Ethics and integrity

We believe in integrity: this means being honest and transparent, treating people with dignity and respect, and setting a good example. This is embedded in our code of business conduct and applies to all our employees in everything we do – from the way we treat our own people, to our relationships with our stakeholders.

Policies and procedures

Our commitment to integrity is underpinned by a comprehensive framework of policies in areas such as human rights, anti-corruption, and insider dealing, as well as a robust code of business conduct. The code applies to all directors, employees, and third parties who act on our behalf, and covers issues such as avoiding potential conflicts of interest, ensuring fair relationships with customers and suppliers, protecting data, and the proper use of company assets. Both employees and stakeholders can report any breaches of our policies and standards via the confidential whistleblowing facility on our corporate website, and in addition we now have confidential whistleblowing hotlines in 30 major countries of operation.

Some of the markets we operate in are more challenging than others when it comes to applying these principles, and where we perceive there to be additional risks we take steps to identify and address them, by organising focused workshops and events, building an awareness campaign, and enhancing our monitoring. We have also developed a new tool to assess risk.


We back up our code with detailed training depending on people’s roles, and this training has to be refreshed every three years. Our employees can access all our compliance policies on our intranet, and we also hold face-to-face training sessions at our sites. Where our compliance training rates are typically low, we run ethics and compliance days, and these are reported on an ongoing basis under What's New.


Any anti-trust proceedings, investigations and follow-on claims involving our subsidiaries are detailed in our 2014 Form 20-F filing to the SEC, section 8A.

The integrity campaign

In 2014, we launched an important integrity campaign across the business. It was designed to reinforce our code of business conduct, and help our people understand how the theory of business ethics translates into the decisions we take – or choose not to take – in our everyday operations. The campaign defines integrity as honesty and transparency, respect and dignity, and exemplarity – in other words, being a good role model. We have also expressed these as eight principles, which include, for example, ‘honour your word’, ‘respect confidentiality’, and ‘lead by example’. We are now supporting our employees to understand how these apply in their own roles through a campaign to convert the principles into practice, with a rolling series of articles across multiple communications channels with practical examples of how problems can arise.