Running our business in an ethical way makes business sense
Absolute integrity underpins our approach to responsible business practice, helping us to deliver sustainable growth.
Training, engagement and support
Our engagement strategy focusses on raising awareness among employees that running our business in an ethical way makes good business sense and providing relevant, practical training to help them with ethical decision-making.
Our ethics training and engagement strategy comprises:
- Values and risk-based training
- Interactive and engaging
- Delivery by senior and line managers
- Face-to-face wherever feasible
- On-line modules to reinforce awareness
- New employees, including those who join the Group following an acquisition, receive training on the Code of Business Ethics (‘the Code’) and other relevant topics within six months of joining.
During 2015, refresher anti-bribery workshops were held in a number of locations across the Group to reinforce key messages. A number of training initiatives on ethical decision-making and working together were also deployed at a number of our operating companies.
In addition, following the results of our 2014 Ethics Survey, we held follow-up meetings with employees in a number of territories to better understand the feedback received and to identify improvements to the programme. A number of actions have been identified, such as reinforcing local leadership for ethics and integrity, and consideration will be given to introducing new training formats and content for 2016.
Following the launch of our fair competition training programme in 2014, face-to-face training has been delivered to around 2,000 employees in senior management, business development, sales, marketing, procurement, customer support, legal and contract management roles across the Group to date. This training was supported by a fair competition e-learning training course which was launched to around 3,000 employees. In 2016, a further module focussed on vertical agreements will be deployed across the Group.
A bespoke Code of Business Ethics e-learning training course will be launched in 2016 to provide additional interactive training for new and existing employees throughout the Group. We remain focussed on values and risk-based engagement and are dedicated to facilitating discussion between all employees in order to build an environment in which employees feel empowered to act according to our shared values.
When a new business joins the Group, we work with the management team to ensure that our ethics programme is rolled out as a priority. A leadership engagement session was held at ESG’s head office in Kingston, Canada, in March 2015 where the management team received training on our Code. An anti-bribery and corruption module was also deployed to relevant employees, and Group standards on gifts, hospitality and entertainment and third-party due diligence have been implemented. A similar process of integration is now underway at Spectraseis, a business acquired in October 2015 which is being integrated into ESG.
A culture of openness and support
We actively encourage a culture of openness, engagement and communication, so employees feel they can discuss any issues that arise in the course of their work, and raise any concerns with their managers. Our independent Hotline (www.spectrishotline.com) gives our people, business partners and other third parties the ability to report concerns anonymously if they wish. All reports are followed up and investigated and the results are communicated to the Audit and Risk Committee every six months. We make a commitment to protect the careers and reputations of employees who report wrongdoing, as long as they do so in good faith and in the best interests of the Group.
During 2015, 18 reports were received via the Hotline and other sources. In each case, reports were investigated and resolved and additional guidance, training and monitoring made available or disciplinary action taken, as appropriate.
The ethical environment in certain Asian countries continues to be challenging in relation to conflicts of interests and fair competition. As a result, actions will be taken in 2016 to strengthen our control framework. A number of issues have been brought to our attention by our employees in the region which have been investigated, and we are encouraged by their willingness to raise their concerns.
Anti-bribery and corruption
A number of actions were taken during the year to strengthen our anti-bribery and corruption compliance framework.
In relation to our third-party management programme, initially addressing our sales channel, comprehensive training was delivered to help reinforce the knowledge and skills of our sales teams and senior management who conduct due diligence and engage with our strategic partners. This strengthens our commitment to an appropriate and effective assessment and mitigation of third-party risk. 85% of our third-party relationships in the sales channel have been risk assessed to date and all new and renewing relationships are risk assessed before they are engaged. We will be extending our risk reviews to other third-party relationships during 2016.
In addition, during the year guidance was issued to operating companies on how to assess anti-bribery and corruption risks in their businesses.
Spectris Integrity Award
We recognise the importance of celebrating and rewarding good ethical behaviour throughout the Group. The launch in 2016 of a new initiative, the Spectris Integrity Award, will go even further to recognise and reward outstanding behaviour which reflects our absolute integrity value.
The Spectris Integrity Award is a Group-wide initiative whereby employees are nominated from each operating company for demonstrating true commitment to our absolute integrity value. The award is designed to emphasise the importance of absolute integrity in our business practice and communicate success stories, providing inspiration for other employees in the Group.
Nominations will be invited from operating companies and the winners will be announced later in the year.