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Ethics

Achieving our goals depends on operational integrity and how our people behave. We expect all our employees to align with our values: Integrity, Commitment, Passion, Seamlessness and Speed. It is fundamental that we uphold these values at all levels and that we adopt the fair business and labor practices our stakeholders expect.

Conducting business with ethics

Our ethics approach includes aspects that influence 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 we expect all our employees, contracted workers and external partners to do the same.

To embed high ethical standards across our entire operation, we formally train every 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, and anti-money laundering.

Our compliance program was developed back in 2011, following the acquisition of Columbian Chemicals and the need for a more coordinated approach to ethics and compliance. Having re-evaluated our Code of Ethics, in 2014 we rolled out a new code, which would be effective in every region we work in, as well as an online training program that reintroduces our employees to the Code of Ethics on an annual basis.

Code of Global Business Ethics and Compliance Standards PDF, 1.3 MB

Ethics: Progress towards our target

100% of active employees to receive Code of Ethics training.

Human rights

For us, respecting human rights is not negotiable and we recognize the valuable role we can play in the protection of these rights. It is crucial to our reputation and our license to operate that respect for human rights is embedded across all our activities and relationships. This includes our extended supply chain. We are committed to respecting the human rights of our workforce, communities, contractors, suppliers and those affected by our operations, in line with internationally recognized frameworks. As a global business, it is a complex challenge, requiring collaboration and investment of resources and time.

We engage with employees at every level of our operations to ensure our commitment to human rights is applied to all our business activities. We strive to comply with, and exceed, laws and regulations 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 the people we employ, do business with or interact with.

In FY2018, we published a new Human Rights Policy, setting out our commitments to upholding human rights in line with the UN Global Compact principles. It covers key issues such as due diligence, employee and stakeholder engagement, diversity and equal opportunities, and forced and child labor.

Birla Carbon Human Rights Policy PDF, 0.9 MB

Antitrust and anti-corruption

We are committed to complying with antitrust and anti-corruption laws in all 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 FY2020, no allegations of corruption were raised.

Grievance measures

We request that our employees voice any concerns or grievances they have about our operations, other employees or our products, and we expect our contractors and suppliers to do the same. To this end, we provide reporting channels enabling them to do so. Our hotline is available for employees to anonymously report, via telephone, text message or email, any illegal or noncompliant 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 HR professionals. The hotline is available at all our plants and offices.

Grievances received

Grievance measuresFY2019FY2020
Hotline calls (total)1017
Calls investigated1016
No further action needed36
Resolved through collective bargaining05
Disciplinary actions75
Formal community grievances00

Labor, human rights and environment

Labor, human rights and environmental grievancesFY2019FY2020
Labor grievances at the local level1417
Labor grievances resolved1217
Human rights grievances filed and resolved01
Environmental grievances filed and resolved30

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 FY2020, the percentage of unionized Birla Carbon sites was 75%. If conflicts occur, we have communications and conflict resolution measures in place for our employees to make their concerns known.

Suppliers

We understand the importance of building a sustainable supply chain, and 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 demonstrates responsibility and transparency. All major suppliers receive a copy of our Code of Ethics in their own language, which they must review prior to the request for proposal stage.

  • In FY2016, we reviewed the contractual Terms and Conditions (T&Cs) that we expect our suppliers to agree to.
  • In FY2017, we worked with legal advisors in each region to tailor our standard T&Cs of Purchase to local requirements.
  • In FY2018, we followed this by conducting a similar process for our T&Cs of Sale.
  • In FY2019, we standardized our T&Cs for all of our suppliers. While these terms may be negotiated subsequently, this standardization provides a baseline from which to begin discussions with potential new vendors.
  • In FY2020, we updated our Purchasing Policies to require use of these standard T&Cs.

We partner with NAVEX Global’s RiskRate®, a third-party due diligence screening program, to vet all of our vendors. We also work with EcoVadis to screen our key suppliers and rate them based on sustainability performance to ensure alignment with our own sustainability goals.

How we engage with our suppliers on ethical issues

How we are supporting the SDGs

SDG 16

Peace, justice and strong institutions

Through our internal governance mechanisms, we prevent corruption and bribery from taking place in our business. This reinforces our own institutional accountability and transparency as well as that of our customers.

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