Standards of Business Conduct
Defining our corporate behaviour
Conducting our business with honesty, integrity and transparency is not only the right thing to do, it is also critical to building A Better Tomorrow™ responsibly and sustainably.
A key driver to delivering our A Better Tomorrow™ purpose is our ethos. This sets out our values and guides our culture and behaviours across the entire Group. Five key behaviours underpin our ethos. These are: bold, fast, empowered, diverse and responsible.
The values and behaviours expressed by our ethos are enshrined in our Standards of Business Conduct (SoBC), which set out the high standards of integrity we are committed to upholding, provide guidance on workplace situations, and ensure we deliver our business results with integrity.
Our Standards of Business Conduct have been in place since the early 1990s. Every Group company and all staff worldwide are expected to live up to them and to ensure our business standards are never compromised for the sake of results.
We conduct a detailed review of our SoBC and Supplier Code of Conduct every two years to ensure they remain at the forefront of best practice, with the most recent review taking place in 2021.
What our Standards cover
Our Standards of Business Conduct set out the Group policy, and provide guidance to staff, in the following specific areas:
- Speak Up
- Our people: respect in the workplace
- Human rights
- Health, safety and welfare
- Conflicts of interest
- Anti-bribery and corruption
- Gifts and entertainment
- Lobbying and engagement
- Political contributions
- Community investment
- Accurate accounting and record-keeping
- Protection of corporate assets
- Data privacy, confidentiality and information security
- Insider dealing and market abuse
- Competition and antitrust
- Sanctions and export controls
- Anti-illicit trade in the Group’s products
- Anti-tax evasion and anti-money laundering
Our Standards of Business Conduct are available in multiple languages
Regularly reviewed and updated
In 2021 we included a dedicated Health, safety and welfare policy, as well as a new Environment policy to reflect the Group’s commitment to environmental sustainability. We also made further updates to a number of key global polices, to keep pace with the external environment and reflect areas identified for improvement following external benchmarking.
The amendments include:
- Emphasising that Speak Up is applicable to supply chain workers and other third parties;
- Adding Modern Slavery to the expressed list of wrongdoings to highlight that any such allegations will be treated seriously and investigated as potential breaches of the SoBC;
- Replacing the ‘No reprisal’ with ‘Protection for those who Speak Up’, to aid understanding;
- Highlighting the fact that people can report wrongdoing anonymously if they wish;
- Expanding the list of protected characteristics to include ethnicity, gender identity, gender reassignment, marital status, pregnancy status and trade union membership, to further reflect our commitment to diversity and inclusion;
- Including a dedicated Health, safety and welfare policy to highlight our commitment to comply with the ILO’s Occupational Safety and Health Management Systems and ISO 45001 Occupational Health & Safety Management;
- Simplifying our Conflicts of interest, Anti-bribery and corruption, and Gifts and entertainment (G&E) policies;
- Renaming our Charitable contributions policy, and enhancing it to reflect the Group Community Investment policy;
- Enhancing our Data privacy, confidentiality and information security policy to reflect increasing focus on cyber security;
- Amending our Competition and antitrust policy to include definition of collusion and highlight risk areas such as ‘no hire’ agreements and salary info exchange;
- Expanding our Sanctions policy to include ‘export controls’, and amended to reflect the updated Sanctions Compliance Procedure; and
- Amending our Anti-tax evasion and money laundering policy to further build understanding and awareness of red flags.
We have also updated our SoBC Assurance Procedure, which complements our SoBC by setting out in more detail how allegations of wrongdoing or breach of the SoBC should be followed up to ensure that they are dealt with fairly and objectively.
Anti-bribery and corruption policy
Corruption causes distortion in markets and harms economic, social and political development, particularly in developing countries. Our Standards of Business Conduct make clear that it is wholly unacceptable for our companies and employees to be involved or implicated in any way in corrupt practices. It is our policy that Group companies and their employees must ensure that:
- They do not offer, promise or give any gift, payment or other benefit to any person (directly or indirectly), to induce or reward improper conduct or directly or indirectly influence any decision by any person to our advantage;
- They do not solicit, accept, agree to accept or receive any gift, payment or other advantage from any person (directly or indirectly) as a reward or inducement for improper conduct or which influences, or gives the impression that it is intended to influence, decisions of the Group; and
- Their activities do not otherwise contravene any applicable anti-corruption measures.
Each Group company is required to maintain, as part of its books of account, a register of political donations, gifts, community investment and non-commercial sponsorships made by or on behalf of the company. Agents, consultants and other third parties engaged on behalf of any Group company are expected to apply standards of business conduct consistent with our Supplier Code.
Confidential Speak Up procedures
The Group’s Speak Up policy contained within our Standards enables staff to speak up and raise concerns, in confidence, about possible wrongdoing or breaches of our Standards, and to do so without fear of reprisal.
Raising concerns and reporting
Staff can raise concerns with their line manager, HR or one of the Group’s Designated Officers. Alternatively, they can use our confidential, independently managed external Speak Up channels via telephone or online. Our Speak Up channels are available 24 hours a day in local languages and are highlighted in our internal trainings and communications.
Our business partners are also welcome to report their concerns and can do so via our Speak Up portal, the details of which are available to suppliers.
The Audit Committee receives regular reports on Speak Up allegations, and remains satisfied that the policy and procedures in place incorporate arrangements for the proportionate and independent investigation of matters raised and for the appropriate follow-up action.
The link to our Speak Up whistleblowing portal is available below:
All Group companies have adopted our Standards of Business Conduct or local policies reflecting our SoBC. Information on compliance with the Standards is gathered at a global level and reported quarterly to the Audit Committee. For more information, including compliance figures, see Our Standards of Business Conduct compliance.
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