Our Approach to Human Rights
The SGS Code of Integrity (the ‘Code’) sets out our principles on human rights issues covering non-discrimination, freedom of association and collective bargaining, child labor and forced labor, and bribery and corruption. The Code is supported by periodic risk assessments, mandatory training, due diligence procedures, performance monitoring and reporting, and whistle-blowing procedures.
Suspected violations of the Code are reported via an Integrity Helpline or directly to the corporate and local Compliance teams. Investigations are conducted by our trained network of investigators who report to the Global Head of Corporate Security.
The Chief Compliance Officer has overall responsibility for managing compliance with the Code and performance is reported to the Professional Conduct Committee. Senior managers are expected to demonstrate visible and explicit support for the Code and related training programs.
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All employees complete annual integrity training which is updated each year using real-life case studies drawn from the business. Training is typically conducted face-to-face and in teams by trained managers using scenarios adapted to the employees’ areas of work. Employees must sign the Code at the start of their employment with SGS and are required to complete the annual integrity training.
The Compliance team monitors the proportion of employees completing the annual integrity training (AIT) and the e-learning for new employees.
Human rights risks are managed through our business risk management system. Regional monitoring and decision-making are overseen by the Operations Council which assesses our scope of involvement in particular regions and evaluates the risks. When assessing human rights risks, the Operations Council considers four critical factors: (1) compliance with international legislation, (2) safeguarding the safety and security of employees, (3) ensuring the continuity of essential services that enable civil society to function, and (4) preserving our independence, impartiality and neutrality.
Since 2012, SGS has operated a network of over 20 employees trained to conduct professional investigations into internal and external incidents which pose a threat to SGS or our employees. The network is managed by an experienced global Corporate Security team. Investigators are recruited from across SGS, with particular focus on areas that typically have heightened risk. External specialists are brought in as necessary, such as for IT forensic work or due diligence.
During 2013, two new employees based in Mexico and Canada were recruited into the Investigation Network and were trained in investigative skills using guidance based on the European Convention of Human Rights (ECHR). Refresher training is planned for all investigators in early 2014.
Key learnings from investigations feed into the development of the annual integrity training program.