Standards of Business Ethics HR Aims & Standards             Standards of Business Ethics                     Monitoring compliance with G4S’s business ethics policy around the group   • Internal Audit   • Whistleblowing   • Conclusion             G4S is committed to operating to the highest levels of business ethics throughout its operations.           We have an extensive business ethics policy which provides the backbone to our culture and practice in this area, describing the group’s core standards in relation to different audiences such as communities, business partners, regulators and our employees. Thus the policy covers a wide range of areas including:           > human rights > bribery & corruption > compliance with the law > accounting standards > ILO Declaration on Fundamental Principles and Rights at Work > health & safety > whistleblowing & complaints           The policy is reviewed regularly to ensure it continues to reflect our business model and areas of operation. To demonstrate its importance within G4S, each year the CEO asks all senior managers and executives around the group to reaffirm their personal commitment to this key policy. All new managers receive the business ethics policy and are made aware of its importance to the group – they also sign up to its principles on an annual basis.                 Monitoring compliance with G4S’s business ethics policy around the group In order to maintain the high ethical standards defined in the G4S business ethics policy, compliance is monitored on a regular basis using information reported via various sources including: > global whistleblowing facility > internal/external audit > ongoing management reporting Internal Audit Internal Audit is one of the cornerstones of ensuring high standards of social as well as financial and corporate responsibility by monitoring business compliance throughout the group. In line with the growth and increasing sophistication of the G4S global business, the group’s internal audit resource has been increased over recent years. For 2009 the headcount will be further increased to a total of 14 full time staff, based strategically at different locations around the world. Alongside this corporate internal audit function, G4S has other internal and compliance auditors based in its regions and some of its larger businesses. These auditors total well in excess of 100. The risk-based, three year group audit plan ensures that all businesses across over 110 countries, including those in small and remote locations, receive at least one visit during the three year audit cycle. Whilst ethical compliance has many facets, internal audit is the means to monitor many of these within the general course of a standard controls audit i.e. standards of business practice, corporate governance and employee relations. Specific reviews of financial data provide further assurance on business practices. The businesses’ Risk Assessments and Controls Self Evaluation analysis is reviewed closely and can also indicate weaknesses or issues that need to be addressed. This monitoring activity helps to ensure that both managers and employees have a clear understanding of the group’s ethical standards of operation and the expectations of our stakeholders. Management are also given assurance on their compliance with group standards and any remedial action to be taken is identified. The chart below shows the internal audit activity during the last two years in terms of assignments completed.           No. of Audits and reviews               All issues encountered, whether classified as control related, financial or ethical, are reported to local and regional management. Serious issues are escalated to the group executive management team and the Audit Committee. The chart below shows the number of issues raised in relation to business practice standards, corporate governance and employee relations over the last two years.           No. of issues raised               Through a thorough follow-up process, we make sure that items are addressed and resolved in a timely manner. Currently 4% of the total number of issues raised during 2007 and 2008 are classified as significant, with remedial action to be confirmed during 2009.           back to top           Whistleblowing The G4S policy is that all businesses must provide employees with a facility to report concerns locally to a senior manager. Such concerns could include fraud, misrepresentation, theft, harassment, discrimination or non-compliance with regulations, legislation, policies or procedures. Where employees have concerns about behaviour which is contrary to the group standards they are advised to raise their concerns, anonymously if they so wish, with their local human resources or finance director in the first instance. Employees can also report serious concerns at a corporate level through the group whistleblowing mechanism which consists of a central telephone hotline and email facility. All concerns reported via the whistleblowing facility or received through other means are reviewed directly by the Head of Internal Audit. These are investigated and the appropriate action taken. In addition to the group whistleblowing reporting hot line, there are also hot lines in some of our major business units, including G4S Care & Justice Services UK and G4S Wackenhut in the USA. The chart below shows an analysis of the whistleblowing concerns raised at group level over the last two years.           No. of whistleblowing concerns received               1 which could include HR practices, employee conduct, conflicts of interest, harassment & discrimination 2 which could include theft, fraud, financial misreporting, misuse of company assets, non-compliance with policies and procedures etc           A total of 32 issues were raised in 2008 (2007 – 24 issues). There are five open issues that arose in 2008 which are being investigated or where resolution is pending. All issues from 2007 have been closed. When we do find evidence of unethical conduct, disciplinary action is taken. Disciplinary actions have ranged from formal reprimand to termination of employment. back to top Conclusion At G4S, we believe that by setting ourselves high standards of business ethics, ensuring that managers understand their role in delivering them and by strictly monitoring compliance through a number of methods, we can be sure that our high ethical standards of operation are maintained across the group. You can access the full text of the G4S business ethics policy at www.g4s.com             Back to top