Robust governance remains at the core of our business and is a foundation of our sustainability agenda. We are committed to ethical and responsible behaviour in all aspects of what we do. Our industry is amongst the most highly regulated of any sector, and we always strive to comply with and often exceed the requirements of applicable laws and regulations.
Our Operational Framework sets out our approach as well as the policies, processes and standards to which we adhere, which apply everywhere we operate. Our Code of Conduct and ‘Supplier Principles – Guidance for Responsible Business’ outline expectations for all our employees and partners.
We support our employees in understanding the vital role they have to play in ensuring that we maintain the high standards of ethical conduct that our customers, shareholders, partners and colleagues expect. We have a zero tolerance policy regarding corruption in all its forms.
Our anti-corruption programme is designed to ensure adherence to all relevant legal and regulatory requirements recognising the bribery and corruption risks that are faced by the Company (see the Laws and regulations principal risk on page 125 of our Annual Report 2022). The programme also provides our employees with practical guidance, helps them to understand what is expected of them and creates an environment in which they feel they can confidently, and confidentially if needed, ask questions and raise issues and concerns.
We continually check and test the effectiveness of our programme receiving both internal and external oversight and assurance, including encouraging feedback internally from our employees and externally from independent third parties. Risk-based due diligence procedures have been implemented to address bribery, corruption and other financial and non-financial risk, and our policies include processes for risk-based internal and external approvals, ongoing monitoring and repeat due diligence.
We drive improvements in the programme annually to ensure it continues to meet best practice. Our anti-corruption programme also includes our Code of Conduct and ethics training.
Employee ethics programme
Our global Code of Conduct lays out the standards and behaviours that are expected of all employees. It guides them in acting responsibly and ethically in everything they do and outlines the ways in which they can seek help and guidance. Our Code is supported by a training and engagement programme to empower them to make ethical decisions. All employees are required to complete ethics training annually alongside e-learning programmes of role-specific training, for example, export controls.
In 2022, 98.4% of our employees completed our ethics training, with the majority of those who did not complete it being employees on secondment, maternity leave, sick leave or other long-term absence. These employees will complete their training on their return to the business.
We engage employees throughout the year on ethics and responsible business. In the US, we produce monthly ‘Ethics Minute’ messages to communicate directly with employees on a range of topics, including workplace respect, creating a culture that speaks up to address issues, reinforcing anti-retaliation, and handling gifts and hospitality, among others. In the UK, we produce regular ethics and compliance communications to spotlight particular areas including gifts and hospitality, security and export controls. We also actively promote our Ethics Officers and Ethics Helpline, to help ensure employees feel they can raise issues and seek guidance in person and in confidence.