At Our Best - Rolls-Royce Holdings
1At our best:Our approachFebruary 2020At our best: our approach
2Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further InformationAt our best: our approachWhat’s in this pack?12345IntroductionTone from the TopRisk AssessmentPolicy and Procedureincluding Due DiligenceTraining andCommunicationp3Our Values &Behavioursp5p6p8p17p4Ethics and ComplianceProgramme6Ensuring our leaderslive our Values7Speak UpReward and Disciplinep18 Raising Concerns andp22 How we encourage theright behavioursQueriesp20 Handling Concernsand QueriesEnsuring ourprogramme is fit forpurpose8Monitoring and Assurancep23 Verifying theeffectiveness of ourprogrammeOur Code and PoliciesEthics and ComplianceTrainingp10 Recruitmentp11Third Partiesp13Mergers andAcquisitionsp14 Joint Venturesp15Offsetp16 Lobbying and PoliticalActivity9Further Informationp24 Where to go for more
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information13At our best: our approachIntroductionOur Values and BehavioursRolls-Royce is committed to conducting its business ethically andin compliance with the laws and regulations which it is subject to.The choices we make and the things we do are guided by ourvalues. Being trusted to deliver excellence, acting with integrityby always doing the right thing, and operating safely in whateverwe do, will mean that we strengthen our business and enable itssuccess.As set out in our Global Code of Conduct (“Our Code”) our valueof acting with integrity means that we do the right thing all thetime. We act with integrity and follow the law. We live up to all ofour ethical principles and we demonstrate this by being true toourselves, and showing honesty and good judgement in all we do.It is also important that we operate in accordance with ourbehaviours which are to pursue collaboration, seek simplicity,embrace agility and be bold.At Rolls-Royce, we are not only judged by what we do, but howwe do it. To truly be at our best, we expect our employees andthose working with us or for us (such as suppliers or contractors)to demonstrate those values and behaviours every dayEmployees will always be supported for upholding our values andbehaviours and our zero tolerance approach to bribery andcorruption even if sometimes that means we may lose business orsuffer another disadvantage. We assure ourselves of thiscommitment through our monitoring activities (see page 23) andcontinuous analysis of our speak up channels (see page 18).This document provides an overview of the approach that RollsRoyce takes to ethics and anti-corruption compliance.
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information14At our best: our approachIntroductionOur Ethics and Compliance ProgrammeOur programme supports our employees living our values and behaviours everyday to ensure everyone it at their best. Ourprogramme is built around the following key principles, all underpinned by Our Code.The programme is run by our Head of Ethics andCompliance who is a member of the EnterpriseLeadership Group (ELG) of Rolls-Royce. The ELGcomprises of the top 80 senior managers fromacross Rolls-Royce. The Head of Ethics andCompliance reports to the Rolls-Royce GeneralCounsel, a member of the Executive Committee.Tone from thetopMonitoring andAssuranceRisk AssessmentOurCodeReward andDisciplineOur StructurePolicy andProceduresThe Head of Ethics and Compliance has anindependent reporting line to the Chairman ofthe Safety, Ethics and Sustainability Committee ofthe Board. The Head of Ethics and Complianceprovides regular reports to the Safety, Ethics andSustainability Committee throughout the yearand attends all meetings of the Committee.Boardincluding DueDiligenceChief Executive Officer/Executive CommitteeGeneral CounselSpeak UpTraining andCommunicationHead of Ethics and Compliance
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information2Tone from the TopEnsuring our Leaders live our ValuesMessage from our CEOEquipping our Managers with the Tools they needOur commitment to conducting business ethically is reinforced byour CEO, Warren East, in the introductory video to Our Codewhich states as follows:We recognise that it is not just important for our seniorleadership to set the right tone, but that this needs to berepeated and reinforced by managers throughout theorganisation.Therefore, we have also issued a series ofLeadership Expectations in respect of the our core values:Trusted to Deliver Excellence, Act with Integrity, and OperateSafely through which Rolls-Royce encourages all of its managersto be role models for ethical conduct. We must be able to be proud of the way in which we dobusiness and interact with the outside world and with eachother. We have worked hard to create an environment where peoplein Rolls-Royce can work safely and deliver excellence. Thishelps ensure that we are the company that people really wantto