To ensure 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 our approach.
Vitec's Code of Conduct sets out our values, beliefs and behaviours and has been communicated to all employees and business partners. We regularly educate and train our employees on business ethics.
Management of responsible business
The Board has overall accountability for corporate responsibility and considers and approves our key policies, including our Code of Conduct (“Code”), Environmental Policy and Health and Safety Policy. These policies set a standard for all Divisions and employees worldwide, are available on our website, and are central to our approach to corporate responsibility.
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.
The Board and Executive Management Board regularly consider the Group’s reputation and measure 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 fostered.
We educate our employees to ensure that they are clear on acceptable 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.
Our agents and distributors are party to agreements which clearly prohibit bribery and set out our expectations on behaviour and values. We carry out due diligence on major customers and suppliers with a more detailed screening of backgrounds using industry standard software from a third party provider focusing on reputational risk.
We operate an independent whistleblowing service in conjunction with EXPOLINK. 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.
All reports are notified to the Group Company Secretary, the Group Chief Executive 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.
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 several languages. There is a clear 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 2019, there were two whistleblowing reports that were HR related. Both matters were thoroughly investigated and corrective actions taken.
Slavery and human trafficking statement
We have adopted a modern 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 repeatedly screening our supply chain using third party software and also physically inspecting our supply chain, we are confident that this is not an issue with our operations. Our Internal Audit function also checks the integrity of the supply chain as part of its internal audit programme.
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 colleauges, 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, shre 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 several languages. Employees of all newly acquired businesses receive the Code as part of their induction. We require all senior management to undertake an online training model covering good corporate governance including issues such as share dealing, conflicts of interest, legal duties and other reputational issues.