The way we do business and the way we treat our colleagues matters to us. We recognise that continually nurturing and developing the ethical culture of our organisation, and demanding the same high standards from our partners and suppliers, helps to build trust with all our stakeholders and supports our business model and the successful execution of our strategy to realise long-term, sustainable growth.
Acquisitions and compliance with laws and regulations are two of our principal risks for which promoting a strong culture, compliance programme and internal control framework are key mitigating factors. Our pre-acquisition due diligence includes consideration of ethics and compliance matters, and the effective integration of operations and personnel requires careful planning and the swift adoption of our Code of Business Ethics. Following the acquisition of Concept Life Sciences in January 2018, we immediately conducted a risk assessment and engaged the senior management team to emphasise leadership responsibility and establish workstreams for ethics and compliance integration.
In 2018, we completed an assessment of ethics and anti-bribery and corruption risks for the Group. The results were considered by the Board and in support of the continuous refreshment of the programme, an Ethics and Compliance Enhancement Programme has been established which will include deployment of several actions in 2019, including:
- Launch of revised Code of Business Ethics and training programme.
- Group-wide ethics survey.
- Revised incident management and reporting.
- New all-employee certification process.
Since 2011, ethics officers have been selected from a variety of business functions to champion the ethics programme within their respective businesses and to act as a point of contact for employees facing ethical dilemmas.
In October 2018, we brought together our ethics officers for a global conference, where we discussed key successes and challenges, the status of global regulatory compliance, our developing strategy and the evolution of our ethics and compliance programme. Each ethics officer, in collaboration with peers, created a personal action plan of priorities for 2019 to closely support our businesses to stay ahead in a changing operating environment.
Delivering on our commitment for 2018, we have reviewed and enhanced our oversight and monitoring activity across the Group, including improving incident management reporting and migrating responsibility for investigations management from internal audit to the Group’s new Ethics and Compliance team.
With renewed rigour in this particular area, we are confident that we are well positioned to guard against, and swiftly resolve, any ethical problems facing our business in the future.
We actively encourage a culture of openness, engagement and communication by integrating messaging on ethics into our business meetings at all levels. This ensures that employees feel they can discuss any issues that arise in the course of their work and raise any concerns with their managers. We also train our managers so they feel confident to discuss these concerns, with support from our ethics officers.
We are proud of our commitment to protect the careers and reputations of employees who report wrongdoing, as long as they do so in good faith. We recognise that speaking up can be a difficult thing to do. Consequently, we regularly review the effectiveness of our mechanisms for whistleblowing and reporting to ensure this process is as effective as possible.
To ensure our employees never feel isolated, our Decisions Guide mobile app is available for all employees to help them tackle challenging decision-making situations, wherever they are in the world. We also have an independent hotline (spectrishotline.com) providing a tool for our colleagues, business partners and other third parties to report concerns anonymously if they wish.
Reports received from all sources are fully investigated and the results are communicated to the Audit and Risk Committee at least every six months. Any allegation is investigated and resolved and additional guidance, training and monitoring made available or disciplinary action taken, as appropriate. The total number of reports received in 2018 compared to prior years is presented below. Following a slight increase in reporting in 2017, owing to a one-off voluntary disclosure programme, it is encouraging that the level of reporting remains consistent and that our people still feel confident to report concerns.
We have a comprehensive training programme in place across the Group comprising group workshops and online learning modules. These training elements improve awareness of the Code of Business Ethics, anti-bribery and corruption, export controls, fair competition and prevention of the facilitation of tax evasion. Employees complete key training elements relevant to their role and function on arrival as new joiners. Periodically thereafter, further training and other interventions are made available to enhance employee awareness of laws and regulations and promote thought and discussion of business challenges.