Business Ethics PolicyG4S has an established Business Ethics policy, as outlined below:
Contents
Our approach to being a good corporate citizen
Our standards of business practice
Our approach to corporate governance
Our commitments to our employees
Our employees’ commitments to G4S
Implementation
1. Our approach to being a good corporate citizen
G4S is committed to being a good corporate citizen, taking account of the economic, social and environmental impact of our business and aiming to maximise the benefits and minimise any negative impact of our global operations.
Human rights
G4S supports the principles of the United Nations Universal Declaration of Human Rights and we are committed to upholding these principles in our policies, procedures and practices. Respect for human rights is and will remain integral to our operations.
We will endeavour to work with business partners who conduct their business in a way that is compatible with our policies of respect for human rights and ethical conduct. We will work with customers to ensure that contractual requirements do not infringe human rights.
We will take measures to ensure that the work of our employees does not compromise internationally accepted human rights conventions, whilst recognising and respecting the diversity in local cultures across the different countries in which we operate.
The environment
We will conduct our business with respect and consideration for the environment. We will strive to minimise our environmental impact through the management of waste, vehicle emissions and energy consumption.
Local communities
G4S is fully committed to supporting and assisting the communities in which we operate through a variety of means including charitable fund-raising, sponsorship of community projects and voluntary work by employees. We conduct our business with respect and consideration for the good of local communities, taking steps to minimise any disturbance as a result of our operations. We will also serve local interests by providing good employment opportunities and effective services and products.
2. Our standards of business practice
We are committed to high ethical standards in our business dealings to ensure the integrity of our employees and our organisation is maintained.
Bribery and corruption
G4S is resolutely opposed to bribery and corruption in whatever form it may take. Gifts or entertainment may only be offered to a third party if they are consistent with customary business practice in the relevant territory, are modest in value and cannot be interpreted as inducements to trade. Where there is doubt, guidance should be sought from the relevant Regional Human Resources, Regional Finance Director or Regional President. No financial or other inducements should be given to third party organisations or to individuals from such organisations in any circumstances, including government agencies and representatives.
Sales of the Company’s services and products and purchases of products and services from suppliers will be made solely on the basis of quality, performance, price, value and/or for the benefit of the Group, and never on the basis of giving or receiving inducements in the form of payments, gifts, entertainment or favours or in any other form.
Employees should not accept gifts, money or entertainment from third party organisations or individuals where these might reasonably be considered likely to influence business transactions. Gifts, other than trivial ones with a low value, should be returned. In a culture where such an action might cause offence, the gift should be declared to the company and, if practical, donated to an appropriate charity.
Political contributions
G4S does not make contributions to political parties and this policy should be followed worldwide. The only exceptions to this are in countries where there is a legal requirement to do so or where there is an established, lawful and generally accepted practice to do so. In such circumstances, any payment must be approved by the relevant Regional or Divisional President.
As G4S is a UK plc, it must comply with the UK Companies Act. As a result any intended payments by any group company to organisations which are politically active anywhere within the European Union must be referred to the G4S company secretary, before they are offered or made. Shareholder approval may be required and obtaining such approval would be difficult, time consuming and expensive, so payments of any more than token amounts are unlikely to be permitted.
Treatment of customers
Mutual trust and confidence between G4S and our customers is vital. All employees should strive to consistently deliver service excellence and value for money, meeting customers’ expectations and anticipating their changing requirements.
Internal suppliers Any business transactions between G4S subsidiaries for the supply of goods or services should be based on normal ‘arm’s length’ business principles. These principles should cover pricing and other contractual terms and must be as defensible as those to which independent parties might be expected to agree.
External suppliers
All suppliers are entitled to fair treatment and all potential suppliers should have a reasonable opportunity to win G4S business. It is our policy to pay suppliers on time in accordance with agreed terms of trade. We set high standards for our suppliers in the context of our own ethical policy.
Competition
G4S will always compete vigorously, but in a fair and ethical way. Competitive success is built on providing good value and service excellence. Competitors should not be disparaged. When in contact with competitors, employees will avoid discussing confidential information and no attempt will be made to improperly acquire competitors’ trade secrets or any other confidential information. Employees must not discuss pricing strategies or undertake any arrangements or practices which would conflict with the laws applicable to the business concerned.
3. Our approach to corporate governance
G4S is committed to protecting the interests of our shareholders and our organisation through compliance with the relevant legal and regulatory environments and careful management of business risks.
Compliance with the law
G4S will comply fully with all relevant national and international laws and will act in accordance with local guidelines and regulations, including those which are industry specific, governing our operations.
It is the responsibility of all managers to ensure, by taking legal or other expert advice where appropriate, that they are aware of all local laws and regulations which may affect the area of the business in which they are engaged, including tax and exchange controls.
Accounting standards and records
All accounting documentation must clearly identify the true nature of business transactions, assets and liabilities in conformity with relevant regulatory, accounting and legal requirements. No record or entry may be false, distorted, incomplete or suppressed.
All Group reporting must be accurate and complete and in compliance in all material respects with accounting policies and procedures, as outlined in the Group Finance Manual. Employees must not materially mis-state or knowingly misrepresent management information for personal gain or for any other reason.
External reporting
G4S businesses may be required to make statements or provide reports to regulatory bodies, government agencies or other government departments. Care should be taken to ensure that such statements or reports are correct, timely and not misleading. Senior management must be made aware of any sensitive disclosure before it is made.
