How We Manage Ethical Conduct
As a global company, we must combat various different types of misconduct. Our rejection of bribery and corruption is incorporated into the SGS Code of Integrity (the ‘Code’). The Code is supported by periodic risk assessments, mandatory training, due diligence, performance monitoring and reporting, and whistle-blowing procedures. Our global Corporate Security team has responsibility for protecting our people and assets from deliberate harm. We must also protect against the SGS brand being used fraudulently, which could place consumers at risk.
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The Chief Compliance Officer has overall responsibility for managing compliance with the Code of Integrity. Senior managers are expected to demonstrate visible and explicit support for the Code and all relevant training.
Training and Communication
Training on bribery and corruption is included in the mandatory Annual Integrity Training (AIT) for all employees, 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.
New employees must sign the Code at the start of their employment with SGS and complete an integrity e-learning module within the first three months of joining. During 2014, we piloted a new e-learning module which will be implemented globally from January 2015.
Training forms part of a continuous process of learning and reinforcement, which begins with employees signing the Code, completing integrity e-learning and attending the AIT.
Employees recruited into our Investigation Network receive training in investigative skills using guidance based on the European Convention of Human Rights (ECHR). This training is delivered by senior investigators with experience of tackling misconduct in various public and private sectors and industries around the world.
Reporting and investigating incidents
The SGS Code of Integrity encourages employees and customers to report suspected violations of our Code using confidential integrity help lines or directly to the corporate and local Compliance teams. Investigations into internal and external incidents are conducted by our network of trained investigators who report to the Global Head of Corporate Security. Managed by an experienced global Corporate Security team, the network recruits investigators from across SGS, with particular focus on areas with heightened risk (see diagram). External specialists are brought in as necessary, such as for IT forensic work or due diligence. Key learnings from investigations feed into the development of the Annual Integrity Training (AIT) program.
During 2014, 241 integrity issues were reported via our integrity helplines. These included four incidents of bribery and corruption. A total of 109 investigations were conducted. Out of the 109 incidents reported, 42 involved breaches of the Code of Integrity.
The Chief Compliance Officer monitors performance via the Integrity Helpline and formally updates the Professional Conduct Committee on suspected violations and emerging trends. Since launching the revised Code in 2012, there has been a significant increase in the proportion of incidents reported, signaling a higher level of awareness and trust in our reporting mechanism. However, while the volume of reported incidents has risen, we have not detected any increase in the number of proven violations (see Performance section for more information).
The Compliance team also monitors the proportion of employees completing the Annual Integrity Training (AIT) and signing the Code of Integrity, and the proportion of new employees completing the e-learning module on the Code of Integrity (see Performance section for more information).
The SGS brand is used across the world to validate the quality of goods and materials that are sold or traded. Purchasing an item with an SGS logo or certificate verifies that it has met a required standard. The Corporate Security team is responsible for investigating incidents of fraudulent use of the SGS name and brand which includes a growing number of counterfeit certificates and inspection reports. We continue to implement practical measures to ensure that integrity is built into every stage of our operational processes in business lines and countries with identified exposure to this type of fraud. (See case study in our 2014 Sustainability Review to find out how we are dealing with counterfeit products.)