Business ethics and anti-bribery and corruption
Being a responsible business partner, employer, customer and supplier is an important part of our strategy and forms an essential foundation on which we carry out our business.
In our view, the ethical behaviour of corporations should not be just a reaction to regulation or legal compliance, but a means of doing business that gives customers, employees, partners and communities the confidence that they are working with an ethical organisation that is not prepared to compromise on its integrity to achieve its objectives or to make money. That is why we ensure that our business ethics and anti-bribery and corruption programmes are embedded within our organisation and are the responsibility of every manager across the group.
We believe that high standards of ethical conduct provide a market differentiator and those organisations with the highest ethical standards will have the most positive impact on the lives of those around them and, ultimately, will be the most successful.
We have a group-wide business ethics policy that clearly defines what we consider to be acceptable and unacceptable business practices. We demand compliance with this policy from all managers and employees across the group.
In order to ensure that everyone in the group understands their obligations in relation to this policy, we do the following:
- Update and strengthen the G4S business ethics policy periodically, incorporating evolving standards and legislation and evaluating any risk to the group’s integrity
- Distribute the policy to managers and request that all managers review the policy and personally sign up to playing their part in ensuring its implementation and therefore the group’s compliance
- Ensure that all employees are aware of their obligations under the policy, through various communications channels, including induction and other training, notice boards, employee magazines, etc
- Provide specific training to all managers and supervisors on business ethics and preventing bribery and corruption through a bespoke programme available in a variety of formats and languages
- Reinforce the importance of ethical behaviour through induction, employment contracts, staff handbooks, training and communications practices.
G4S' Ethics Code
Progress in 2015
Every G4S employee has a responsibility to ensure that they uphold our core values, adhere to the law and deliver against the important commitments set out in our business ethics policy and ethics code. One of the key methods of ensuring that we maintain high standards of ethics and integrity is to ensure that employees are able to report concerns that they may have about the business, or the activities of individuals, that they believe contravene our ethics code.
Following a review of our whistleblowing policy in 2014 by a specially formed Ethics Steering Group, we launched our new and enhanced whistleblowing process in September 2015. Hosted by an independent specialist hotline and case management provider, Speak Out allows all G4S employees and former employees to raise ethical matters of concern online or via a free telephone service.
Both channels are available 24 hours a day, seven days a week and are completely confidential.
Accompanying the launch of Speak Out, we have developed a range of communication materials to raise awareness and encourage employees to report any concerns or wrongdoing. The new case management system enables us to better record, manage and report on whistleblowing cases. This integrated system gives us greater visibility of the issues and what, if any, are the common themes. It offers employees greater visibility of the status of their case and any investigations.
Another area that has been improved is the way we select and appoint the people who carry out investigations. In addition to the internal audit team, we have appointed a wider network of investigators (all of whom have received additional training) with the integrity and expertise to deal with confidential matters relating to financial issues, ethical issues, bribery issues, or issues relating to any of our policies as they arise.
The ethics steering group will continue to oversee the successful implementation of Speak Out, monitoring its caseload and carrying out as well as carrying out regular review of cases being reported, investigation progress and resulting actions.
During 2015, the internal audit function carried out eight investigations into issues raised through existing whistleblowing channels. Other investigations covering less serious matters were carried out by regional management with the results and recommendations from those investigations being shared with the group director of risk and audit.
The internal audit team meets regularly with PwC, our external auditor, to ensure that there is strong cooperation and to minimise any gaps in audit coverage.
|Types of issues investigated by the group internal audit function and actions resulting include:
Alleged unethical behaviour by management, including abuse of position and fraud
All issues are investigated and in proven cases action taken against management, including disciplinary action up to and including dismissal.
In the case of serious issues such as fraud, the group has a zero tolerance approach and reports such cases to the local police and wherever possible will seek criminal prosecution.
This applies to all types of fraud whether internal or external.
Concerns regarding operational procedures
Investigations with regional management to ensure that G4S standards are being followed properly.
- complete the global implementation of the Speak Out whistleblowing hotline and case management system
- continue to create an environment in which G4S colleagues can be confident that they can Speak Out and raise concerns and that they will be taken seriously without fear of retaliation
- conduct annual control self-assessments of key issues, including business ethics, health and safety, and human rights, using the group risk and compliance system
- complete our review of the group’s anti-bribery and corruption policies to ensure that they are in line with current best practice and to implement any changes as appropriate.