Devro’s policy on Business Conduct, accessed via this link, sets out what clearly what we expect from our people. All business partners are expected to comply with every aspect of it. At the end of the year, each of our senior people must sign a certificate confirming full compliance with our internal Business Conduct Policy throughout the year. In 2020, 389 people affirmed compliance, and we had no instances of non-compliance.
BRIBERY & CORRUPTION
Devro’s policy is to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and implementing and enforcing effective systems to maintain this policy. All our senior managers are required to complete online training on bribery and corruption, reinforced by face-to-face training where appropriate. Employees or contractors may also be required to complete the training in circumstances where we have identified a potential risk. The main Board reviews the risks associated with bribery and corruption every year to ensure that our procedures remain appropriate and effective. Every year the main Board reviews the risks associated with bribery and corruption to ensure that our procedures remain appropriate and effective. The Board also reviews and approves an annual Global Business Conduct Statement which stresses the company’s commitment to trade in an ethical manner. This statement is then disseminated to all employees throughout the Group at the beginning of the year. No Devro Group company has ever been prosecuted for any offence involving bribery or corruption, and no employees have been disciplined for non-compliance with the Business Conduct Policy.
HUMAN & EMPLOYEE RIGHTS
Devro does not have a specific Company human rights policy since we consider that we are served in this area by the developed culture of ethical business practice and strong labour regulation present in most of the countries in which the Group operates. All the Group’s sites, wherever located, adhere to our own high-standard labour practices, even where local regulatory requirements are not as advanced. We run our business responsibly and ensure that all our employees, customers, suppliers and other stakeholders are treated fairly and with respect. There have been no violations reported against the Company on human rights in 2020 or the previous three fiscal years. Any violations on human rights would be reported and action taken.
Devro maintains an open environment in which colleagues and other stakeholders can raise any issue about any aspect of our business. We support anyone who voices genuine concerns, even if they turn out to be mistaken. Nevertheless, Devro has a multi-language, externally-hosted whistleblowing system primarily designed to offer employees and third-party stakeholders a confidential and anonymous way of raising issues. This covers all individuals working at all levels of the global organisation, including contractors, casual and agency staff. A Board-approved procedure for handling any issue raised through the hotline is in place.
All our employees are entitled to a fair salary and other terms and conditions of employment, as appropriate. We benchmark salary and benefits against similar roles in the same local area annually to ensure that we are competitive. Our policy is to comply, at the very least, with minimum wage legislation for any job role for all employees, although in many instances, wage rates and salaries are higher and we seek to be competitive where our facilities are based. The terms and conditions on working hours are detailed in our contractual terms and, where applicable, within agreements with our Trade Union groups. Overtime is voluntary and the Company will always abide by the legal requirements relating to overtime and payment for it. We pay benefits as appropriate to local markets, and in 2021 there is a review planned to ensure competitiveness. Legally required benefits such as annual leave, sick leave, maternity leave and normal working patterns and hours are of course applicable to all.
FREEDOM OF ASSSOCIATION
We have recognised Trade Union groups in our facilities in the Czech Republic, Scotland and Australia and value their partnership and involvement. We encourage collective bargaining with Trade Union groups and negotiate with them on the terms and conditions for their members and consult with them on changes within the organisation. Employees can become affiliated with a Trade Union and their involvement in that organisation will not affect them in terms of recruitment, promotion, transfers, development opportunities or any other employment arrangements. In Europe, we have a long-established European Forum, consisting of management and employee representatives, who meet annually to discuss, communicate and consult on trans-national issues relating to the business. Where there is no representative group, we establish and encourage an open two-way communication process with employees and have various communication mechanism and methods to keep this active.