work for and really want to work with. It helps keep usstrong, sustainable and resilient as a business. It is important we all follow the principles embodied in OurCode. They will help us protect the brand and the cultureand help us to be the business that we want to be. The Rolls-Royce Executive Leadership Team will supportpeople who speak up and we expect our managers to do thesame, with no tolerance for retaliation or bullying.Regular ReinforcementOur leadership has regularly reinforced our commitment toconduct business ethically and in accordance with our zerotolerance approach to corruption, both internally and externally.Warren East Code Intro Warren East Deferred Prosecution Agreement (DPA) statement Leadership talking about Anti-Bribery and Corruption Further ethics and compliance modules are included in ourleadership training at the various levels of the organisation. Inaddition to our regular training and communication (see page 17)which is often manager-led, we provide monthly dilemmas andreal-life case studies that managers can use to start aconversation about ethics and compliance in their team meetings.5At our best: our approach
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information36At our best: our approachRisk AssessmentEnsuring our programme is fit for purposeEthics and Compliance Risk AssessmentRolls-Royce undertakes an annual bribery and corruption riskassessment, which informs its anti-bribery and corruptionprogramme and compliance resource. The risk assessment looksat: industry risks (including how competitive the markets weoperate in are); the risks associated with the locations of Rolls-Roycecompanies and their sales; routes to market for sales (including the complexity ofcontractual chains and controls over payments to thirdparties assisting in sales); the types of customers we sell to (for example, governmentcustomers); interactions with government officials; other risks identified as part of the company’s enterprise riskmanagement process; culture (based on employee opinion survey results and issuesraised via our speak up channels); the breadth of the Ethics and Compliance Team; the results of any internal Ethics and Compliance MaturityReviews (see page 23); the nature and volume of speak up cases; findings from any audits; and its specialist expertise and knowledge of bribery andcorruption issues arising in the industry sectors it operates inand in general.Deep DiveA deep dive on the ethics andcompliance programme was held withthe Board in May 2019. The Head ofEthics and Compliance presented on theprogramme and the current controlsdesigned to prevent and detectcorruption risks in Rolls-Royce.
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information37At our best: our approachRisk AssessmentEnsuring our programme is fit for purposeRisk Assessment ProcessDevelopmentIn addition to the risk assessments undertaken by the Ethics andCompliance Team, compliance (which includes a number of areasnot just ethics and anti-bribery and corruption) is reviewed by theRolls-Royce Executive Team and the Safety, Ethics andSustainability Committee of the Board as part of theirconsideration of our principal risks, as outlined in the Rolls-RoyceAnnual Report.All risk assessment activity helps the Ethics and Compliance Teamestablish its programme for the following year, including whichsites should receive an Ethics and Compliance Maturity Review(see page 23), what training and communication should beundertaken and/or where to focus resource or a new policy orprocedure. This ensures that the programme is sufficientlytailored to the specific risks that Rolls-Royce faces.This involves ensuring that there are proper mitigation plans andcontrols in place for risks identified as part of the widerenterprise risk management process. Compliance is identified asone of our principal risks, so is subject to ongoing riskassessment, mitigation and scrutiny at the most senior levels ofour organisation.In addition, specific steps taken as a result of risk assessmentfindings have included: Increasing the size and spread of the Ethics and ComplianceTeam, including recruiting full-time ethics and compliancepersonnel in some of our remote (and higher risk) locations. Overhauling our approach to the management and oversightof third parties. Launching a communication campaign on speaking up withan emphasis on the role that managers have to play inembedding a culture of speaking up.Identifying Resource NeedsOne of the main risks identified by ourinitial risk assessment work was a lack ofethics and compliance resources in ourbusiness.At the start of our work to improve ourethics and compliance programme, wehad 20 ethics and complianceprofessionals, most of whom were basedin the UK. We now have over 50 fulltime professionals split between the UK,USA, Mexico, Brazil, Germany, Spain,China, Singapore and India.
