Managing corporate responsibility and business ethics
The Code and its application in Smiths is not a paper exercise. It is an ongoing commitment to everyone with whom we do business, or who is affected by our operations, to doing business the right way.
Smiths has identified six fundamental strengths that underpin our position as a world leading technology company and help us to meet or exceed the targets and standards that our customers and other stakeholders rightly expect. One of these core strengths is doing business the right way.
The Code of Corporate Responsibility and Business Ethics
In order that our employees and stakeholders understand what doing business the right way means, we have a Code of Corporate Responsibility and Business Ethics ('the Code'). The Code sets out in a written document twelve principles for how Smiths does business.
Implementing the Code
The principles set out in the Code are based on common values of integrity, honesty, fairness and transparency. The principles cannot address all areas or all circumstances, but they provide a framework for wider policies and programmes.
The Code is approved by the Board of Directors at Smiths Group plc and is supported by the Chief Executive, the directors and the management of Smiths at all levels. The Board has ultimate responsibility for the Code and its application across Smiths businesses worldwide.
The Audit Committee of the Board has particular responsibility for monitoring the implementation of the Code, in addition to the programmes and functions that underpin compliance.
The Code of Corporate Responsibility and Business Ethics Compliance Council ('the Council') is responsible for reviewing issues, determining priorities and making recommendations to the Audit Committee. The Audit Committee is briefed periodically on the activities of the Council and Code compliance issues.
Communicating the Code
Responsibility for managing specific issues lies at different levels within Smiths Group, depending on the nature of the issue and how it can most effectively be managed.
- Health, safety and environment issues are managed through a Group-wide steering committee, a technical implementation committee, and local coordinators.
- Employee issues are managed through the human resources function and by line management.
- Supplier and customer programmes are managed by each business.
- Community programmes are principally managed locally, although there is also some Group-level activity.
The Chief Executive and his leadership team actively champion the Code, securing its ongoing relevance and profile via several routes. These include:
- the discussion of ethics issues and Code compliance at management meetings;
- the review of ethics issues in the performance review system for all managers; and
- the examination of Code compliance issues in site level internal audit reviews.
Day to day responsibility for compliance with the Code has to rest with each and every Smiths employee. Various tools and materials are available to support understanding of the Code, including a question and answer booklet (which is available in eleven languages); Group, divisional and business level policies and procedures; and communication and training, which is provided in a number of formats. For example, the second principle of the Code, which sets out the requirements for fair competition, is supported by an online anti-trust compliance programme. This is taken by employees in sales, procurement or other functions whose job responsibilities may bring them in contact with competition issues.
The 12 principles outlined in the Code:
1 Compliance with national laws and regulations.
2 Fair and vigorous competition in the marketplace.
3 Integrity and ethical conduct as the standard for individual and corporate business behaviour.
4 Fair and honest treatment of suppliers and customers.
5 Proper and respectful treatment of employees.
6 High standards for health and safety in the workplace.
7 Respect for the environment.
8 Contributing to the communities in which we live and work.
9 Engaging appropriately with government departments and agencies.
10 Respect for human rights.
11 Prudent and transparent public accounting and reporting.
12 A culture of compliance throughout the entire Smiths organisation, embracing all employees.
Managing specific issues
An Ethics Helpline is accessible by both phone and email to answer queries relating to ethics issues, as well as to act as a confidential reporting line for concerns and allegations. The Helpline is available via toll-free numbers in 36 countries where Smiths has businesses, staffed by individuals who speak the local language. All issues are addressed promptly and referred, as required, to relevant functions to enable proper investigation and, if appropriate and possible, reported back on to callers.
Information about the Ethics Helpline and other aspects of Code compliance are available to employees on the Smiths intranet and via posters and wallet cards to ensure that employees without access to Smiths Group electronic communication tools can also access it. Employees with concerns or questions are encouraged to raise them through a variety of routes, including line management, local human resources management and Smiths legal counsel, in addition to the Helpline.
The Code and its application in Smiths is not a paper exercise. It is an ongoing commitment to everyone with whom we do business or who is affected by our operations, to doing business the right way.