The principles covered in this policy cover all areas of Goodwin PLC's operations and have been developed and continue to be reviewed against and updated by reference to relevant codes of corporate governance and international standards including the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, the Guidelines for Multinational Enterprises established by the Organisation for Economic Cooperation and Development (OECD), the Rio Declaration on Environment and Development and the UN Convention against Corruption and the UK Modern Slavery Act 2015.
The Board of Directors supports the principles set out in those codes and standards and the aim of this policy is to translate that support into a set of guidelines and standards that set a common approach for Goodwin PLC and provide practical guidance for our managers, employees and contractors. We wish to be transparent, fair and reasonable.
This code applies to all of the operations of Goodwin PLC and its subsidiaries (“the Group”) and sets out the minimum standards which the Board of Goodwin PLC expects from staff in their internal and external dealings with colleagues, customers, stakeholders and third parties.
We always conduct our own services honestly and honourably, and expect our clients and suppliers to do the same. Our advice, strategic assistance and the methods imparted through our training, take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers.
Basic standards of conduct:
Compliance with Law:
Conflicts of Interest and Confidentiality:
The Group is committed to ensuring that its companies (www.goodwin.co.uk) and supply chains do not undertake any activity which contravenes the UK Modern Slavery Act 2015 (Act). The Group has a ‘zero tolerance’ policy to slavery and human trafficking.
As required by the Act we are required to disclose the steps we have taken during the year to identify and eradicate modern slavery and human trafficking. These include an assessment of country, sector, transaction and partnership risks through an induction and awareness programme reviewed by the Audit Committee for effectiveness. Transparency is encouraged through whistle blowing awareness and the maintenance of personal visits by management where possible. Particular attention is paid through our Know Your Customer policy to find true identities and during the year to 30th April 2018 Steven Birks, a Main Board Director was nominated to mentor all subsidiaries in risk analysis including the effectiveness of KYC. Considerable effort was also put in to implement the requirements of the General Data Protection Regulation to avoid identity theft through fraud.
Supply Chains and Suppliers
The Group focuses on manufacturing within mechanical engineering and refractory engineering sectors. Our mechanical engineering sector serves the oil, petrochemical, gas, LNG and water markets as well as defence contractors, civil aviation authorities and border security agencies. Our refractory sector serves the jewellery casting, aerospace, fire protection, tyre moulding and shell moulding casting industries.
The Group operates in the UK, Australia, Brazil, China, Finland, Germany, India, South Africa, South Korea and Thailand.
The makeup and complexity of supply chains :
The Group has the following policies in place:
The Group will consider adopting and implementing the good practice guidance and tools such as Stronger Together (www.stronger2gether.org) across the Group and review existing policies to assess how these work to prevent modern slavery.
Supply chain ethics: We visit and write letters to our major suppliers in line with the United Nations Global Compact voluntary initiative. The letters invite our major suppliers to adopt, implement and evidence adequate compliance policies.
Anti-Slavery and Human Trafficking Policy: The Group has implemented and introduced for major suppliers:-
The Group will take steps to regularly assess, prevent, manage and mitigate the risks within our business and supply chains in high risk countries as identified on the Global Slavery Index (https://www.globalslaveryindex.org/index/).
In 2016, Directors and Senior Management attended a Culture and Conduct workshop at our Business conference which dealt with Corporate Social Responsibility issues such as modern slavery and human trafficking.
During the year to 30th April 2018 considerable effort was made in setting up on-line training courses in respect of many of the Group’s policies including, amongst others, those on Modern Slavery and KYC. Directors of all subsidiaries are encouraged to undertake these courses and tests and also to flow the values and best practices down within their own companies taking into account local legislation in order to achieve an understanding of best practice. This was re-emphasised during a recent business conference attended by Directors and senior managers.
This Statement was approved by the Board on 29th October 2018 and is signed on its behalf by:
John W Goodwin, Chairman
The Group has outlined employee responsibilities in observing and upholding its position on bribery and corruption
We provide information and guidance to those working for the Group on how to recognize and deal with bribery and corruption issues.
