Our Standards of Business Conduct compliance
Monitoring our adherence
Our Standards of Business Conduct (SoBC) apply to all our Group companies and employees.
Employees are required to report any instances of non-compliance and managers are required to take appropriate disciplinary action in cases of non-compliance. Retaliation against employees for reporting information or raising questions about possible violations is itself a breach of the Standards.
Any allegations are investigated internally and strong action is taken where necessary.
All business units worldwide complete an annual self-assessment against our key audit controls, in which they confirm they have adequate procedures in place to support SoBC compliance.
In addition, all staff working across the Group are required to complete an annual sign-off, confirming their commitment and adherence to the SoBC and disclosing and/or updating any personal conflicts of interest.
Continuous information on compliance with the Standards through the year is gathered at a global level and reported to the Regional Audit and CSR committees, and quarterly to the Board Audit Committee.
All Group companies have adopted the SoBC or local equivalent.
In 2021 over 24,000 Group company employees completed our annual SoBC sign-off online in the SoBC portal, including an e-learning with scenarios covering New Categories compliance risks in the areas of competition and antitrust, modern slavery, child labour, engaging with Public Officials, handling confidential information, and processing consumers’ personal data. Over 25,000 other Group company employees and contractors who do not have easy online access, completed the SoBC sign-off ‘offline’, of which just over 14,000 signed off via the SoBC app.
In our 2021 global ‘Your Voice’ survey, completed by 93% of Group company employees, 79% of employees again strongly agreed that they “can report concerns about actual or suspected wrongdoing at work without fear of reprisal”; 1% higher than the FMCG comparator norm.
Not all contacts made via our SoBC portal involve SoBC allegations; some relate to questions regarding the SoBC or other matters.
In 2021 there were 581 contacts (2020:554), of which 304 were assessed as alleged SoBC breaches, including 145 contacts where the person raising the case chose to remain anonymous.
For the detailed investigations conducted into all of the reported cases in 2021:
- No wrongdoing was found in 154 cases (2020:158).
- 99 cases were established as breaches, and appropriate action taken (2020:116).
We take strong action for all cases established as breaches, which will vary from case to case depending on the circumstances. In 2021, established SoBC breaches resulted in 46 people leaving the Group, and 72 written warnings.
The appropriate action will vary from case to case but will include, depending on the circumstances, disciplinary action or dismissal. Where criminal activity is believed to be involved, the matter will generally be reported to the relevant authorities. Where any weakness in internal controls is identified, appropriate measures are taken to strengthen them.