The Morgan Code

The Morgan Code is a set of principles supported by policies that lay out how we should conduct ourselves. The Code applies to all employees and, to the extent appropriate, to Morgan’s business partners including agents, joint venture partners and third-party representatives.

The Code has four sections: working safely; working ethically; treating our people fairly; and protecting our business. Copies are available for all employees in key languages. These require employees to operate not only in accordance with applicable laws and regulations, but also in line with internal rules and reporting requirements relating to areas such as ethical business behaviour, trade compliance, hospitality, gifts, donations and sponsorships.

A suite of Group policies brings to life The Code and sets out our expectations in more detail. These policies have been translated into the Group’s key languages and are available for our employees through the intranet.

Processes are in place at site level to ensure the policies are effectively implemented. Morgan’s internal audit function monitors compliance with key ethics and compliance processes and ensures that the ethics hotline and its availability are adequately promoted.

Divisional and global business unit presidents and all heads of functions are required on an annual basis to certify that the businesses and functions they are responsible for have complied in full with Group policies or declared any exceptions. This certification forms an integral part of the Group’s system of internal control.

Employees, contractors or other third parties who have a question about the Code or see something that they feel is unethical or unsafe can discuss these with their managers, supporting teams, or through the ethics hotline, a confidential helpline operated by an independent company.