, as do bus companies Brighton & Hove and Metrobus.
Installing on-train meters on Southern’s trains now means that the company can be more accurate when forecasting the electricity it consumes and budgeting to cover the cost of that energy.
Prior to installing the meters, Southern – like the majority of electric train operating companies – would be charged by Network Rail for estimated energy consumption based on modelled rates. Every year estimated and actual consumption would be reconciled and any outstanding costs paid or money returned.
On-train meters also enable Southern to identify more efficient ways of driving. Drivers are instructed to 'coast' on particular sections of the network - using the train’s own momentum to reduce electricity consumption. This energy-efficient driving contributes towards Go-Ahead's continual aim of cutting carbon emissions and reducing costs.
Improving every customer's journey
Walking in our customers’ shoes, we have identified where we can improve the experience they have of our services.
We have detailed action plans to deliver enhancements across:
• planning and researching journey options
• buying tickets
• boarding the bus or train
• getting help from our staff or through information channels
• completing the onward journey
• contacting customer services, clearing delay repay or locating lost property.
Our new vision helps the Group to create an aspirational version of what the future will be like for customers; the ideal customer experience where every journey is taken care of. Our commercial bus companies work hard to attract and retain customers and we are proud that for another year we have achieved leading national ratings of 90% customer satisfaction in the national bus passenger survey. Features that many of our services outside London have, such as onboard Wifi, USB phone charging points, and new way-finding apps all assist to increase satisfaction. As expectations increase we need to be agile and find new ways to take care of every aspect of journeys and deliver even better experiences.
We also appreciate that every customer is unique, so has different needs and expectations, increasing personalisation is key to people feeling taken care of. Whether it is an ‘app’ remembering a passenger’s ‘home’ station, a customer service system automatically calculating a refund that is due, or a bus driver recognising the signs that a customer may have dementia and responding appropriately, it is increasingly important to offer a personal service that suits the needs of the individual.
We are investing in technology, and through our industry groups, working with information technology companies to build a substantial portfolio of innovative transport apps. Providing information at people’s fingertips helps people make decisions about their journeys from start to finish. We know every minute counts for many of our customers, and providing people with the best information is essential to building trust
Driving change through technology
Value for money and making it as easy and convenient as possible to pay for travel are a significant element of Go-Ahead’s mission to take care of each passenger’s journey. As well as providing WiFi and USB charging points, it’s important that all other aspects of our bus services remain in line with customers’ expectations.
Several years ago, Go-Ahead’s smartcard “the Key” led the way for the industry to introduce smart ticketing. Now, more than three quarters of all retail spending in the UK is made using contactless payment cards, so in the past year we introduced technology to support the next generation of contactless payments across our regional bus division. A range of options, including Visa, Mastercard, Apple Pay and Android Pay, can now be used by customers on most of our regional bus services. We are the first bus operator to introduce the UK Cards Association’s aggregated pay as you go ‘model 2’.
Unlike other major operators that can only accept ‘flat fare’ transactions, ours has the ability to sell London Oyster-style ‘pay as you go’ ticketing. Multiple trip fares are calculated and capped, meaning customers can make several journeys with payment transactions aggregated into a single debit from their account, based on the best fare available. Go-Ahead will soon be operating the largest transport contactless payment scheme outside London, using ‘model 2’. This project has been delivered in collaborative partnership with UK software and hardware company Ticketer and Australian fintech start-up Littlepay.
Taking care of our customers
Our vision focuses on taking care of customers’ journeys, from start to finish. We recognise that it’s impossible to deliver our vision alone and so we rely on partners, such as local authorities and Network Rail, to ensure road and rail infrastructure is properly maintained, to allow us to run reliable services.
We aim to increase passenger satisfaction through strong, collaborative partnerships with these key stakeholders, together with a clear focus on factors within our direct control. Our regional bus business continues to lead our sector in customer satisfaction, with a high score of 90%, as measured by the independent passenger watchdog, Transport Focus. Findings indicate that one of the most important drivers of satisfaction is the attitude of the bus driver. We’re proud that scores across all our regional bus companies recognised the helpfulness and friendliness of our drivers and we continue to invest in recruitment, training, development and wellbeing programmes to ensure this remains the case.
