Sustainability Report 2011 - Balfour Beatty Rail

Managing sustainability
Ethics, values and compliance
Ethics Helpline
We continued to encourage employees and others to come
forward if they witness or suspect unethical behaviour, and saw a
significant increase in the number of such cases reported via the
Ethics Helpline or other channels. We use the data from our Ethics
Helpline cases to assess and measure our speed and effectiveness
in investigating allegations, our consistency and fairness in applying
sanctions for wrongdoing, and a range of other measures.
“Our reputation depends not only on
what our employees do but on you: our
partners, subcontractors and suppliers –
what you decide, what you do. Our
reputation is a vital asset – so is yours.
I urge you to challenge any unethical,
dishonest or questionable behaviour –
in your organisation and ours – and
speak up when you see things that fall
short of the standards we set ourselves.”
Ian Tyler, Chief Executive
For further details on our Code of conduct
go to P23 for more information
Third party risks
A significant challenge for us is managing third party risk. We have
thousands of subcontractors and suppliers, and consultants and
subconsultants, and many joint venture and consortium partners.
We need to exercise great care to identify and mitigate risks
associated with their actions and to gain assurance about their
ethical standards.
During the year we launched a new Code of Conduct for
Subcontractors, Suppliers and Partners. This plays an important
role, as third parties unable to demonstrate their own embedded
code of conduct and ethical compliance can help provide assurance
by agreeing to comply with our code.
Managing risks in high corruption
risk countries
We have a rigorous approach to managing corruption risks with
projects in high-risk markets. We assess the risks associated with
the specification, prequalification, tendering, award, execution,
certification and payment phases of a project and also any with
third parties we engage. But we do not rely purely on due diligence,
which can be ineffective or misleading. First and foremost we seek
to minimise risks by satisfying ourselves that the client’s processes
are robust and transparent and not easily susceptible to subversion
by a partner or other third party. Secondly, we ensure that there is
a clear, legitimate business justification for selecting and engaging
with all third parties. Thirdly, we try to ensure that opportunities
for corruption by third parties are within our control or at least
visible to us.
24
Independent review of
anti-corruption measures
During 2011, the Global Infrastructure Anti-Corruption Centre
(“GIACC”) continued its detailed review of the anti-corruption
compliance programme across our operating companies. This
included sample risk and commercial management assessments,
and interviews with senior management and compliance officers.
GIACC’s main conclusions in its 2011 report are as follows:
• overall, Balfour Beatty has developed and is implementing a
best practice anti-corruption compliance programme throughout
the organisation
• the leadership from the Board and senior management in relation
to the importance of ethical compliance is clear and unequivocal
• major steps have been taken during 2011 to improve the
compliance programme, and good momentum is being
maintained
• there are differences in the strength and level of implementation
of the programme between different operating companies.
However, these have been identified, and appropriate action
is being taken
• GIACC believes that Balfour Beatty is committed to continuing
to implement and improve its compliance programme on a
long-term basis.
At the end of 2011 GIACC completed its detailed review of all
our operating companies apart from Parsons Brinckerhoff,
whose review will be complete at the end of 2012.
Ethics Helpline data
2009 2010 2011
No. of cases 64 176 284
Our plans for 2012
Our priorities for 2012 and beyond are to continue to embed our code
and our procedures and controls, such as third party due diligence
and ethical assurance in the supply chain, to provide the business
with the support it needs with its growth strategy in new, often
high-risk markets. We seek to improve our processes for recruiting
and appraising employees on the basis of ethics and values, and not
just qualifications and skills. For the last three years our anticorruption
procedures have been independently assessed by GIACC.
We are now developing our internal audit capability to provide
assurance and will be looking at further means of assurance.
Balfour Beatty Sustainability Report 2011