Divisional Presidents and all functional heads are required on an annual basis to certify that the businesses/functions they are responsible for have implemented and complied in full with the Group policies or, declared any exceptions. The CEO and the CFO then certify to the Board on a Group-wide basis.
This certification forms an integral part of the Group’s system of internal controls. No material exceptions were declared in respect of 2015.
Internal Audit monitors adherence to key RBP processes including completion of site-level training, RBP in induction processes, compliance with key elements of the RBP policies and the filing of reporting forms. Internal Audit also ensures that the availability of the Ethics Hotline is adequately promoted at site level.
The Morgan Advanced Materials Ethics Hotline enables employees and others who are aware of, or suspect, misconduct, illegal activities, fraud, abuse of Company assets or violations of Morgan Advanced Materials’ policies to report these confidentially without fear of retribution should they feel they cannot use a local channel.
The Ethics Hotline, operated by Expolink and launched in 2011, includes local free-phone numbers in each of the countries in which the Group operates with real-time translators available as necessary.
Issues raised through the Ethics Hotline or via other channels are followed up by the Divisional Presidents or the Company Secretary as appropriate. Further investigation may be conducted through the Audit Committee as required. Where appropriate, disciplinary action up to and including dismissal is taken and/or additional guidance and training provided.
During 2015, 17 reports were received via the Hotline in respect of 13 matters (compared with 31 reports relating to 14 matters in 2014) from the UK, the US, Germany, Brazil, Venezuela, Mexico and Guatemala. Each of the calls related to local human resource grievances or the style/behaviour of local management. The reports were subject to investigation, the results and recommendations then presented to the Audit Committee for approval. No material issues were discovered.