Transport Focus also praised Southeastern for its improved customer satisfaction levels, up 10ppts to 82% in the spring 2017 national rail passenger survey, and also noted improving results on the Gatwick Express and Southern routes. Southeastern attributes success in this area to ensuring employee and union representative involvement as active partners in projects aimed at improving customer experience. Charing Cross station’s wellreceived ‘customer ambassadors’ are there to look after customers and provide on-the-spot assistance. As well as giving train service information, they arrange taxis, provide coffee vouchers, and issue immediate compensation to people whose journeys have been delayed. Involving the whole station team, encouraging ticket office colleagues to come out from behind ticket office windows at quiet times to take a more proactive approach to helping customers. Elements of this successful customer-focused initiative are being rolled out at other key stations across our rail business. Passengers’ expectations are always rising.
As rail services are modernised with the arrival of new trains, improved technology and modern working practices, there is greater expectation that staff will be on hand to assist customers. We are pleased that the increased number of on-board supervisors assisting Southern customers has led to better experiences for passengers, reflected in the latest satisfaction scores. Despite the impact of industrial relations issues on many services, there was a marked increase in levels of satisfaction customers felt with the availability and helpfulness of staff.
An important element of public transport is providing an inclusive service. Whether customers are using wheelchairs or mobility scooters, have difficulty walking, are pregnant or travelling with young children, or have learning difficulties or mental health issues – all our bus and rail companies strive to make their services as accessible as possible to everyone.
We invest approximately up to £80m per annum in new buses and this year all vehicles acquired have audible announcements and electronic visual signage (AV) onboard, also we have made a commitment that future purchases will be fitted with AV. Our bus companies have signed up to the RNIB charter, using the ‘Stop for Me, Speak to Me’ training material to help drivers appreciate some of the experiences and problems blind and partially sighted people face.
We continue to deepen our people’s understanding of the issues facing customer with dementia and – particularly in the coastal areas we serve which have higher percentages of elderly people – have used the Dementia Friend training along with other accessibility training to positive effect. Practical ways to assist passengers with hidden disabilities, such as the introduction of ‘helping hand cards’ at many of our operating companies, enables us to provide a more personal service. The Samaritans work with our train companies to promote mental health and wellbeing and also, as part of their ‘safeguarding’ programme, to assist identifying young people who may bevulnerable and at risk.
All our trains are wholly accessible for users of wheelchairs, but there is still some way to go before most stations have step-free access as many stations were built at a time when step-free accessibility was not a consideration. However, many of the barriers to increasing accessibility of our bus and train services are not physical ones, and can be overcome with increased employee awareness and training.
On Track rail app
Go-Ahead’s rail app On Track is considered one of the best rail-journey-planning apps in the UK, providing customers with the ability to look up train times, buy rail tickets and find out to the minute how rail services are running.
Built in collaboration with rail passengers, On Track provides rail passengers with all that is needed to plan a journey: identifying nearest stations, buying train and car park tickets and real-time train-running information. It also gives one-touch email or phone contact to customer services and allows passengers to claim compensation if their journey is delayed.
Integrated and accessible travel
We are mindful that the majority of people’s journeys don’t start and end with a bus or train ride and our aim is to deliver integrated transport solutions where we: provide accurate, real-time information about delayed services by developing apps; make purchasing tickets as simple as possible with smartcards and mobile tickets; and make contacting or claiming compensation for delayed journeys as simple as possible.
Public transport should be accessible for all those who wish to use it - cycle hire schemes and bike storage provision at stations along with good walking routes to and from stations are ways we work with our partners to make them easier places to access.
We also know that by considering people with audio, visual and other physical limitations we will be improving the service for all passengers. We are increasing audible announcements and information screens on board our trains and buses and all our buses and trains are accessible to wheelchair users. Many of our hundreds of railway stations were built at a time when accessibility was not a consideration, so, together with Network Rail and local authorities, there is a programme of installing ramps and lifts to make stations step-free. Priority is given to stations that have the most of passengers using them and where we are successful in securing local authority and government grants. All our customer-facing employees have training in disability awareness using the social model of disability – appreciating that it’s our responsibility to remove the barriers that restrict people from using our public transport services.
