Managing the Code
The Code is approved by the Board of Directors of 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 Business Ethics Compliance Council ('the Council') is responsible for reviewing issues, determining priorities and making recommendations to the Audit Committee. Members of the Council brief the Audit Committee periodically on ethical issues and suspected or actual breaches of the Code. Responsibility for managing specific issues sits at different levels within Smiths Group, depending on the nature of the issue and how it can most effectively be managed:
- environment, health and safety (EHS) issues are the responsibility of line managers and all employees. The Group-wide EHS steering committee, a technical implementation committee and local coordinators assist in the development of strategy and policy and the provision of advice and support;
- security is managed through a Group-wide steering committee and, in each business, by line management;
- employee issues are managed through the human resources function and by line management;
- supplier and customer programmes are managed by each business; and
- 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 managers; and
- the examination ofCode compliance issues in site-level internal audit reviews.
Day-to-day responsibility for compliance with the Code rests with each and every Smiths employee.