We conform with the laws of the England and Wales, including the Bribery Act 2010.
It is the Group's policy to conduct all business in an honest and ethical manner. A zero-tolerance approach to bribery and corruption will be taken and all laws relevant to countering bribery and corruption will be upheld.
This policy applies to all individuals working at all levels within the Group who interface with external sources, including all employees and Directors, consultants, contractors, trainees, apprentices, interns, seconded staff, casual workers, agency staff, volunteers, agents, sponsors or any other person associated with the Group wherever located (collectively referred to as Workers in this policy).
The Directors have overall responsibility for ensuring this policy complies with the legal and ethical obligations of the Group, and that all those under its control comply with it.
The Chairman has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
All employees are responsible for:
We wish to be transparent, fair and reasonable in processing and storing personal data.
Adopting the EU General Data Protection Regulations, the Group expresses a privacy notice on all its websites. To promote transparency and fairness we have carried out data impact analysis on our processes known to handle personal data. We will continue to consult and include individuals responsible for handling data with the intention of training them to comply with the Regulation. We aim to inform people how their data is used, gain consent and give choice in their personal data handling.
Personal data is encrypted and for contractual, insurance and legal requirements may be retained for periods proportionate to those needs and, where requests for data removal are refused, explanation will be given. The Data Protection Officer is the Chairman contactable through the Company Secretary email@example.com to whom any complaint should be made in the first instance and in the absence of resolution contact should be addressed to the independent Non-Executive Director.
The Group does not at present make contributions to political parties., The Group only makes charitable donations that are legal and ethical under local laws and practices.
Climate change is recognized as an international issue with national governments on both sides of the Atlantic committed to taking action to reduce greenhouse emissions.
The Group is acutely aware of its greenhouse gas emissions, for which we understand that there is a need for Group companies to contribute to targeted global reductions. We are committed to reducing the greenhouse gas emissions from our operations in a way which supports national government strategies and in line with our commitment to our customers to provide safe, efficient and reliable products and services.
Our key climate change commitments are:
Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If it is uncertain whether a particular act constitutes bribery or corruption, or if there are any other queries, these should be raised with an appropriate director. Concerns may be reported by following the procedure set out in the Whistle Blowing Policy.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Training and Communication
Training on the policy will be given to all those that have interface with external sources. This should be identified at the induction stage for all new employees, though existing workers will also receive training as appropriate.
A zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
Monitoring and Review
Directors will monitor the effectiveness and review the implementation of the policy during the annual management review considering its suitability, adequacy and effectiveness.
Any improvements identified will be made as soon as possible and this policy amended as required.
Internal control systems and procedures will be subject to audit to provide assurance that they are effective in countering bribery and corruption.
Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Chairman.
Anyone who has a reasonable belief that there is serious malpractice relating to any of the matters specified above, may raise a concern under the procedure detailed in paragraph below.
The issues raised may relate to another employee, a group of employees, the individual's own Board of Directors or other parties such as subcontractors
Concerns must be raised without malice and in good faith, and an individual must reasonably believe that the information disclosed, and any allegations contained in it, are substantially true.
In view of the protection afforded to an employee raising a bona fide concern, it is preferable if that individual puts his/her name to any disclosure. The identity of the person raising the matter will be kept confidential, if so requested, for as long as possible provided that this is compatible with a proper investigation.
Anonymous complaints are more difficult to authenticate but may be reported by dialing a telephone answering machine and leaving a message. This will be listened to by the Chairman or Company Secretary and investigated or acted upon as the person receiving the complaint sees fit (including the use of this procedure), having regard to the seriousness of the issue raised, the credibility of the complaint, the prospects of being able to investigate the matter, and fairness to any individual mentioned in the complaint.
Any disclosure should be made in the first instance in confidence to:
If no response is received following a disclosure from a named individual or the individual is dissatisfied with the response then the individual may raise the concern with the Partner of the Company’s Auditors:
KPMG Audit PLC (Tel: +44 (0) 121 232 3000)