Sustainability continued
Our focus is on building long-term sustainable relationships, earning trust through meeting our customers’ needs and delivering the highest quality of services. Our Code of Ethics sets the standard we uphold ourselves to and we take pride in our approach. We consider the interests of all our stakeholders, including colleagues, when we make decisions on the Group’s future priorities and plans. Anti-corruption and anti-bribery We do not tolerate bribery and corruption. We have established policies on anti-bribery and the receiving and giving of gifts, and hospitality. Anti-bribery awareness is part of our colleague induction process and regular refresher training is mandated. Colleagues are encouraged to report any concerns to their manager or, if required, our confidential and independent whistleblowing service. The whistleblowing process is overseen by the Audit Committee. We aim to engender in our colleagues principles of honesty and integrity and the desire to work to the best of their ability. We strive to act in a professional, honest and ethical manner in all our dealings with our customers, colleagues, shareholders, suppliers, and the community. Our reputation is paramount and nothing we do should detract from or compromise our standing in the market and the community. Our independence and impartiality as a Group are fundamental. We have a Code of Ethics, which all colleagues are required to adhered to. Supply chain Our customers and colleagues respect us for providing a trusted service, and to achieve this we rely on supply chain partners to support our business operations. We are fully aware of the responsibility we have toward our stakeholders and we seek to work with supply chain partners who are equally aware of and proud to uphold these high standards. Our relationship with supply chain partners is based on trust, collaboration and continuous improvement, underpinned by fair contracts.
We, and our customers, expect our supply chain partners (and their supply chain) to behave ethically and securely and to treat everyone fairly and with respect. Supply chain partners are an extension of the NCC Group team, and our Supply Chain Code of Conduct exists to clearly articulate the standards and behaviours we expect to see in our supply chain partnerships.
Human rights (including anti-slavery and human trafficking)
We recognise our responsibility to uphold and protect the rights of individuals in all aspects of our operations across the world. Through our published statement and our global policies, we make it clear that we will observe and uphold the principles contained in the Universal Declaration of Human Rights and the International Labour Organization Fundamental Conventions. We believe that human rights belong equally to all people without distinction as to race, colour, sex, language, religion, political or other convictions, national or social origin, birth or other traits. We support freedom of association, the abolition of forced labour and the elimination of child labour. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We communicate this to all our suppliers, contractors, and business partners at the outset of the relationship and regularly thereafter. Our Anti-Slavery and Human Trafficking Statement is available to download from our website. Governance and oversight The Board recognises that robust governance and oversight are vital to maintaining a strong business, which can weather a changing business environment. We have a dedicated and independent Global Governance function, which has been designed to work together to ensure seamless oversight of the control environment and management decision making. This team is made up of:
• Group Legal Services • Information Security • Data Protection • Compliance and Standards • Health and Safety • Internal Audit
The Global Governance function reports into the Group Board, or its sub-committees, the Audit Committee and Cyber Security Committee. The primary remit of the team is to validate compliance with the Group’s policies and procedures, legislation and regulations and good practice.
Read more about our governance on pages 70 to 73 and risk management on pages 40 to 48
This Strategic Report was approved by the Board of Directors and signed on its behalf by:
Adam Palser
Tim Kowalski
Chief Executive Officer 14 September 2021
Chief Financial Officer 14 September 2021
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NCC Group plc — Annual report and accounts for the year ended 31 May 2021
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