Go-Ahead is leading the way as a transport company in using social media. Twitter and Facebook are widely used across our bus and rail companies to keep passengers updated with service-running information and latest product and ticket offers. Social media platforms also enable our passengers to exchange information and views about our services.
All our bus and rail companies provide customer service through social media from first thing in the morning to last thing at night.
Go-Ahead's businesses have identified ways of using social media to interact with staff, many of whom use social media in their daily lives. Southeastern created an internal dedicated business and social network for its 3,800 employees called 'Workmate', and the rest of our rail and bus companies have followed suit with similar portals.
In addition to the range of award-winning social media activity already underway in our bus and rail companies, Go-Ahead Group has a Twitter and LinkedIn accounts to update followers about the Group’s operations. You can follow Go-Ahead
Mobile ticketing and smartcards
Go-Ahead continues to invest in smarter ways to improve the service we offer customers to make it as easy as possible for them to travel with us. We operate the largest smartcard scheme outside London’s Oyster and were one of the first in the sector to introduce mobile ticketing (m-ticketing).
Through smartcards and m-ticketing we have a greater understanding of our customers’ behaviour and preferences and we are able to communicate with many of them in a more personalised way.
Our online customer database can be used for effective, targeted marketing campaigns across our bus and rail businesses and now has almost four million registered customers.
The data gathered through this channel enables us to gain a fuller understanding of passengers’ travel habits and purchase preferences. This means we can provide them with relevant information and products to suit their needs.
Living our vision
A world where every journey is taken care of – is our new Group vision. It is future focused, aspirational and puts customers at the heart of our business. It sets out where we want to be.
Creating our vision has been a collaboration between colleagues across the organisation and external stakeholders including customers. We know it is important that this is not just an exercise to refresh the words we use but that they make a tangible difference to how our people feel about working at Group, how customers experience the service we offer and a point of differentiation from our peers.
The vision is a continual reminder that we are an organisation that provides a valuable public transport service for people rather than just being operational logistics experts. The act of taking care of people’s journeys resonates with our employees and is a common purpose for everyone in the Group.
Embedding the new vision, behaviours and attitudes across the organisation is underway – our policies, procedures, KPIs and contracts are all being re-drafted to align the organisation with our vision so that we are agile and responsive to meeting our customer needs. We have launched a programme entitled ‘going forward together’ to deliver the key changes we need to put in place in all our operating companies to continue to grow, deliver better value for money and provide a good service for customers. Facilitated workshop sessions have been held at all operating companies to ensure consistency of approach and language throughout the business. Action plans and commitments are part of our ‘better together’ sessions with leaders and managers accountable for overseeing delivery.
The new vision, beliefs and attitudes help us meet our shared goals and objectives in a way that we have mutually agreed is how we wish to behave and be seen to behave. With these strong values in place, the organisation will support the right behaviours and challenge those that go against them. Like other successful organisations we will use our values and behaviours to govern decision making. Our leaders and senior managers play a crucial role in assisting others to do this.
Delivering improved efficiencies and greater agility will help us to be one step ahead of the competition and continue to invest in the future. We know that by working together we will be able to create a truly customer-focused collaborative workplace and through that deliver growth. Passengers will benefit from better services; customers and our supply chain will benefit from increased responsiveness and improved value for money; our people will benefit through greater opportunities across the Group; and our shareholders will benefit in our success.
Succession planning is an important part of running a responsible sustainable business and our people plans include several schemes to ensure colleagues have opportunities for full and successful careers within the Group. We have a strong talent programme where individuals with potential are encouraged to work on projects and take secondments in other areas of the Group to deepen their understanding of the industry.
Go-Ahead bus division’s two year graduate scheme, launched in 2013, has now successfully seen 21 graduates go through the programme and six take management roles. The scheme built on the Group’s well established engineering scheme and broadened the scope to include high calibre individuals enthusiastic about transport, who were commercially aware with strong leadership potential. Participants focus on the operational aspects of company management and have the opportunity to work across all areas of the business including driving, contract and project management, marketing and stakeholder relations. A coaching approach underpins the scheme and MDs and operations directors act as mentors for the graduates.