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information48At our best: our approachPolicy and Procedures including Due DiligenceOur Code and PoliciesOur CodeOur PoliciesRolls-Royce has a Global Code of Conduct which was lastrefreshed in 2018. The Global Code of Conduct: At Our Best(“Our Code”) is available as a short form document, with a fullerversion available as a separate website.In addition to Our Code, Rolls-Royce has a suite of policies,procedures and guidance governing areas relevant to ethics andcompliance as follows: Anti-Bribery and Corruption Policy (which also coversfacilitation payments) Confidential Information Policy (which covers the appropriateuse of third party information) Gifts and Hospitality Policy Conflict of Interest Policy and Guidance Know Your Partner Policy and Procedures (setting out therequirements for the due diligence and management ofexternal business partners) Lobbying and Political Support Policy Speak Up Policy Charitable Donations and Social Sponsorships Policy Offset ProceduresIt is also available as a digital application (“app”) downloadable byanyone onto Apple and Android devices.Our Code provides the foundations of our ethics and complianceprogramme and having the fuller version available only in digitalform allows us to ensure it remains fresh and current, so that itcan evolve in response to emerging trends and stay fit forpurpose.Having a fully digital code of conduct allows us to track howregularly it is used and which sections people consult with, whichprovides useful data to feed into the development of ourprogramme. In 2019, we recorded 65,608 instances of individualsaccessing Our Code.Our Code Website Our Code App (IOS) Our Code App (Android) Our Group policies Offset Procedures Conflict of Interest Guidance Know Your Partner procedures
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information4Policy and Procedures including Due DiligenceOur Code and PoliciesOur PoliciesExtending Our Code and Policies to Third PartiesAll our ethics and compliance related policies are reviewed andupdated, as necessary, annually and are made available inmultiple languages via our intranet. They are also available onthe Rolls-Royce external website.We include anti-corruption commitments in our contracts with externalparties which bind them to conduct themselves in ways which adhere tothe principles of the Rolls-Royce policies.Our Group policies Offset Procedures Conflict of Interest Guidance Know Your Partner procedures Higher risk third parties are expected to agree to more stringentcontractual commitments, which may include rights of audit andindemnities (see pages 11 and 12).Similar expectations are also set through our Supplier Code of Conductwhich is provided to all suppliers as part of our procurement process.Supplier Code of Conduct 9At our best: our approach
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information410At our best: our approachPolicy and Procedures including Due DiligenceRecruitmentConflicts of InterestRecruiting the Right PeopleEthics and compliance is also incorporated into the recruitmentprocess.In addition, subject to any legal restrictions which may apply in aparticular territory (such as the “revolving door” requirementswhen recruiting former government officials), new recruits(including contractors) are subject to pre-employment screeningwhich includes checks for potential bribery and corruption redflags.New candidates are asked about potential conflicts of interest aspart of that process. If the candidate does ultimately join RollsRoyce then they are required to formally register that conflict ofinterest using our conflict of interest declaration form.All declarations are maintained on a central register and reviewed(and followed up where necessary) by the appropriate member ofthe Ethics and Compliance Team.Conflict of Interest declaration form Conflict of Interest Guidance The Ethics and Compliance Team is directly consulted on anyrecruitment into the Rolls-Royce senior management group toadvise on what additional screening is necessary.As a minimum, senior recruits are screened using a tool whichchecks whether they are named in any adverse media orgovernment watchlists.For higher risk roles, a due diligence report is obtained on thenew recruit from a corporate intelligence provider.Recruiting former public officialsWhen recruiting former public officials,we abide by the applicable rules andregulations relevant to the territory andthe circumstances of that recruitment.
