Morgan Code

The Morgan Code is a foundational component of our ethics and compliance programme. The 'Code' is a set of principles supported by policies that lay out how we must conduct ourselves, in support of our people, our communities, our business partners and our shareholders.

The 'Code' applies to all employees and, to the extent appropriate, to Morgan’s business partners including agents, joint venture partners and other third-party representatives.

The 'Code' has four sections

1. Working safely
2. Working ethically
3. Treating our people fairly
4. Protecting our business.

The 'Code' is publicly available in 19 languages. It requires our people to operate in accordance with applicable laws and regulations, and Company policies and processes relating to areas such as ethical business behaviour, trade compliance, gifts and entertainment, donations and sponsorships.

Our 'Code' is implemented through a suite of Group policies which set out our expectations in detail. We required all senior employees to certify that they have read, understood and agree to comply with the Morgan Code and the supporting policies which are relevant to their role.

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 (EQS).