To ensure that our employees have a clear understanding of what is expected of them in conducting business ethically, with a common set of values. We expect our business partners to act in a manner which aligns with our approach.
Vitec’s Code of Conduct sets out our values, beliefs and behaviours and has been communicated to all employees and business partners. It is available on our website and is translated into local languages used within the Group. We regularly educate and train our employees on business ethics.
Management of responsible business
The Board has overall responsibility for compliance and ethics and considers and approves our key policies, including but not limited to our Code of Conduct (“Code”), Environmental Policy, Anti-Corruption and Bribery Policy, Health and Safety Policy, Modern Slavery Policy, Supply Chain Policy, IT Policy and Cyber Security Policy. These policies set a standard for all our employees, are available on our website, and are central to our approach to being a responsible business.
The Board has delegated the coordination of our responsible business efforts to Stephen Bird and, together with the Executive Management Board and senior management, he focuses his efforts on the areas outlined above. We established a cross-divisional Environmental, Social and Governance Committee in early 2021 that will oversee the Group’s continuing approach to ESG. This is chaired by the Group Chief Executive and Group Company Secretary and meets on a regular basis to review progress against all ESG matters. We will report on this in more detail in 2021’s Annual Report as well as on our website.
The Board and Executive Management Board regularly consider the Group’s reputation and measures progress against our responsible business objectives. Examples include: monthly health and safety performance reviews; whistleblowing and anti-bribery reports; and regular training of employees ensuring that the right corporate culture and good governance practices are developed.
Anti-bribery and corruption
We educate our employees to ensure that they are clear on the right ways of doing business and that there is a zero tolerance of bribery and corruption. Our Code of Conduct is expressly clear that bribery and corruption will not be tolerated. We have a policy on anti-bribery and corruption measures. The policy is available here and sets out a zero tolerance approach to bribery and corruption, a clear commitment to doing business the right way, covers gifts and hospitality, prohibition on facilitation payments and kickbacks and how employees are to raise issues of concern. We regularly train our employees on anti-bribery and corruption measures using web-based training modules and through face-to-face training on our Code of Conduct.
To mitigate the risk around bribery and corruption, we actively screen all major third parties we do business with including customers, suppliers, distributors and agents. This is done through a third party software that screens third parties for reputational risk issues including bribery and corruption, sanctions, politically exposed persons and adverse media reports. This covers over 750 entities and continues to be expanded. We train our people to ensure that as part of doing business with a new partner, that the new partner is screened through this service.
The Board and the Audit Committee are regularly updated on the Group’s anti-bribery and corruption measures including training initiatives and status of screening of third parties.
Our agents and distributors are party to agreements which prohibit bribery and set out our expectations on behaviour and values.
We operate an independent whistleblowing service in conjunction with NAVEX. This enables any employee or third party who feels that the normal reporting channels through line management are not appropriate, to confidentially report on any issues around alleged wrongdoing or other Code contraventions. Anyone making a report can choose to do so anonymously.
All reports are notified to the Group Chief Executive, the Group Company Secretary and the Chairman of the Audit Committee and are investigated independently by senior management who are not connected to the report. The outcome of investigations is reported to the Chairman of the Audit Committee and remedial action taken where necessary. The Board is notified of all whistleblowing reports and the outcome of all investigations.
This service is communicated to all employees with posters prominently visible at all sites, and a letter sent explaining the service to ensure that it remains visible and understood. The documents are also available on the Group intranet with all communications translated into local languages. There is a policy on how whistleblowing reports will be investigated and the Board is expressly clear that all reports made in good faith which are genuine and not malicious in intent, will not result in an employee or third party being subject to recriminations or disciplinary action. During 2020, there were four whistleblowing reports that were HR related and that related to the US and UK. Each matter was thoroughly investigated and corrective actions taken where necessary.
We plan to recommunicate the whistleblowing service to all employees in 2021.
Slavery and human trafficking statement
We support the Modern Slavery Act 2015 and have adopted a slavery and human trafficking statement, setting out our processes to ensure that this issue is not in existence in our operations or supply chain. The statement can be viewed here. Through screening our supply chain using third party software and physically inspecting our supply chain, we are confident that this is not an issue within our operations. We expect our business partners to have similar values to our own to ensure that slavery and human trafficking is not something we are associated with. Our internal audit function also checks the integrity of the supply chain as part of its internal audit programme. We train our employees on this issue through a combination of web-based training modules and also through our Code of Conduct.
Code of Conduct
Our Code forms the backbone of our culture and provides clear guidance to our employees on how they are expected to behave towards colleagues, suppliers, customers, shareholders and on our wider responsibility to the communities within which we operate.
Our Code defines our approach to business integrity, including an absolute prohibition on bribery, kickbacks and political donations, along with guidance on gifts and hospitality, conflicts of interest, books and records, competition, share dealing, respect for the UN Universal Declaration of Human Rights, compliance with anti-slavery legislation, respect for the individual and privacy, diversity, health and safety, environmental sustainability, business partners and charitable donations.
Our Code has been communicated to all employees, including new employees joining the Group, and is available on the Company website translated into local languages. We require all senior management to undertake an online training module covering the Code, good corporate governance including issues such as share dealing, conflicts of interest, legal duties and other reputational issues.
Breach of the Code of Conduct, upon investigation, may lead to disciplinary action being taken against an individual and in the worst case, dismissal. Any investigation around the Code of Conduct would be conducted by the Group’s HR functions. During 2020 no employee was dismissed from the business due to a breach of the Code of Conduct.
The Company fully supports the principles set out in the UN Universal Declaration of Human Rights. The Company’s policies and procedures reflect the principles contained within the Declaration.
Information systems and technology
Given the ever-increasing importance of Information Technology to the Company’s operations and performance, we have an IT policy that is available on our website. Responsibility for IT ultimately rests with the Group Finance Director and the IT policy sets out standards to be followed across the Group for its employees, contractors and third parties around the use of the Group’s IT systems. The policy has been implemented to ensure that the Company’s IT is fit for proper business purpose and is a safe environment for all our users. Breach of the IT policy may lead to disciplinary action being taken. Notably, the IT policy covers issues such as confidentiality of data, GDPR requirements, inappropriate content, security of data including cyber security and reporting processes. The Group’s Audit Committee receives regular updates on the Group’s IT arrangements including matters such as pen testing, user access and training of employees.