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information411At our best: our approachPolicy and Procedures including Due DiligenceThird PartiesOur Expectations of Business PartnersDue DiligenceRolls-Royce expects the third parties it deals with to demonstratethe same commitment to conducting business ethically and inaccordance with its commitment to anti-corruption.The Rolls-Royce Know Your Partner Policy and Proceduresprovide employees with a framework to do this and set the levelsof due diligence, approval and ongoing monitoring required forall third parties with which we deal.The Know Your Partner Procedures incorporate a risk assessmentthat risk rates third parties based on the following factors:Expectations of our Business Partners The type of service or activity undertaken by the third partyon behalf of Rolls-Royce; The country of incorporation of the third party; The territory(ies) in which the third party will be providingservices to Rolls-Royce; Whether the third party will be interacting with publicofficials, directly or indirectly, in connection with Rolls-Roycebusiness (for example, lobbyists); and The method by which the third party will be paid (for example,commission, sales bonus, profit share, discount, rebate orsuccess fee).Know Your Partner procedures Higher Risk Third PartiesHigher risk third parties would typicallyinclude lobbyists, distributors, agents/intermediaries, suppliers of logisticsservices (such as freight forwarders andcustoms brokers) and visa agents.These third parties are subject tostringent due diligence on both the thirdparties and their ultimate beneficialowners and require senior levelapproval. The approval may be subject toa variety of conditions including: Ethics and Compliance Team approvalof payments Limits on activities (product type andgeography) Refreshing the due diligence withinaccelerated timescales (for example, 1or 2 years) In-depth audits supported by externallawyers and forensic experts Monitoring by our own teams Appointment of commercial contractmonitors Requirement for regular activityreports from third party Limits on commission rates anddiscounts payable to the third party
Contents Introduction Tone from the Top Risk Assessment Policy Training Speak Up Reward Monitoring and Assurance Further Information412At our best: our approachPolicy and Procedures including Due DiligenceThird PartiesOngoing MonitoringTraining our Third PartiesRolls-Royce expects its third parties to sign up to antibribery and corruption commitments as part of theircontracts with Rolls-Royce. The commitments provide aframework for ethical business and allow Rolls-Royce toterminate those contracts in the event of breaches.For high risk business partners, such as agents anddistributors, copies of policies and training are providedduring site visits to those business partners conducted aspart of our due diligence.For higher risk third parties, the contracts include auditrights (which we exercise on rotation), a commitmentfrom the third party to implement its own ethics andcompliance programme, an agreement from the thirdparty to take part in training provided by Rolls-Royceand a requirement to inform us of changes in ultimatebeneficial ownership.Online training has also been made available for businesspartners which is tailored to them and talks about theirrole and our expectations of them from an ethics andcompliance perspective.As part of our ongoing monitoring, some third parties willalso be required to submit to performance review and toprovide written reports on their activities. The Ethics andCompliance Team is required to approve all payments tothe highest risk third parties.Higher Risk Third PartiesTo assist third parties that need toimprove their ethics and complianceprogrammes, we have developed anAnti-Bribery and Corruption ComplianceProgramme Guidance document whichsets out the basic elements Rolls-Royceexpects its high risk third parties to havein their own compliance programmes.For certain types of business partners, training isprovided in person during business partner conferences.For other partners the principles of the Rolls-Royceapproach to combating corruption are covered in ourSupplier Code of Conduct or the “Rolls-Royce Ethics andCompliance Expectations for our Partners” document.It provides practical guidance on whatsteps those third parties can take toimprove their own approaches to ethicsand compliance.Know Your Partner procedures Anti-Bribery and Corruption ComplianceProgramme Guidance Supplier ManagementThe onboarding of new suppliers (regardless of value)and oversight of existing suppliers is overseen bydedicated Procurement teams.The Procurement teams also conduct ongoingmonitoring to look for any expe
4 At our best: our approach Our programme supports our employees living our values and behaviours everyday to ensure everyone it at their best. Our programme is built around Ourthe following key principles, all underpinned by Our Code. 1 Introduction Our Ethics and Compliance Programme Structure The programme is run by our Head of Ethics and
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