Policies and Control Processes
Our Morgan Code underpins our commitment to our people, our communities, our customers, our suppliers and our shareholders. It defines how we do business and sets out key principles, supported by Group policies, that define how we conduct ourselves. The Morgan Code has four sections covering working safely, working ethically, treating our people fairly and protecting our business. The Morgan Code applies to all employees and, where appropriate, our business partners including agents, joint venture partners and third-party representatives.
Supporting the principles of the Morgan Code are a suite of Group policies, including Bribery Corruption and Facilitation Payments, Competition Law and Anti-Trust, Trade Controls, and Information Security.
Morgan’s ethics and compliance policies are available to employees in multiple languages, together with related manuals and guidelines. 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, gifts & entertainment, donations and sponsorships.
Third party management
Our policies also apply, to the extent appropriate, to Morgan’s business partners including agents, joint ventures and third party representatives. In particular, Morgan’s Supplier Code of Conduct sets out the minimum conduct standards that we expect from our suppliers globally. Our Supplier Code focuses on treating people fairly, complying with health and safety rules, protecting the environment, and adhering to important ethics and compliance obligations.
A new Conflict Minerals Policy was published which sets out Morgan’s position on avoiding the sourcing of conflict minerals including tantalum, tin, tungsten and gold from areas where the revenue may aid the furtherance of human rights violations and other illegal activities. We expect our suppliers to adhere to the same principle.
We recognise the importance of making informed decisions when considering new or renewed business relationships with third parties. We are implementing a new third party management system to strengthen our ability to risk assess and conduct appropriate due diligence checks on certain third parties such as agents and distributors.
All policies, manuals and guidelines are subject to routine review.
Control processes are in place at the site level to ensure the policies are effectively implemented.