Our compliance and ethics programme
With this global programme we aim to create an exemplary compliance environment and embed a culture of integrity across the business. At its heart is our Code of Business Conduct, which sets out what we expect of our people, all of whom are trained on how to behave with integrity in business.
We are committed to conducting our business responsibly and in accordance with all laws and regulations wherever we operate. Our board of directors put in place the compliance and ethics programme to help us live up to this commitment. The programme is managed by our global compliance and ethics director who reports directly to the chief financial officer on all compliance and ethics matters.
We have a confidential independent whistleblowing service, ‘SpeakUp’, and we expect anyone who comes across a breach of our Code to report it immediately to his or her line manager, or to a member of the compliance and ethics, human resources or legal teams, or through the SpeakUp service.
Programme summary and highlights of the year
Our programme is organised into seven areas, each of which has a plan of work for the year.
- Organisation and leadership: embedding the right culture across the business requires managers throughout the company to take it on board and implement it in their own areas.
- Standards and procedures: ensuring we have the right standards and procedures in place, and that they are clear to employees. This year we undertook a full review of our global policies to simplify them and make them easier to follow.
- Training and communications: employees must be given clear guidance on what is expected of them, and the messages must be reinforced frequently. This year we finished the roll-out of our global Code of Business Conduct training to all employees, and created a single induction programme on compliance and ethics for all new employees regardless of geography, role or grade. We have also sought to communicate more transparently with employees about Code breaches to enable continuous improvement.
- Enforcement and incentives: we take a positive approach to encouraging people to do business with integrity, although we also make clear that unethical behaviour is unacceptable and will be treated with the same seriousness wherever it occurs. This year we included compliance and ethics objectives in the performance objectives of all employees from middle manager level upwards. We also refreshed our disciplinary framework which deals with compliance breaches, ensuring that it is clear and is operated consistently throughout the world.
- Due care in delegating authority: doing business with integrity is also about those outside Diageo – our partners and suppliers – and we encourage them to adopt our standards as far as we can. This year we updated our standards for suppliers, and began training them on its application. We also integrated a more rigorous approach to compliance within our M&A process so that we can be confident of the standards of governance and ethics of our potential acquisitions.
- Monitoring, auditing and reporting: ensuring that the programme delivers its objectives is essential for promoting ethical standards throughout the business. The audit and risk committees of the board review the programme and its performance frequently during the year.
- Response and continuous improvement: in order to keep our programme current and consistent with any changes in external laws or regulation, we reviewed it this year in light of the new UK Bribery Act.