Behaving ethically and with integrity is a key element of one of our core values (Earning Trust). It is the right thing to do and protects our reputation. Ethics, bribery and corruption risk has been identified as one of the principal risks that could threaten our strategy, performance and reputation.
Corporate transparency is increasingly assessed by third parties and is becoming enshrined in company law (e.g. gender diversity, greenhouse gas emissions and corporate approaches to modern slavery). A company’s transparency is now seen as an important performance indicator and we see the benefit of making continual improvements in this area through strengthening the trust of our various stakeholders.
We engage with stakeholders on ethical topics within our sector. For example, we are an active participant in many of the local medical device trade associations of the countries in which we operate and we played an instrumental role in drafting the Code of Ethical Business Practice for our European industry association, MedTech Europe.
We have developed a Code of Ethics and Business Conduct [link], and a series of Global Policies which cover a range of business conduct and compliance issues, focusing particularly on anti-bribery and anti-corruption. We strive to ensure that all employees complete the necessary training, and completion is carefully monitored.
Our Compliance Officers thoroughly investigate employee breaches of the Code of Conduct. Our Chief Compliance Officer runs a Compliance Steering Committee made up of ConvaTec leadership team members. We have Compliance Officers (‘COs’) working in our Regions, covering APAC (excluding China), China, EMEA, Latin America and North America (US & Canada) respectively. These COs are based in their respective Regions and run cross-functional compliance committees that include members of the regional leadership teams. On an annual basis, the COs conduct risk assessments for their regions, in order to prioritise their compliance activities for the year.
Further information on our Compliance team resources are covered in detail in our Corporate Responsibility Report.
Our Compliance Team works closely with the Internal Audit team which collaborates on some of the actions in our annual global compliance monitoring plan. Additionally, we have a Quality, Regulatory and Clinical Affairs team which focuses on product and supply chain regulatory and quality matters.
Our legal and compliance function works with the Audit and Risk Committee, and the Board. This approach provides visibility to our leadership regarding compliance initiatives and ensures positive “tone at the top” with respect to adherence to the Company’s ethical principles.
Further details are set out in the Annual Report and Accounts
We operate a whistle-blowing line which is managed by an independent, third-party, provider. Their website provides a channel for employees and others to report any suspected breaches of our Code of Ethics and Business Practice.
Information on political donations and relationships, and regulatory compliance, in 2017, is covered in detail in our Corporate Responsibility Report.
Being transparent with our stakeholders about all aspects of our CR performance is a vital part of building strong, long-term relationships based on trust. We are working to improve the quality of our disclosure through the publication of CR Reports and, as part of our commitment to transparency, we have aimed for the 2017 Corporate Responsibility Report to be in accordance with the GRI Standards: Core option. We have mapped the requirements of the standards to the relevant disclosures in a GRI Content Index . We aim for future CR Reports to be subject to external assurance to provide additional credibility to the disclosure.