Responsibility

Business Ethics

Code of Conduct

Our Code of Conduct has been developed to promote ethical behaviour from all our employees and is based on our foundation of core company values. The core principle is that each one of us must take individual responsibility for our actions and behave ethically and compliantly. It includes companywide and local employment policies, procedures and practices, including equal opportunities and diversity, non-harassment, violence prevention and family-friendly policies, which in many instances exceed the minimum local statutory requirements. It also includes business ethics policies, procedures and practices on transparency, independence and impartiality, risk management, data protection, corrupt practices, confidentiality, insider dealing, competition and anti-trust matters. A comprehensive section on whistle-blowing encourages our employees to report any concerns and provides for them to do so with anonymity.

Find out more about our Code of Conduct.

Employee engagement

We believe that we can facilitate greater employee engagement in the business by providing forums for two-way dialogue, information exchange and collaborative working. We have a structured internal communications framework for the Group, and we use a number of different communications channels, including our new SharePoint-based intranet, email and monthly companywide meetings.

We recently updated and reissued our HR Policy Guide. It provides our employees with a reference guide to help them understand the policies and procedures that affect their employment and benefits.

We recently partnered with the consultancy Great Place to Work^® Institute to launch an internal employee engagement survey to measure if our employees and leaders are living our company values and give us insights into general employee satisfaction. We received valuable feedback which we are already putting into action through local employee representative committees and we plan to conduct our next survey in 2012.

Training and developing

Our success depends on the abilities and skills of our employees and we recognise that training and development helps them fulfil their maximum potential, while also benefiting the business. Training and development is an important part of each employee's annual appraisal process and a training team is available in the UK to help identify suitable opportunities. Identified training and development needs are reviewed on a regular basis to ensure relevance for both the employee and the company. Lunch and Learn Seminars also seek to capitalise on internal expertise and disseminate knowledge internally, for the benefit of all employees. Work placement and internship requests are considered on a case-by-case basis at each site.

We conduct regular workshops for employees at all sites to ensure that the importance of our values is recognised. We aim to live by our values and they are formally measured as part of the employee appraisal process.

Targets for 2011-12

• Complete Compliance training for our new colleagues at Biocompatibles sites and roll out a Compliance certification process for all employees; and
• Complete Horizons 2, the second companywide Leadership Training Programme.