Care must also be taken when making statements to the media that information given is correct and not misleading. Enquiries from the media should be referred to company media relations experts and statements should only be made by designated spokespersons.
G4S will provide, through our web-site and through the published annual report and accounts and other statements, appropriate information to enable shareholders to assess our business performance. We will comply with applicable laws and stock exchange regulations as to the disclosure of information about G4S.
Policies and procedures
G4S recognises that there are risks associated with carrying out any business activity. Management is responsible both for ensuring that policies and procedures are in place to manage risks and for complying with those policies and procedures. Employees should ensure that they are aware of the risks associated with their activities and that they comply with policies and procedures in place to manage those risks.
4. Our commitments to our employees
G4S is committed to optimising individual and business performance through employing the best people at all levels and creating an environment in which they want to and are able to contribute fully to the Group’s success. To achieve a working environment in which team spirit and commitment to the goals and values of G4S are maintained, the Company will ensure that individual employees are treated fairly and with dignity and respect.
National regulation
In dealing with our employees, we will act in compliance with national regulatory requirements and employers’ obligations to employees under labour or social security laws and regulations must be respected.
ILO Declaration on Fundamental Principles and Rights at Work
G4S supports the four fundamental principles in the ILO Declaration. Thus, in accordance with local legislation and practice we will respect freedom of association and the right to collective bargaining, employment will be freely chosen with no use of forced or child labour, and we will not discriminate on the basis of gender, colour, ethnicity, culture, religion, sexual orientation or disability.
Harassment
Harassment can be defined as unwanted behaviour, which a person finds intimidating, upsetting, embarrassing, humiliating or offensive. Conduct involving the harassment (racial, sexual or of any other kind) of any employee is unacceptable. Should an employee believe that he or she has been harassed the matter should be raised with the relevant Human Resources Manager who will arrange for it to be investigated without delay, impartially and confidentially.
Equal opportunity
We value all our employees for their contribution to our business and their opportunities for advancement will be equal and not influenced by considerations other than their performance, ability and aptitude. Employees will also be provided with the opportunity to develop their potential and, if appropriate, to develop their careers further with the company.
Health & safety
G4S places the highest priority on promoting the health and safety of employees whilst at work. In particular, we will constantly review the effectiveness of our methods of operation to best protect those who work in a high-risk environment.
Terms of employment
The businesses and their employees will work towards creating permanent long-term relationships. Employees will be paid for and work hours at least as favourable as the terms established by national legislation or agreements or industry standards.
Pre-employment screening and selection
In order to protect the interests of our employees and customers, and because of the nature of our business, G4S will apply rigorous pre-employment screening and selection techniques.
5. Our employees’ commitments to G4S
Employees must avoid situations where appearance of business impropriety exists, even though the circumstances might not otherwise specifically violate this code of conduct or where specific laws or regulations do not apply.
Confidential information
Employees must not make use of confidential information obtained through their employment for personal gain, nor disclose such information to any third party during or after their employment. ‘Confidential information’ is either information that has been specifically described as being confidential or is otherwise obviously confidential from the surrounding circumstances.
The term “confidential information” does not include information in the public domain or information which the individual concerned is required by law to disclose.
Conflicts of interest
Every employee has a duty to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of the Company, or which divides his or her loyalty to the Company. Any activity which even appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not unethical or improper, does not compromise integrity and is not detrimental to the reputation and standing of the company.
6. Implementation
This Business Ethics Policy must be adopted by all companies as a minimum standard and issued to all G4S senior managers. It will be published on our global intranet and incorporated into future employment contracts where applicable. It will be monitored as part of G4S compliance processes. The policy will be reviewed annually. Where G4S companies already have their own published ethics policies, these must be reviewed against this Group policy to ensure they meet the same minimum standards.
Staff complaints, whistleblowing and suggestions
Staff can expect that the Company will give due consideration to their constructive suggestions and will provide a considered and objective review of genuine concerns and complaints. Such concerns include fraud, misrepresentation, theft, harassment, discrimination and non-compliance with regulations, legislation, policies and procedures.
Concerns must be investigated impartially so that the employee’s rights are protected. Employees who have concerns about potential unethical behaviour should advise their local Human Resources or Finance Director in the first instance. Employees may do this anonymously if they so wish. To ensure that confidentiality is maintained, employees should not discuss such concerns with colleagues or other third parties, unless specifically authorised or unless it is a legal requirement.
If the employee is dissatisfied with the response to the concern which he or she has raised, or if the concern relates to a matter of exceptional gravity or sensitivity, he or she can contact the Head of Group Internal Audit in accordance with the Group Whistleblowing policy which is published on the global intranet. A special hotline telephone number ( +44 (0) 1293 554411 ) and e-mail address (gdoc@g4s.com) are available for this purpose.
Compliance monitoring
We monitor, on a regular basis, compliance with this ethics policy, using information reported via the whistleblowing facility, internal/external audit and ongoing management reporting.
Adherence to policy
Since G4S aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with the Group’s principles and policies are not tolerated. Strict adherence to these principles and supporting policies is a condition of employment in the Group. Any action by an employee, which deliberately or recklessly breaches this ethics policy, may result in disciplinary action and where appropriate, criminal proceedings will be instituted.
Issue date: March 2008
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