Drafting and Implementing a Global Code of Conduct

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• Drafting and Implementing a Global Code of
  Conduct
• Wolter Kymmell
• Ruth Steinholtz
• 5th March 2009

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• Programme
• Why, What, When, Where, Who.
• Choices involved in introducing a GCOC
• Practical cases and tips
• What did Flexsys learn? Borealis?
• Questions

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• Trends
• Wider recognition
• GCOCs publicly available
• Participation stakeholders increases

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• Why?
• Involvement global markets
• Legal issues
• Improve decision making
• Raise awareness corporate values
• Reputation, media
• Corporate (social) Responsibility

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Effectiveness of Antifraud Methods
Frequency of Antifraud Methods
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• When?
• A.S.A.P. ! ??

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• Who (leads)?
• CEO 95
• GC 92
• HR 86
• BOD 80

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• You will face many choices when beginning to
  consider your ethics programme think about each
  one of them and keep in mind the culture of the
  company at every step of the way

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• Issues vs. Stakeholder Code
• Its a matter of style...

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• Values based vs. Compliance Based
• Many issues to consider here...

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• Short statement of business principles?
• Medium length Code of Ethics or Conduct?
• Lengthy Procedures?
• What considerations would guide this choice?

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• Whistle blowing vs help line?
• Internal vs. External?
• Email, phone or both?
• 24/7 or office hours?
• What considerations would guide the choice?

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• Separate compliance department vs part of the
  Legal Department?
• Other?
• What considerations would guide the choice?

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• Content Questions
• For example, total ban on facilitating payments?
• Gifts and entertainment policies...

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• What?
• Bribery/corruption
• Conflict of interest
• Confidentiality
• Receiving and giving gifts
• Equal opportunity
• Environment
• antitrust

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• How?
• Flexsys a case study
• Define objectives and approach
• Identify and define core values
• Implementation plan
• Maintaining focus

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• Define objectives and approach
• -We do not want this ever again!
• -Review of strategy global teams
• -Agent for culture change Approach
• -Value based vs compliance based
• -1 page vs 70 pages

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• Challenges
• Leadership and cynicism
• How to be global
• From principles to practice
• How to measure success
• How to maintain focus

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• Identify and define core values
• How are we perceived now? survey
• (culture and values)
• Top down process
• How do we want to be perceived?
• Long list of values short list
• Check feasibility and strategy

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• Flexsys core values
• Honesty
• ESH
• Accountibility
• Respect
• Trust

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• Example Honesty
• Demonstrate honour in principles, intent and
  actions by being
• Open
• Truthful
• Unbiased
• Evidence
• -informed workforce
• -Promises are kept
• -Questions are asked and challenges welcomed
• -Constructive feedback is sought and given

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• Decision support the 6 questions
• Why is this bothering me?
• Who and what else matters?
• Is it MY problem?
• What is the core value concern?
• What would others think?
• Am I true to myself?

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Decision Tree

• Use the Decision Tree to help you decide whether
  a course of action is correct when you cannot
  otherwise find the answer in the Borealis Ethics
  Policy

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Framework

• For the occasions on which an issue or situation
  arises which falls into a grey area, use the
  following Framework to guide your thinking

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• Implementation plan
• Communication -site visits by management
• -use of symbols/slogans
• -video delivering the vision
• Educate -focus groups
• -lunch meetings
• -games and presentations
• Lead by example
• Behavioral training programme T.E.A.M.

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• What did we learn?
• Empowerment feels good
• Lead from the top and walk the talk
• Face-to-face
• K.I.S.S. and Fun
• Local involvement
• Create missionaries

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Its a Question of Ethics
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Who was Borealis when the Ethics Excellence
Programme was designed and implemented ?

• EUR 5 billion sales revenue
• Tiny legal department, little resource
• 4,500 employees in 11 countries
• Four European hubs
• Private Ownership

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Team Charter

• Do the groundwork for the development of a new
  Borealis Ethics Policy building upon Borealis
  Values which is clear, easy to understand and to
  use.
• Our aim is to provide Borealis employees with a
  clear set of principles, together with the
  guidance and support they require in order to
  resolve the ethical dilemmas they may face in
  their work. In addition, the Policy will
  contribute to external stakeholders confidence in
  Borealis ethical standards. For this reason,
  the Policy will be published on Borealis
  website.
• We will also develop a draft implementation plan,
  including appropriate training for all users and
  communication to internal and external
  stakeholders to introduce the new Policy.

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Questionnaires interviews in 12 locations,
involving 15 nationalities, covering all BUs,
Functions Sites
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Development The Overall Process
Regular training annual certification
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Managing Ethics Going Forward
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Ethics Pack
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text

• No text

"Expecting an ethics policy to have any effect
when no training is provided really does not make
any business sense." Simon Webley, Institute
of Business Ethics
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Case StoryRon Unstoppable
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text
"I am very impressed by the way in which the
Ethics Policy was developed and implemented in
Borealis. It shows that Borealis takes ethics and
the control environment seriously. Torben
Kristensen Partner, KPMG, Denmark

• No text

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• What do others do?
• Compliance/ethics officer
• Hot line
• Involve other stakeholders, e.g. suppliers
• Make part of bonus system
• F.A.Q. on inter-or intranet
• Integrate in all team meetings
• Look at what BP did!

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• Questions?
• Thank you