Monitoring

CR policy compliance

Business Area Heads and other senior executives will be asked annually to report on compliance with all the CR policies and processes within the Business.

CR audits

Appropriate audits of employee, health and safety and environmental processes should be planned and implemented on a regular basis.

The Group’s Internal Audit function undertakes a comprehensive programme of reviews across the business to check compliance with Group financial controls including specific areas relating to bribery such as compliance with authority levels, review of gift registers and relationships with agents. Audit reports are submitted to the Audit Committee of the Board.

Business conduct/code of ethics – Speak Up

Bunzl must be made aware of failure to adhere to the standards set out in the Business Conduct/Code of Ethics, including any issues relating to accounting, internal controls and auditing matters. The details of any concern can be reported on a confidential or anonymous basis and should be reported honestly, accurately and without malice:

• In the first instance, any concerns should be raised with the employee’s line manager, director in charge or any other senior person within Bunzl with whom the employee feels comfortable. They will either act on the information or pass it to the relevant person who can deal with it.
• If the matter is not dealt with in a manner the employee feels is appropriate, or it is not possible to discuss the matter with the line manager for any reason, the matter should be reported to the Director of Group Human Resources or a message left on the dedicated Speak Up telephone line. Full contact details are posted on the notice board in each Bunzl facility including information on how to report matters anonymously.
• The Director of Group Human Resources will record all reported incidents and report them to the Head of Internal Audit if appropriate. The Director of Group Human Resources will ensure that appropriate action is taken regarding reported issues.
• Any issues, including those handled within the Business Areas, relating to accounting, internal controls and auditing matters should be notified to the Head of Internal Audit at the same time as they are reported to the company.
• Employees should be satisfied that, in making a disclosure, they are acting in good faith and genuinely believe that the information and allegations are substantially true. Bunzl will respect the wishes of employees raising concerns if they ask for anonymity or confidentiality, but Bunzl may need to act to protect its employees, clients and businesses. Appropriate steps will be taken to ensure that the working environment and/or working relationship are not prejudiced as a result of the disclosure.

Bunzl may take advantage of the full range of disciplinary sanctions against any employee who acts or attempts to act in a way prejudicial to an employee who has made a disclosure using this process. Bunzl reserves the right to deal with malicious or false allegations made under this process through the appropriate local disciplinary procedure.

Suppliers/ethical trading

Each Business Area is responsible for implementing appropriate processes to assess key suppliers’ compliance with the CR standards and to monitor performance and improvements against the standards.

Suppliers who are unable to meet all the requirements after an initial assessment/audit will be given the opportunity to comply fully within a period which is deemed appropriate for the circumstances.

If a serious breach is identified following assessment, an action plan should be documented and the supplier will be expected to commit to addressing all the areas where discrepancies have been identified. The process of improvement via this method is principally down to the commitment of the supplier’s management team/owner/agent to ensure that all areas are addressed. If Bunzl has reason to believe that the supplier is not making sufficient or committed progress, then this could lead to a suspension in the relationship until such time that Bunzl is confident that all areas were being satisfactorily addressed.

Bunzl companies reserve the right to cease a relationship with a supplier if it is found that unacceptable practices are being employed at any sites used for producing or sourcing Bunzl products. Such practices include use of child labour, forced or bonded labour as well as physical abuse or discipline and intimidation.