Target: 100% of active employees to receive Combined Code of Ethics training
Conducting business with ethics
Our ethics approach includes aspects that support our business activities: human rights; antitrust and anti-corruption; grievance measures; and collective bargaining. We ensure that ethical conduct is embedded across our operations, and expect our employees, contracted workers and external partners to do the same.
Our five key values, aligned to the Aditya Birla Group, drive everything we do: Integrity; Commitment; Passion; Seamlessness; and Speed.
We embed high ethical standards across our operations by formally training each employee, who must then sign a document confirming their compliance with our Code of Global Business Ethics and Compliance Standards (Code of Ethics). The Code of Ethics covers our policies on fair competition, antitrust, freedom from discrimination and harassment or other abusive situations, as well as anti-money laundering.
Human rights are of increasing importance to all businesses: it is important that respect for human rights is embedded across all activities and relationships. Making this happen requires investing resources and time. We engage at every level of Birla Carbon to ensure our commitment to human rights.
We respect human rights in all our business activities and strive to comply with the laws and regulations in place wherever we operate, as well as adhering to international standards and those of our own Group. We seek to proactively prevent and address any negative impacts we may have on the rights of people we employ, do business with or interact with.
Antitrust and anti-corruption
We are committed to complying with the antitrust and anti-corruption laws of all the locations where we conduct business, and we intend to uphold competitive free enterprise while prohibiting payments or promises to pay anything of value to obtain or retain business. In FY2017, two allegations of corruption were raised, investigated and found to be without merit.
We require our employees to voice any concerns or grievances they have about our operations, our employees or our products, and we expect contractors and suppliers to do the same. To this end, we provide reporting channels to enable them to do so. Our hotline is available for employees to anonymously report, via telephone, text message or email, any illegal or non-compliant behavior they observe. The hotline is run by an independent third party, 24 hours a day, 365 days a year and escalates issues to our Internal Audit Department and Chief Legal Officer.
Employees may ask questions concerning actual or potential situations, and calls made to the hotline are handled in full compliance with local law. Depending upon the issues, these are then investigated by a team of auditors and/or human resources professionals. The hotline is available at all our plants and offices.
|Hotline calls (total)||17||5|
|No further action needed||9||4|
|Resolved through collective bargaining||5||0|
|Formal community grievances||0||0|
Labor, human rights and environment grievances
|Labor grievances at the local level||15||16|
|Labor grievances resolved||4||13|
|Human rights grievances filed and resolved||1||6|
|Environmental grievances filed and resolved||4||1|
Collective bargaining agreements
We are committed to absolute fairness when it comes to employee concerns such as wages, working hours, benefits and conflict resolution processes. As such, we sign legally binding collective bargaining agreements to ensure we operate fairly and consistently with all our staff. In FY2017, the number of unionized Birla Carbon sites was 75%. If conflict issues occur, we have communications and conflict resolution measures in place for our employees to make their concerns known.
We expect our external partners to adhere to the same standards and principles of ethics and integrity as we do. It is vital that every member of our supply chain can demonstrate responsibility and transparency. Over the last two years, we sent our major suppliers a copy of the Code in their own language; in FY2016, we reviewed the contractual Terms and Conditions (pdf, 140KB) that we expect our suppliers to agree to.
In FY2017, we worked with legal advisors in each region to tailor our standard Terms and Conditions of Purchase to local requirements. We did this because some clauses and provisions may be unenforceable or not applicable in some locations. We plan to conduct a similar process for our Terms and Conditions of Sale in FY2018.
Read more on how we engage with our suppliers on ethical issues.
A robust approach to ethics
Birla Carbon’s acquisition of Columbian Chemicals Company in 2011 presented several opportunities and challenges – including creating a unified approach to ethics. It is our guiding principle that the highest standard anywhere will be the minimum standard everywhere. Since 2011, we have invested time and resources to carefully developing a Code of Global Ethics and Compliance Standards (Code of Ethics), which we have rolled out in the following ways:
- Employees – our Legal, Audit and Human Resources departments worked together and produced a new e-learning module in our 11 local languages on the Code of Ethics, which was launched in FY2014. All our employees complete this course annually.
- Suppliers – we contacted our major suppliers, representing over 90% of our total global purchases, initially to explain our expectations on ethics and subsequently to include a paragraph on ethics in our contractual Terms and Conditions. Over FY2017, we have started screening select supplier groups for their ethical performance.
We aim to take our ethics approach further in FY2018, by expanding our screening program to other suppliers and taking full control of our employee training system. We are constantly seeking new ways to ensure that the business we conduct meets and surpasses the highest ethical standards.