
Behaving ethically and transparently
“Doing business responsibly is key for all our stakeholders. From ensuring labour standards and environmental stewardship to ethical marketing and data privacy, our core value 'Do what's right' applies to everything we do. We hold ourselves accountable for the commitments we make, and expect the same level of transparency from partners."
James Kerton, EVP, General Counsel & Company Secretary

Our approach
How we conduct ourselves in commerce – earning trust by behaving with integrity and doing what we say we will do – is essential if we are to achieve our vision and create value for our stakeholders. It is also the right thing to do and protects our reputation.
Our extensive ethics and compliance programme incorporates several policies and procedures including:
- Maintaining a Code of Ethics and Business Conduct
- Making available an independently provided Compliance Helpline and web link for employees and third parties
- Assuring the existence of mechanisms to ensure issues can be reported and reviewed
Our targets & commitments
In the past year, we have updated our Human Rights and Labour Standards Policy, expanded the scope of our risk assessment process for suppliers, and improved Code of Conduct training completion rate. Convatec’s Human Rights Committee - a working group under the direction of our ESG Steering Committee - holds the company accountable to meeting targets around behaving ethically and transparently, including:
- Keeping human rights-related policies updated to current global standards and expectations.
- Expanding human rights training across the business.
- Expanding the use of our supplier assessment platform.
For more information about how we behave ethically and transparently, see pages 49-51 of our 2024 Annual Report.

FTSE4Good
We are proud members of FTSE4Good, a global sustainable investment index series, designed to identify companies that demonstrate strong ESG practices measured against international standards.
Companies that meet inclusion demonstrate strong transparency and management in clearly defined ESG criteria.
Transparency
Rating organisation | 2020 | 2021 | 2022 | 2023 | 2024 |
---|---|---|---|---|---|
ISS | B- | B | B | B | B- |
Sustainalytics Risk Rating1 | 15.2 | 14.6 | 14.5 | 16.6 | 14.1 |
MSCI | AA | AA | AAA | AAA | AAA |
CDP | B | B | C | B | B |
1. As at 28 Oct. 2021. Lower scores are desirable for Risk Rating while higher scores are desirable for Overall Performance.
Policies, procedures and resources
We maintain a Code of Ethics and Business Conduct and a series of Global Policies which cover a range of business conduct and compliance issues, focusing particularly on anti-bribery and anti-corruption. All employees are required to complete the training on our Code of Conduct.
A Compliance Helpline is available for employees and third parties to report suspected breaches. Any issues reported are reviewed by our ethics and compliance function and the resulting investigation and outcome of any significant issues are overseen by the Audit and Risk Committee.

Policies and standards
Convatec's Code of Ethics and Business Conduct (Our Code) embodies our corporate vision and corporate values. We are committed to creating a working environment where everyone is treated fairly with respect, dignity and consideration and where there are opportunities for all. Our Human Rights and Labour Standards Policy, which incorporates principles and guidelines set out in the United Nations Universal Declaration of Human Rights, Modern Slavery Act and the UN Guiding Principles on Business and Human Rights, addresses a range of issues including equal opportunities, anti-harassment and dignity at work. Many elements of our Human Rights and Labour Standards Policy are reflected in our Code of Conduct. Our Code of Conduct and Human Rights, Labour Standards Policy, California Supply Chains Act statement and Modern Slavery Act statement are available here.

Working responsibly with partners
We require new suppliers to adhere to our Global Third Party Compliance Manual (the “Manual”) which covers a range of topics, including commitments to the International Labour Organization conventions and the Principles of the UN Global Compact and environmental protections, and extends our Code of Conduct and our Human Rights and Labour Standards Policy to the supply chain. The Manual is introduced to all existing supplier contracts as these are renewed. A copy of our Manual is available here. Our Supplier Code of Conduct lays out our expectations of suppliers and the process followed when expectations are not met.
We monitor and assess suppliers using third-party risk platforms, which provide in-depth, real-time coverage of a range of factors that could impact supplier performance (including geopolitical, climatic and civil unrest), as well as events that may have been caused by our suppliers (for example major pollution and strikes incidents).
Supplier due diligence
To ensure best in class human rights and labour practices throughout the supply chain, all of our suppliers are initially screened by a third-party platform, EcoVadis IQ. Suppliers identified as high risk of modern slavery are required to complete a Sedex self-assessment questionnaire (SAQ) at locations that manufacture Convatec products, provide raw materials or store our goods. Through the SAQ, suppliers with risks identified that have potential to conflict with our Code of Conduct are expected to complete a Sedex Members Ethical Trade Audit (SMETA). We operate processes that are designed to facilitate corrective actions after SMETAs, to ensure vendors are engaged promptly when a risk event occurs and that these events are tracked through to satisfactory closure of the potential risk. We will continue to build on this progress in 2025.
For more information about how we work responsibly with our partners see page 50 of the 2024 Annual Report.
Global Third-Party Compliance
In many countries Convatec conducts its business via third party distributors. We expect and require that our distributors comply with all applicable laws and regulations and follow the Convatec Code of Ethics & Business Conduct. To support our distributors’ compliance efforts, we have prepared the Convatec Global Third Party Compliance Manual.
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