Code of Business Conduct
Babcock aims at all times to act responsibly and ethically when pursuing and awarding business. We understand that our reputation and good name are amongst our greatest assets, which could easily be lost by actual or suspected corrupt or unethical behaviour. To protect the Company and reduce these risks we have set out a policy on how we should all conduct business in the form of the Babcock Code of Business Conduct. Compliance with this policy is compulsory for employees, business advisers and business partners (or, in the case of business advisers and partners they must have equivalent standards and procedures in their own businesses).
The Babcock Code of Business Conduct is a Group-wide policy that sets out the following principles to ensure that those who work with or within the Company do so to the highest of ethical standards:
As a company Babcock:
- Will respect the dignity and rights of its employees and place the highest priority on ensuring the safety of each other at work and the safety of others who might be affected by our activities
- Will seek to minimise so far as it reasonably can its impact on the environment
- Will comply with the law in the conduct of its business
- Will be honest in our dealings with those with whom we do or seek to do business
- Will strive to avoid even the appearance of wrongdoing or impropriety in the way we go about our business
- Will not bribe or attempt to bribe anyone
- Will be diligent in selecting our business advisors and partners so that we minimise the risk of our reputation being damaged by others
- Will implement and observe appropriate training and procedures designed to ensure that we and others working for us understand what our Code of Business Conduct means for them in practice
- Will treat seriously breaches of our code or its associated guidance
And our employees:
- Will avoid (or properly disclose and obtain clearance for) potential conflicts between their interests (or those of their friends and families) and their responsibilities to Babcock or our customers
- Will not take bribes and will report to appropriate management any attempts made to bribe or improperly influence them or another employee in the carrying out of their duties for Babcock
- Will not bribe or attempt to bribe anyone (including by making ‘facilitation payments’) and will report to appropriate management any request or suggestion that Babcock, or anybody working for or with Babcock, should bribe or attempt to improperly influence someone
- Will seek advice on how to proceed if they are at all unsure whether something complies with our Code of Business Conduct or how to apply its associated guidance
- Will be able to raise (confidentially if they wish), without fear of unfavourable consequences for themselves, any genuine concerns they have that our Code or its associated guidance is not being followed.
And our business advisors:
- Must agree to comply, and actually comply, with our Code and this guidance, so far as it is relevant to them, as if they were our employees
And our business partners:
- Should either be willing to subscribe to our Code and its associated guidance or have equivalent standards and procedures in their own businesses
The Babcock Code of Business Conduct is supplemented by a detailed manual available on the Group’s intranet that contains guidelines, authorisation and other procedures aimed at identifying and reducing corruption and ethical risks. For example: an explanation of the law and how it can apply; ‘Red Flags’ to look out for; guidelines and authorisation procedures for giving or accepting gifts and hospitality or making charitable or political donations; due diligence and approval requirements before engaging new business partners; and how to whistleblow concerns. This manual can also be accessed online on the Company’s website at www.babcockinternational.com/about-us/responsibilities/ethical-compliance/.
Employees take online training courses in anti-bribery and corruption risks. Each Division and Group function is required to have a designated member of its senior management team with specific responsibility for ensuring the distribution, communication and implementation of the anti-bribery and corruption guidance, and for overseeing training. Divisions and Group functions are also required to consider carefully whether they need also to designate business unit level or site specific managers with the same responsibility. Anti-bribery and corruption risks have expressly to be considered each year in business unit risk reviews as an integral part of our risk management arrangements. Internal audit carries out a review of the implementation of the Guidance as part of the annual internal audit plan. Divisional monthly reports contain information on anti-bribery and corruption compliance, copies of which go to each Board meeting.
As an international business we recognise our responsibility for upholding and protecting the human rights of our employees and other individuals with whom we deal in our operations across the world. We welcome the opportunity we have to contribute positively to global efforts to ensure that human rights are understood and observed. We believe that a culture of respect for, and promotion of, human rights is embedded throughout our business and can be demonstrated by our commitment to ethical conduct (pages 54-55), our customer and supplier relationships (pages 56-57), the importance we place on health and safety (pages 58-59), the commitment we have towards the people who work for and with Babcock both now and in the future (pages 59-61), and our respect towards the wider society and environment in which we work (pages 62-63), as we set out throughout this Sustainability report.
Babcock insists on responsible, transparent and accountable business practices in accordance with our Code of Business Conduct. Confidential employee whistleblower hotlines are available Group-wide to relay any employee concerns that these standards are not being adhered to for investigation. The service is provided by an independent third party who promptly reports messages received to central Group senior management. Callers can remain anonymous if they wish. The hotlines are intended for use by employees to report concerns that they feel unable to raise with line management (or if they have raised matters, but are not satisfied with the response) regarding financial irregularities, non-compliance with laws, or breaches of our Code of Business Conduct, threats to health and safety, conflicts of interest or improper practices. New employees are made aware of the existence of the hotlines as part of their induction; details of the hotlines are advertised at operating sites.
All whistleblowing incidents are reviewed and a method of investigation confirmed, which can be by a senior manager not directly related to the incident, an external agency or by internal audit. In all cases this review is followed up by a report to Group senior management. Where possible, the caller reporting the incident will be notified of the outcome of the investigation. A report on all whistleblowing calls throughout the Group, the investigations undertaken as a result of these calls, the conclusions drawn and the recommendations and actions resulting is given to each meeting of the Audit and Risk Committee.
The total number of whistleblowing reports in the year to 31 March 2014 was 39. During the same period to 31 March 2013 the number was 40. Details of the number of cases by division and by category are set out below.