Governance in Practice

Legal compliance is non-negotiable and we take the issue very seriously. We have robust systems and procedures in place to ensure our employees, third-party representatives (including agents, distributors and consultants), suppliers and other stakeholders act legally, responsibly and ethically.

Legal Compliance Training


completion rate for our 2023 annual employee compliance certification program (code of conduct and combined which also includes anti-corruption, export controls and trade sanctions) with no disclosures made.


completion rate for our 2023 employee compliance training program. The equates to 4,240 training courses delivered to 2,118 employees.

Compliance training

We deliver compulsory online training on various aspects of legal compliance. This ensures our employees have a good understanding of the rules and related risks as they apply to our business. Our online training platform is provided by SAI Global.

Our core employee compliance courses are:

  • Code of Conduct
  • Anti-corruption and Anti-bribery
  • Competition Law/Anti-trust
  • Export Controls and Trade Sanctions
  • Modern Slavery
  • Data Protection
  • Gifts and Hospitality

Regional mandatory in-person induction training

All regional mandatory in-person induction training is coordinated by our legal compliance team based in the UK. Weekly new starter induction sessions are held, alternating between our geographical regions to ensure all employees understand what is expected of them.

We also deliver training in other relevant areas, for example in 2023 we also ran courses in:

  • The ABCs of Anti-bribery and Anti-Corruption
  • Code of Conduct: A Journey of a Thousand Miles

Business Assurance

Internal business assurance audits

Our legal compliance team conducts several compliance related audits each year alongside our existing rigorous external and internal business assurance audits. The objective is to monitor our compliance with various policies and procedures. We assess the related compliance risks and mitigate any identified.

Reporting Concerns

Whistleblowing procedure

Employees with concerns about illegal, fraudulent, or unethical actions can report them to any manager or our legal compliance, HR or business assurance teams. Alternatively, they can use our confidential reporting hotline EthicsPoint. This is available 24 hours a day, 7 days a week. Where local laws allow, the service can be used anonymously. It is operated by an independent third party using local call numbers and online access and is also available for reporting by third-party stakeholders.

In 2023, there were three reports to EthicsPoint – our confidential whistleblowing hotline. Two related to safety issues and one misuse of company assets. All 3 were investigated and found to be unsubstantiated.