Policies and Management Systems — Business Integrity and Ethics
The company strives to maintain the highest standards of ethical conduct and corporate responsibility worldwide through the application of the principles within its Business Integrity and Ethics Policy. These issues are further safeguarded through corporate governance processes and monitoring by the board and its sub-committees. All employees have a duty to follow the principles set out in the Business Integrity and Ethics Policy. It is integrated into the Group Control Manual and is available to staff at all sites.
Read our Business Integrity and Ethics Policy
International Business and Human Rights
Most Johnson Matthey operations are conducted in developed nations, but a small number of ‘at risk’ countries have emerged as significant growth opportunities for our business in recent years. While the protection of human rights and enhancement of labour conditions are largely the responsibility of governments and international bodies, we recognise our responsibility to conduct our business so as to protect the rights of individuals.
We support the principles defined within the United Nations Universal Declaration of Human Rights and the International Labour Organisation Core Conventions, including the conventions in relation to child labour, forced labour, non-discrimination, freedom of association and collective bargaining. Compliance with and respect for these core principles are integrated within the risk assessment procedures and impact assessments which are undertaken when entering into business in a new territory and within the due diligence processes when making an acquisition or entering a joint venture. Here, significant investments are defined as those that require approval by the Chief Executive’s Committee or the board. All of the significant investments have undergone assessments of human rights or have included specific clauses relating to human rights. This is in accordance with Johnson Matthey's human rights position and our business integrity and ethics policy.
While we are confident of the human rights performance of our own operations, we recognise that business practices in the supply chain are not always transparent and represent a risk that must be managed. Every effort is made to ensure the issues are managed effectively.
Supply Chain
Management of the supply chain and contractor activities is a core component of the ISO 9000 and ISO 14000 series of standards. Supply chain and contractor management questionnaires are a requirement of achieving and maintaining registration and as such, ISO registered Johnson Matthey sites require the completion of appropriate questionnaires. For those sites without ISO registration, the group EHS management system provides policy and guidance on both supply chain management and contractor control.
In March 2009, around 20 people from our businesses’ European procurement teams met to review and discuss sustainable procurement. Participants also shared their ideas on best practice and as a result, development of a sustainable procurement policy for the company has been initiated.
In April 2009, Johnson Matthey conducted a corporate social responsibility audit of one of our most important suppliers, Anglo Platinum Limited. The purpose of the audit was to verify that Anglo Platinum’s policies and philosophy on the non-financial elements of the sustainability triple bottom line are aligned with Johnson Matthey’s position. Six critical elements were scrutinised: management of sustainable development; ethics; labour; environment; health and safety; and communities. For each element the audit team reviewed Anglo Platinum’s published corporate policies, then verified them with local manufacturing site management and finally with groups of workers. The audit revealed that Anglo Platinum’s policies and philosophy on corporate social responsibility are in line with those of Johnson Matthey.
Johnson Matthey's own corporate social responsibility stance is aligned with globally recognised standards published by organisations such as the World Bank and the International Labour Organisation. Performance indicators published by these organisations were used in constructing the audit questionnaire.
A particular focus for the audit was the resettlement project being undertaken by Anglo Platinum at the Mogalakwena development near Mokopane in Limpopo Province, South Africa. Anglo Platinum’s conduct during this project has been the subject of some adverse publicity recently, with allegations made of human rights infringements. Johnson Matthey was keen to visit the area and form its own view. No human rights infringements were identified, although the auditors agreed with Anglo Platinum’s own view that lessons had been learned during the project which would be used to improve management of similar projects in the future.
Ethical Management
Johnson Matthey’s ethical policy is integrated into the Group Control Manual and is available to employees at all sites. Measures are in place to identify and prevent fraud or money laundering through activities undertaken by Johnson Matthey or on behalf of customers.
Johnson Matthey facilities have established policies and procedures through which employees can raise employment related issues for consideration and resolution. A confidential and secure ‘whistleblowing’ website and telephone helpline is also in place to give all employees an additional means to raise any issue of personal concern.
The group control self assessment process assesses the implementation of the ethical policy. Implementation is also assessed as part of the internal audit programme.
