In 2022, we renewed our commitment to ethics and integrity with the appointments of a global chief compliance officer for Allied Universal and director of ethics and compliance for Allied Universal International (G4S). Together, they lead the ethics and compliance department (E&C). E&C is a new organisational function that administers and oversees the global ethics and compliance programme.

The programme is the foundation for the company’s key commitments to ethics, integrity and compliance with all laws, and doing business the right way. The programme is built upon a very simple premise, “Always Act with Integrity,” which is expected from all employees, contractors and subcontractors regardless of where they work or what role they perform. Acting with integrity means always being honest and having strong moral principles.

Organisational integrity starts with leadership—the “tone at the top.” Senior leadership is expected to “role model” and promote an organisational culture that encourages integrity, ethical conduct, and a commitment to compliance with all laws.

Equally as important as “tone at the top” is “tone in the middle” from all management. Managers are expected to reinforce ethics and compliance messaging and initiatives throughout their respective businesses and communicate the company’s expectations around the Ethics Codes and company values. Our Ethics Codes provide guidance for legal and ethical decision making.

Importantly, as a global organisation, we expect our teams and colleagues to always follow the law in their respective geographic regions, at a minimum. In implementing and embedding the programme, E&C works with businesses, functions, leaders, and individuals across the organisation. E&C provides assurance, oversight, and governance to ensure the businesses and functions
operate ethically with integrity and in accordance with the Ethics Codes and applicable laws. E&C supports the businesses and functions by implementing risk management processes, policies and procedures and communicating messages setting forth the company’s expectations regarding ethical and compliant conduct.

The programme is comprised of six elements, which play unique and important roles in identifying, prioritising and mitigating risks related to ethics and compliance in the organisation.

The programme elements are as follows:

• Ethical culture and leadership engagement
• Management support, resources and oversight
• Standards, policies and procedures
• Communication, education and training
• Monitoring, evaluation and risk management
• Internal reporting, investigation and remediation

In the end, our goal is to drive a strong ethics and compliance culture that builds trust, promotes integrity and improves the way we engage with each other and our business partners.

Anti-bribery and Corruption

Anti-bribery and corruption (ABC) policy and procedures form a key element of the Ethics Codes for our North American and international businesses.

Our ABC policy is supported by specific training and awareness programmes globally. In 2022, we refreshed and relaunched the Global Anti-Bribery and Anti- Corruption policy to the global group. We summarise the key policy takeaways below, which are also incorporated into a variety of global communications.

The company’s Anti-Bribery and Anti-Corruption Policy is simple:

• The Company does not accept or offer bribes
• The Company does not accept or offer kickbacks
• The Company does not tolerate corruption in any form

A company employee or anyone acting on the company’s behalf, may not offer, make, promise, request or accept a bribe; provide or accept kickbacks; or otherwise provide or accept any improper payment, gift, favours or other item of value in connection with the company’s business.

2022: ABC training completed by 81% of targeted G4S employees. (686 courses delivered in North America)