For the past few years our rail division has taken part in the industry’s ‘track and train’ scheme providing all-round experience for graduates. In the past year we have introduced our own Govia graduate scheme with five graduates in 2015/16 and in line with our effort to increase gender diversity across our business, two women are part of the cohort.
Investors in People
The Go-Ahead Group head office has been recognised as an Investor in People (IiP) and has achieved the Gold award. The IiP framework is used to measure and assess an organisation’s commitment to achievement through its employees and to accepting that people’s strengths, ambitions and ideas are the engine of success. Particular strengths highlighted in the assessment included the quality of leadership, level of employee engagement and involvement and commitment to continuous improvement.
Listening to our people
Two-way communication is key to making Go-Ahead a great place to work. All our operating companies have internal mechanisms to make sure employee ‘voice’ is heard loud and clear. Employee phone-ins, staff panels, forums with management teams, employee surveys and online interactive feedback tools are just some of the ways that we make sure that employee views and suggestions are listened to.
Southeastern became the first train operating company in the UK to provide a social networking tool for its 3,800 employees to share information and discuss work-related issues with colleagues. The site, Workmate, means staff can interact with each other in the way that many of them already do with friends and family on sites like facebook and twitter. Workmate enables Southeastern to provide better service to customers – if an employee posts a question the site, there are hundreds and thousands of colleagues who have the power and ability to instantly respond with the answer.
In our bus division, our largest company Go-Ahead London has launched a ‘Have Your Say’ forum on its employee website which enables all 7,000 staff to post questions, feedback and opinions. Managers, including directors, are involved in responding to questions, with the aim to reply within 48 hours.
We also listen to the views of our people through our consistent employee surveys. Over the past few years we have been undertaking an annual employee survey across the Group’s head office and our subsidiary companies in order to continually identify ways to make Go-Ahead a better place to work.
Southeastern’s award winning 50,000 page Wikipedia site, developed and built by the company’s engineering team, features technical processes and manuals and 30,000 images – everything the technicians need to maintain the organisation’s 400 strong train fleet.
Maintaining a large fleet of trains for one of the most demanding commuter networks in the UK is challenging. Almost every train is in passenger service every day, so the smallest delay in a depot could result in cancelled services. Moving to a paperless system has resulted in significant time savings and improved efficiencies.
Having seen the benefits Southeastern’s innovative system has delivered, other train operators and even aviation companies are looking to replicate its success. The wiki was awarded ‘Small Scale Project of the Year’ at the Railway Industry Innovation Awards and also won accolades at the National Rail Awards and the National Transport Awards.
Continuous development of our leaders
In line with best practice and good corporate governance, the Board is required to undertake a formal evaluation each year to help continually improve its effectiveness. This year as part of the Group-wide culture change programme, Go-Ahead’s Board has considered the personal development of each member in the wider context of the Board’s overall effectiveness. The programme, which runs over several months, and is still ongoing, includes interviews, surveys, data analysis, personal coaching and feedback sessions, as well as a two-day off-site session to foster stronger relationships between Board members. Challenging conversations in a supportive and constructive environment have resulted in a commitment to make better use of the relationships between executive and non-executive directors.
Changing culture through collaboration
Adopting the Group’s vision, beliefs and attitudes has had a tangible, positive impact on the engagement, morale and working practices across the business, particularly at one of the Group’s largest companies: Go-Ahead London. With 7,000 employees and five different companies under the Go-Ahead London umbrella, all with slightly different employment terms, conditions and working practices, there were initial reservations about the effectiveness of any one-size-fits-all approach to culture change. However, the desire to work as ‘one Go-Ahead London’ overrode any misgivings and, since the beginning of the year, more than 650 managers and supervisors have had interactive sessions to discuss the values with the senior management team, as well as being encouraged to do what they can to make the business a better place to work. Culture change Changing culture through collaboration Customer experience Taking care of our customers OUR CHANGE THEMES CONTINUED All 7,000 employees have taken part in training and development sessions on the Group’s vision, beliefs and attitudes, diversity and inclusion workshops, and sessions designed to improve communication skills. As a result, a culture of ongoing engagement has developed across the organisation. In addition to Go-Ahead London’s specific programmes, all drivers are taking part in TfL’s ‘Hello London’ customer service training. The combined effect of these initiatives has been greater engagement and better two-way communication, embodying Go-Ahead’s ‘can-do’ attitude. Progress has been seen across the business, with a 12% reduction in costs associated with driver shift overruns. QICs payments have risen in the period, with a connection being made between this strong performance and the change in culture. Our Group-wide vision, beliefs and attitudes are ties that bind all our operating companies together and, in a devolved management structure, ensure that all employees are working to the same common purpose: to take care of customers’ journeys.
