Operating with high ethical standards at all times embodies the Carillion Values in practice.
Carillion takes the effective prevention and detection of fraud, bribery and corruption extremely seriously, and we are committed to promoting a zero tolerance approach. Our Ethics and Compliance Office is responsible for reviewing and monitoring compliance with ethics policies and procedures and relevant laws and regulations. These are primarily the UK Bribery Act 2010 and competition laws and their equivalents in all the territories in which we operate.
A compliance annual return is completed by directors and senior managers across the organisation. The annual returns are required to detail and certify controls in operation to ensure the control environment is appropriate.
Carillion has also launched an Ethics and Business Integrity Response Plan, which details the actions that should be taken in the event of a suspected breach of the Ethics and Business Integrity Policy. It is designed to ensure that investigations are conducted fairly and decisions are taken by appropriate individuals commensurate with their roles.
For more on how we embed our Values see Engaging our people.
Stamping out fraud and corruption
Within our Disciplinary Policy, examples of gross misconduct include ‘any actions of bribery, including both the offering and accepting of bribes’. Through our employee management system, Oracle, employees can now record any conflicts of interest, and gifts and hospitality.
In 2012, over 1,500 people across the Group received face-to-face and online training on our competition policies.
We encourage employees to raise concerns about fraud, corruption, or any other malpractice at the earliest possible stage, with their managers or through monthly Team Talks and feedback sessions. We also have a confidential whistleblowing hotline provided by an independent third party. Of the 122 whistleblower reports received across the Group in 2012, 48 resulted in disciplinary action taken against staff, 41 cases were either unfounded or required no action, and the remaining 33 are currently under investigation.
A response to claims of blacklisting
Along with other companies in the construction industry, campaigners have accused Carillion of being involved in the blacklisting of workers. Carillion does not condone or engage in blacklisting and takes very seriously any accusation that it does so.
In 2009, the Information Commissioner’s Office (ICO) raided an organisation called the Consulting Association and uncovered a database containing information on over 3,000 people. A former subsidiary, Crown House Engineering, the only Carillion subsidiary to access the database, stopped using it voluntarily in 2004 – several years before the practice became illegal. According to the ICO, Crown House was one of more than 40 construction companies to have used the database. Carillion was not one of the 14 construction companies against which the ICO took enforcement action.
In 2012, Carillion was dropped from a class action related to blacklisting.
We take our commitment to transparency and openness extremely seriously, and we are the only company to talk openly about this issue. Richard Howson, our Chief Executive, led the industry when he apologised for our subsidiary’s use of the database, and we have made a full and voluntary submission about the issue of blacklisting to the House of Commons Scottish Affairs Committee investigating blacklisting in employment.
We have positive working relationships – and formal recognition agreements – with a number of unions across the country. Read more about our response to blacklisting allegations on our website.
employees across the Group (excluding senior management) have completed anti-corruption courses in 2012
We support the UN Universal Declaration on Human Rights and treat all our internal and external stakeholders fairly. See our Ethics and Business Integrity Policy.
“By all living the Values in and out of work, we can build stronger relationships of trust with customers.”Nigel Taylor, Chief Operating Officer, Carillion Services
employees have received human rights training in 2012
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