Governance

Corporate Behaviour

Business ethics

Our commitment to the highest ethical standards means that the Group Risk Committee works to ensure these are communicated and upheld throughout the business. We believe in the rights of individuals and take our responsibilities to all our employees seriously and those who may be affected by our activities. During the year we updated the Group’s modern slavery and human trafficking policy, business ethics and conduct policy and ethical sourcing policy, all of which are available on the Group’s website. These policies form part of our way of doing business and are embedded in our operations. They are also communicated directly to employees through dedicated communication and training programmes.

Senior employees across the Group receive regular business ethics training to ensure they are aware of their obligations and responsibilities with regard to competing fairly, the UK Bribery Act and, in the US, the Foreign Corrupt Practices Act.  Anti-corruption and bribery policies are maintained and reviewed on a regular basis with relevant guidance incorporated into our employee handbooks and available on our intranet pages.  

Whistle-blowing 

Our confidential, third-party operated whistle-blowing service is available to all employees and third parties in both North America and the UK to raise any concerns that they may have about unethical or illegal behaviour, or potential breaches of our ethical policies. 

All whistle-blowing matters are investigated and outcomes are reported to the Board together with any action taken. Our approach is one of non-retaliation and we confirm that no employee will suffer any detriment from raising genuine concerns about ethical conduct. 

Cyber security

As the world continues to move online, accelerated due to the pandemic and increasingly connected technologies, at least in the short to medium term, awareness, monitoring and adaptability to cyber security issues is ever more crucial for us.  We are prioritising the monitoring of any potential cyber security vulnerabilities and working to ensure business continuity under all potential scenarios.