Leaning into change
We are adopting lean working methods across all of the Group’s engineering departments, to ensure depots are structured in a way that best supports the needs of the business. Lean is a set of management tools and processes which encourages continual review and change. It ensures there is a focus on improving important operational areas, eliminating inefficient practices and reducing waste. As a result, this means all working practices are reviewed and altered where needed. As waste is reduced, productivity is increased and costs are rationalised. In line with the Group’s collaborative approach, this process encourages the establishment of long term relationships and partnership arrangements with suppliers. Our bus company, Brighton & Hove, has transformed its engineering function through the introduction of lean processes which have led to streamlined costs, better fleet and scheduling management, and also improved operational performances. Through the adoption of lean working, remarkable improvements have been delivered. These include a reduction in spare capacity in vehicles, stock and employee time, cutting ‘dead mileage’ and drastically improving MOT performance. At Brighton & Hove, involving the trade unions in the change programme from the outset meant new employee shift patterns and working practices were introduced without concerns being raised. The fundamental principle behind lean is continuous improvement, so there is ongoing dialogue with colleagues and union representatives to keep improving operations and enable innovation and evolution. While the Group’s engineering functions are the first to adopt a lean approach, the ethos that underpins it is common to other areas. Developing individuals through team problem-solving is about engaging colleagues and encouraging their contribution to the success of the team’s overall performance. Our operating companies understand that their strong performance at a local level ultimately leads to the overall success of Go-Ahead.
Focused on accountability
We continue to be one of the few FTSE 250 companies with the Fair Tax Mark – something that we were the first in the FTSE 350 to be accredited with at the scheme’s launch in 2014. The Board continues to work towards being assessed as ‘low risk’ by HMRC and ensure that we adhere to our policy of not undertaking tax planning or making use of tax havens.
Our devolved approach
Our devolved approach enables us to build management accountability at operating company level. It means that decisions can be taken locally about where to re-invest to deliver the maximum benefit for customers. A significant portion of our profits are reinvested in the business to increase opportunities for growth as well as drive further efficiency. Organisational efficiency programmes include upgrading IT systems and moving all Group companies to one enterprise platform. Our central procurement department achieves cost savings through negotiations on behalf of our operating companies and our central marketing function adds value by negotiating advertising space nationally rather than at individual company level.
Our central procurement division has successfully delivered savings in the region of £4m across a range of contracts. For example the team has negotiated a telecommunications data contract leveraging the scale of our UK wide operations and the growing desirability of having Wifi service onboard our buses and trains and at stations.
Our suppliers play a strong role in helping us deliver our strategy and we aim to get the most from them. We aim to choose companies who act ethically and responsibly and by working in partnership with our suppliers we have continued to reduce our carbon, water and waste emissions. We have also signed up to the prompt payment code and follow the principles of the government’s better payment practice code.
Over the last few years we have invested in establishing a central services IT helpdesk team offering our operating companies 24 hour technical support. This shared service centre allows employees to log all faults ranging from a problem with equipment such as station ticket vending machines through to getting assistance over the phone or via online chat with a computer software problem or query.
A sustainable option
Go-Ahead has been commended by ethical funds on the corporate social responsibility information we publish, making it easier for investors to determine whether the Group meets the investment requirements of ethical funds. Recently, Kempen Capital Management (KCM) Ethical Funds has commended Go-Ahead on its sustainability information saying there was an ‘increased demonstration of business ethics performance due to introducing a corporate-wide code of conduct’.