The Board has overall responsibility for compliance and ethics, instigating and approving our key policies.

These policies set a standard for all our employees and are central to our approach to being a responsible business. We have monthly health and safety performance reviews, whistleblowing and anti-bribery reports and regular training to ensure the right corporate culture and good governance practices are developed.


Anti-Corruption and Bribery Policy

We have a policy on anti-bribery and corruption measures. It sets out a zero tolerance approach and a clear commitment to doing business the right way, covering gifts and hospitality, prohibition on facilitation payments and kickbacks and how employees are to raise issues of concern.

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Modern Slavery Policy

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.

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We operate an independent whistleblowing service in conjunction with NAVEX, which enables any employee or third party to confidentially report on any issues around alleged wrongdoing or other Code contraventions. This is supported by a policy on how whistleblowing reports will be investigated and the Board is expressly clear that all reports made in good faith will not result in an employee or third party being subject to recriminations or disciplinary action.


Code of Conduct

Our Code of Conduct 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.

Code of Conduct English - February 2018

Code of Conduct Chinese - February 2018

Code of Conduct Dutch - February 2018

Code of Conduct French - February 2018

Code of Conduct German - February 2018

Code of Conduct Italian - February 2018

Code of Conduct Japanese - February 2018

Code of Conduct Latin American Spanish - February 2018

Code of Conduct Russian - February 2018

Code of Conduct Ukrainian - February 2018


Health and Safety Policy

We have a Health and Safety policy that sets guidelines for the prevention of accidents and work-related ill health and provides guidance for the adequate control of health and safety risks arising from work-related accidents. We expanded the policy in 2020 to reflect the reality of dealing with COVID-19.

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Responsible Sourcing Policy

Our Responsible Sourcing policy was developed in 2021 to reinforce our commitment of working together with our suppliers towards a long-term, sustainable and successful future for all parties. We recognise that our supply chain activities have a broad impact, with our responsibilities extending beyond our own operations, and into those of our suppliers.

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Environmental Policy

Our Environmental policy sets out our commitment to our environmental responsibilities and our recognition of the need to reduce our long-term impact upon the environment. Each business unit within the Group is encouraged to develop the most appropriate measures to reflect their particular operations, but focus on our aim is driven by oversight and ownership at Board level.

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IT Policy and Cyber Security Policy

Given the ever-increasing importance of Information Technology to the Company’s operations and performance, we have an IT policy which 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. It covers issues such as confidentiality of data, GDPR requirements, inappropriate content, security of data including cyber security and reporting processes.

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Diversity Policy

We are committed to encouraging equality, diversity and inclusion among our workforce. Our Diversity policy’s purpose is to provide equality, fairness and respect for all in our employment, ensure we do not unlawfully discriminate because of the Equality Act 2010 protected characteristics, and oppose and avoid all forms of unlawful discrimination.

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