Ethics and compliance

Ethics & Compliance

Our code of conduct, The way we work, provides clear expectations for how we should conduct our business, no matter where we work or where we are from.


We have strong governance and accountability processes to ensure our global business acts in line with the law, local regulations and our values. This includes clear standards around human rights, competition, business integrity (includes bribery and corruption, conflicts of interest, benefits, sponsorships and donations, fraud and other financial crimes and third-party due diligence) and data privacy. 

Our dedicated Ethics & Compliance team operates independently from our operations and provides full-time compliance resources, as well as centralised monitoring and reporting. We hold quarterly risk, assurance and compliance forums to identify, address and mitigate Group-wide and specific business integrity risks and other concerns in our host communities. Our monitoring activities, controls and systems help us identify potential risks and act quickly to address them.

We continuously evolve our monitoring and prevention programme so that it mirrors the risk profile of key assets and business activities and enables targeted intervention and awareness to prevent issues from occurring.

2019 Performance

  • Year in Review
  • Year in Numbers

Fostering Business Integrity

In 2019, we continued to evolve our business integrity compliance programme We strengthened our monitoring programme by increasing our on-site compliance presence to assess and review the operating effectiveness of our business integrity control framework. Our on-site reviews are a key element of monitoring, allowing us to better understand the compliance culture of relevant sites and to identify opportunities for improvement.

We also carried out additional analysis of key business integrity risk indicators to identify potential or emerging compliance issues in order to prevent the chances of these occurring, intervene appropriately and respond to reported incidents in a timely manner.

We improved our annual online business integrity training, both in terms of content and approach, which was well received by our employees. We also introduced revamped questionnaires to better identify risk factors by role, region, country and business unit and to assess employees’ confidence when dealing with ethical dilemmas and business integrity issues – enabling targeted follow-up with employees in 2020.

Raising Concerns

We continued to enhance how we interact with and respond to people who report concerns through Talk to Peggy, our whistleblowing programme. Improving end-user experience led to more regular engagement with and trust in the programme. 2019 saw a 19% rise in reported incidents.

Compliance by Design

A major component of our strategy and focus in 2019 was embedding “compliance by design”, whereby ethics and integrity measures and critical controls are built into existing business processes. As an example, our privacy impact assessments (PIAs) are a key preventative process, working alongside our existing security risk assessments to support transparent, fair and compliant personal data processing across our company.

PIAs are used on all new personal data processing technology, or when new personal data processing or changes to existing processing are likely to result in a risk to the rights of data subjects.

  • 4,400 employees and contractors in 15 countries had face-to-face training in recognising and managing business integrity dilemmas
  • 805 incidents reported either through Talk to Peggy, compliance managers or team leaders, up 19% over 2018
  • 34% of reported incidents were substantiated

Types of Cases Raised:

  • 441 personnel (55%)
  • 142 business integrity (18%)
  • 111 information security (14%)
  • 54 health and safety (7%)
  • 49 miscellaneous
  • 5 finance
  • 3 communities

Talk to Peggy Case Activity

Talk to Peggy by Case Class

Fostering a Culture of Integrity

We know that our integrity – and our reputation for strong governance – hangs on the actions and decisions we make each day across our business.

We are committed to a culture of transparency and encourage our employees, contractors and other partners, including community members, to speak up about their issues and concerns, either through management, our Human Resources or Ethics & Compliance, through our Talk to Peggy whistleblowing service or community complaints and grievance mechanisms.

We empower and equip our people to seek guidance when faced with a business integrity dilemma – both to prevent incidents from occurring, and to protect them and others from harm. This includes providing training to help build employees' awareness of possible issues, like bribery and corruption, and to help promote consistent instincts – and decisions – across the business.

Talk to Peggy

Our confidential and independently operated multilingual whistleblowing service, Talk to Peggy, is available to all our employees and their families, contractors, business partners and communities.

Talk to Peggy provides an avenue for people to share concerns about our business, or an individual's behaviour. This can include suspicion of violations of our policies, standards and procedures, human rights, safety, environmental, financial reporting, fraud or business integrity issues in general.

Concerns can be raised anonymously, but it is important to know that the content discussed and the right to anonymity may be subject to local laws.

If you have a concern, let us know.