Being an ethical, responsible employer and supply chain partner continued...
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. Whistleblowing We are committed to maintaining the highest standards of honesty, integrity, openness, and accountability. It recognises that colleagues, contractors, and other workers have an important role to play in achieving this goal and we expect everyone acting for or on behalf of NCC Group to maintain our high standards. The Group will deal responsibly and professionally with any genuine concern about any wrongdoing in the workplace. Our commitment is underpinned by our Whistleblowing Policy to: • Encourage colleagues to raise genuine concerns about suspected wrongdoing at the earliest practical stage, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected • Provide colleagues with guidance as to how to raise those concerns • Reassure colleagues they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken. All managers are expected to operate an ‘open door’ policy and should therefore make themselves available, either personally or by telephone or email, to resolve issues or concerns. In the past financial year, we published our Whistleblowing policy in six additional languages to English to represent key locations of our operations, publishing on our website. View our Whistleblowing Policy online Risk management Risk is an inherent part of doing business and risk management is a fundamental part of good corporate governance. A successful risk management process balances risk and reward and is underpinned by sound judgement of their impact and likelihood. The Board has overall responsibility for ensuring that NCC Group has
The Board has established a Risk Management Policy, which has established protocols, including: • Roles and responsibilities for the risk management framework • Risk scoring framework • A definition of risk appetite The integrated approach to risk management diagram on page 66 of our FY22 Annual Report summarises the Group’s overall approach to risk management, which is supported by a web-based tool – the Integrated Risk Management System (IRMS). NCC Group adopts both a ‘top-down’ and ‘bottom-up’ approach to risk, to manage risk exposure across the Group to enable the effective pursuit of strategic objectives.
FTSE4Good Index Series FTSE Russell (the trading name of FTSE International Limited and Frank Russell Company) confirms that NCC Group plc has been independently assessed according to the FTSE4Good criteria and has satisfied the requirements to become a constituent of the FTSE4Good Index Series. Created by the global index provider FTSE Russell, the FTSE4Good Index Series is designed to measure the performance of companies demonstrating strong Environmental, Social and Governance (ESG) practices. The FTSE4Good indices are used by a wide variety of market participants to create and assess responsible investment funds and other products.
an effective risk management framework, which is aligned to our business objectives.
Page 13 | NCC Group Communication of Progress
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