Our Code of Business Ethics is the cornerstone of our ethical mindset and corporate and compliance programmes. Flowing from the Code, our other policies, procedures and internal controls are designed to address specific ethical matters, conduct or risks in a more comprehensive manner.

These include our Third Party Vetting Policy and Procedures, which are a critical part of our efforts to avoid doing business with persons or entities who may be involved in behaviours that are unethical or that we consider to be unethical.

We are committed to fostering an open working environment where concerns can be readily raised, and grievances are properly addressed in a timely and confidential manner. Our Ethics Hotline for reporting breaches of policy, or other ethical concerns, is available 24-7 and our teams are encouraged to contact our legal team to discuss any queries. Retaliation for reporting concerns is strictly prohibited and we aim for transparency and communication during investigations to foster a reporting culture.

The Code and our other policies are reviewed regularly, as are our compliance programmes, and we undertake external benchmarking and evaluation against best practice models. Internal compliance with our policies is monitored and reported through our Internal Audit process and we periodically undertake audits and/or request confirmation of compliance from suppliers and other parties deemed to be high risk.

Supporting our ethical mindset

All employees are required to comply with our ethics policies. To ensure that our policies are understood and followed, we communicate regularly on ethical matters. Team members in leadership positions and those that are customer-facing or supplier-facing are required to complete ethics training every year and an ethics module has been added to our cultural orientation training class for new employees.

Human rights

We respect the principles of the Universal Declaration of Human Rights and the International Labour Organization’s core conventions. We are committed to treating people according to merit and contribution, refraining from coercion and never deliberately causing harm to anyone. We have not adopted a formal human rights policy as we believe that our existing adopted policies and our Values recognise and communicate the importance of how we conduct our business and its impact on a wide range of stakeholders, and therefore our responsibilities in relation to human rights. The requirement for a specific human rights policy will continue to be monitored.