Behaving ethically and transparently
“Doing what’s right and owning it are two values that represent who we are at Convatec. We recognise that we need to make sure that our business decisions at all levels embody these values and we embed ethical behaviour in everything we do. By doing so, we earn trust, build stakeholder confidence and ensure that we act with integrity and do what we say we will do.”
Evelyn Douglas, EVP, Corporate Strategy and Business Development, General Counsel and Company Secretary
Our approach
How we conduct ourselves in commerce – earning trust by behaving responsibly with integrity and doing what we say we will do – is essential if we are to achieve our vision and create value for our stakeholders. It is also the right thing to do and protects our reputation.
Our extensive ethics and compliance programme incorporates several policies and procedures including:
- Maintaining a Code of Ethics and Business Conduct
- Making available an independently provided Compliance Helpline and web link for employees and third parties
- Assuring the existence of mechanisms to ensure issues can be reported and reviewed
Our targets & commitments
In the past year, we have updated our Code of Conduct to reflect amended laws and industry codes, and expanded the scope of our due diligence process for added categories of third parties. We also re-established Convatec’s Human Rights Committee as a working group under the direction of our ESG Steering Committee. This committee will help to hold the company accountable to meeting targets around behaving ethically and transparently, including:
- Keeping human rights-related policies updated to current global standards and expectations.
- Expanding Code of Conduct training across the business.
- Expanding the use of our supplier assessment platform.
For more information about how we behave ethically and transparently, see pages 50 to 52 of our 2021 Annual Report.
Policies, procedures and resources
We maintain a Code of Ethics and Business Conduct and a series of Global Policies which cover a range of business conduct and compliance issues, focusing particularly on anti-bribery and anti-corruption. All employees are required to complete the training on our Code of Conduct.
A Compliance Helpline is available for employees and third parties to report suspected breaches. Any issues reported are reviewed by our ethics and compliance function and the resulting investigation and outcome of any significant issues are overseen by the Audit and Risk Committee.
Transparency
| Rating organisation | 2017- | 2018 | 2019- | 2020 | 2021 |
|---|---|---|---|---|---|
| ISS-oekom | C- | C | B- | B- | B |
| Sustainalytics Overall Performance | 64/100 | 72/100 | 74/100 | 73/100 | Not available |
| Sustainalytics Risk Rating1 | 16.5 | 15.3 | 15.2 | 14.6 |
1. As at 28 Oct. 2021. Lower scores are desirable for Risk Rating while higher scores are desirable for Overall Performance.
Code of Ethics and Business Conduct
Convatec's Code of Ethics and Business Conduct (Our Code) embodies our corporate vision and corporate values. We are committed to creating a working environment where everyone is treated fairly with respect, dignity and consideration and where there are opportunities for all. Our Human Rights and Labour Standards Policy, which incorporates principles and guidelines set out in the United Nations Universal Declaration of Human Rights, Modern Slavery Act and the UN Guiding Principles on Business and Human Rights, addresses a range of issues including equal opportunities, anti-harassment and dignity at work. Many elements of our Human Rights and Labour Standards Policy are reflected in our Code of Conduct. Our Code of Conduct and Human Rights, Labour Standards Policy, California Supply Chains Act statement and Modern Slavery Act statement are available here.
Working responsibly with partners
We require new suppliers to adhere to our Global Third Party Compliance Manual (the “Manual”) which covers a range of topics, including commitments to the International Labour Organization conventions and the Principles of the UN Global Compact and environmental protections, and extends our Code of Conduct and our Human Rights and Labour Standards Policy to the supply chain, which prior to 2022 were addressed in our Supplier Code of Conduct. The Manual is introduced to all existing supplier contracts as these are renewed. A copy of our Manual is available here. We monitor and assess suppliers using third-party risk platforms, which provide in-depth, real-time coverage of a range of factors that could impact supplier performance (including geopolitical, climatic and civil unrest), as well as events that may have been caused by our suppliers (for example major pollution and strikes incidents).
EcoVadis
We strengthened our supplier due diligence in 2021 by expanding the use of a third-party provider, EcoVadis. The EcoVadis platform offers an evidence-based assessment of our supply base covering four themes: environment, labour and human rights, ethics and sustainable procurement. The resulting EcoVadis score is now incorporated in the compliance section of our supplier relationship management scorecards. As of December 2021, we include an assessment of potential new suppliers’ ability to participate in EcoVadis as part of our new sourcing process. This assessment is part of the Request for Information (RFI) and Request for Proposal (RFP) phases.
For more information about how we work responsibly with our partners see page 51 of the 2021 Annual Report.
Supplier Diversity
We use a database maintained by a third party to verify the status of potential vendors as women or minority-owned businesses, and supplier diversity is a consideration when we select our partners. In addition, our supplier selection and oversight processes require us to proactively assess that positive progress is being observed throughout our Logistics Supplier base. Third party logistics providers are expected to have set DE&I targets which we assess at the time of their appointment and monitor through supplier annual performance reviews.
Global Third-Party Compliance
In many countries Convatec conducts its business via third party distributors. We expect and require that our distributors comply with all applicable laws and regulations and follow the Convatec Code of Ethics & Business Conduct. To support our distributors’ compliance efforts, we have prepared the Convatec Global Third Party Compliance Manual.
