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Embedding our Code, policies and standards

To create a culture of compliance and ethics, it is essential that we make sure people understand what is expected of them and how they should behave.

Training our employees

All employees are required to be trained on our Code of Business Conduct, using a curriculum that we reviewed in light of the UK Bribery Act 2010. As well as covering the key areas of our Code, including human rights and anti-corruption, the training tries to bring our Code to life with engaging scenarios, and also explains how to report breaches and where to get help and advice.

The approximately 4,000 employees who joined us this year were taken through a one-hour induction on compliance and ethics which is the same for all, regardless of geography, role or grade. All new employees must do this induction within 30 days of joining. Moreover all new recruits are expected to have a conversation with their line manager about our Code and what is expected of them within the first two weeks of joining the company.

Some regions go beyond the basic Code training, with special workshops and events tailored to their audience that reflect the needs of the region. Events such as the Pathway of Pride programme in Africa, ‘Asi soy, asi somos, sin excepcion’ in Latin America and Carribean and Ethics Day in Asia Pacific provide a forum for sharing experiences and to promote ethical behaviour.

We have been working closely with our controls, compliance and ethics managers and policy subject matter experts to determine the right training materials and training programmes for employees in different functions and markets. For example, marketing teams have received specific training on our Digital Marketing Code to help them understand how to use social media channels in our marketing campaigns, while in supply we have had a huge focus on health and safety and our ‘Zero Harm’ programme.

Engaging and relevant communications

We have brought our communications around compliance and ethics up to date, making them far more engaging and relevant. For example, the posters to launch the updated global policies had a humorous side to capture people’s attention – picking up on the ‘don’t be out of date’ theme. We also tailor communications to what’s going on in the business or for the time of year – for example focusing on gifts and entertainment guidelines during the holiday season.

To help employees understand the link between our Code and values, in February we launched a ‘Valuing our Code competition. Employees watched a video on our Code and values, then aligned areas of our Code to each of our values to be in with the chance to win an iPad. We had a great response with 1,688 correct entries.

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