Doing the right thing the National Grid experience

Transcription

1 Doing the right thing the National Grid experience Place your chosen image here. The four corners must just cover the arrow tips. For covers, the three pictures should be the same size and in a straight line. IIA Conference Penny Garner, UK Business Conduct Manager and Suzy Reid, UK Ethics Manager

2 Overview Who we are What we do Ethics Setting the tone in National Grid Always Doing the Right Thing publication How we Communicate ethical messages to our employees How we make it real for our employees How we manage conduct issues Questions & Answers 2

3 Who we are and what we do 3

4 Global Ethics Governance National Grid Board Audit Committee Executive Committee Global BCC S.S.R Committee UK BCC US BCC UK Ethics and Compliance Ethics champions Ethics champions Ethics champions Ethics champions 4

5 Embedding ethics at National Grid

6 National Grid s Vision Connecting you to your energy today, trusted to help you meet your energy needs tomorrow. Emphasis on the word trust We earn trust not just by delivering on our commitments, but by also making sure that we do so in the right way It s about how we behave How we work is as important as what we do 6

7 Leadership and Tone at Top Values based Codes Tone Behaviour Policies and Operating Procedures Rules based Tasks / instructions Internal Controls 7

8 A trust culture We ve made a big step in the messages we have included in the introduction to Doing the Right Thing. We set out what having a trust culture means, and our intention to develop and embed it in our business.

9 Bystander apathy Place your chosen image here. The four corners must just cover the arrow tips. For covers, the three pictures should be the same size and in a straight line.

10 Bystander apathy WOULD YOU STOP TO CHECK IF THIS LADY WAS OK? 10

11 Bystander apathy WHY WE DON T STOP Diffusion of responsibility if there are a lot of people around we have a tendency to think that someone else will stop, or why should we Uncertain of the situation We might be scared and unsure what reaction we will get Don t want to get involved not our problem we don t have time it is having no direct impact on us ingroup/outgroup 11

12 National Grid Core Values Respect others and value their diversity Take ownership for driving performance Demonstrate integrity and openness in all relationships Work as one team, one National Grid 12

13 Creating a culture of ethics - messages Guidance, including Always Doing the Right Thing, cannot answer every question. If you are unsure about how to handle a situation, speak up and ask for guidance before you act. Performance is never more important than ethical business conduct. No one, no matter what his or her position in the company, can tell you to do something that is illegal or unethical nothing is more important than doing the right thing. Harassment of, or retaliation against, anyone who reports a concern or cooperates in an investigation will not be tolerated at National Grid. If you are subjected to, see, or hear about retaliatory behaviour of any kind, you should report it immediately We have one set of rules. Always Doing the Right Thing applies to every employee at every level of the company.. 13

14 Creating a culture of ethics - messages If you are not comfortable with local resources or if you reported your concern but it has not been resolved, contact the Business Conduct Helpline. The Helpline is managed by a third party; it is available by telephone or and accepts anonymous reports. Nothing is above question. If you have a concern about an existing process, procedure, or business practice, raise your concern. Because something has always been done in a particular manner, does not necessarily make it right or ethical. National Grid expects employees raise concerns, and values employees who do. When we hear about problems early, we have a chance to fix them. If you need to discuss an issue or concern, we will listen. Ignoring or excusing unethical behaviour will encourage that behaviour. 14

15 Ethical decision making matters RIGHT DECISION WRONG DECISION 15

16 Getting it wrong 16

17 Always Doing the Right Thing Publication Place your chosen image here. The four corners must just cover the arrow tips. For covers, the three pictures should be the same size and in a straight line.

18 Background to Always Doing the Right Thing 2016 Commence 3 year cyclic review 2017 and beyond Consider alternative communication mediums e.g. Apps 2014 Updated guidance launched and branded Group policy statement setting out requirement 2013 Fundamental review of document 2010 Initial guidance document produced and issue to all employees 18

19 Always Doing the Right Thing Our guide to ethical business conduct Speak Up Know the rules Maintain values Act Ethically Comply with laws and regulations Reviewed on a 3 year cycle Distributed to all employees via mail Available on-line internally and externally Comply with company policies

20 Responsibilities National Grid Responsibilities Promote an environment where everyone can do the right thing and feel comfortable raising concerns Investigate facts thoroughly when concerns are raised Not tolerating retaliation or victimisation Protecting people against malicious and untrue allegations Individual Responsibilities Follow the guidelines set out in the book Not to tolerate poor ethical standards in others Ensure there is a respectful working environment Promptly report any unethical behaviour Co-operate fully with all parties in the event of an investigation. 20

21 ALWAYS Doing the Right Thing At National Grid, Doing the Right Thing underpins everything we do. The choices and decisions we make every day really matter. We should all feel confident in voicing our opinions and concerns, and in challenging behaviour which is inconsistent with the principle of doing the right thing even if that might mean missing targets, extra costs or questioning an instruction from your manager. Sir Peter Gershon and Steve Holliday

22 ADtRT - Guidance areas CORRUPTION AND TRANSPARENCY ACTING RESPONSIBLY INFORMATION AND COMMUNICATIONS CONFLICTS OF INTEREST

23 Corruption and transparency Fraud, bribery and Corruption Gifts and Hospitality Political interactions and lobbying Use of company resources Competition Community volunteering, investment and sponsorship

24 Information and communications Data Privacy Information Security Managing Records Global and the internet Social Media

25 Acting responsibly Drugs and Alcohol Safety Environmental Protection Insider Threats Physical Security

26 Conflicts of interest General Conflicts of Interest Price sensitive information, insider trading and material nonpublic information Human Resources

27 Future publications How can we enhance the current publication What linkages can be made to other employee documents Communication medium On-line? Interactive? Benchmarking Feedback 27

28 How we communicate ethical messages internally

29 Overview Global Communications Plan Ethics week Ethics annual event Guest speakers Global Ethics Liaison Networks UK Ethics Champions Network Role of champions Campaigns Stop, think, Go! 29

30 60+ Champions Ethics Champions Gas Distribution Transmission Support functions/other 30

31 Ethics Champions define role Ethics Champion Role Outline Purpose To promote an ethical culture in local teams. To be an ambassador for ethical practices and provide support for colleagues by helping to make sure they understand the key messages and requirements of Always Doing the Right Thing. Key Objectives Increase awareness of Always Doing the Right Thing components Promote an ethical culture and demonstrate the associated behaviours What does an Ethics Champion do? Useful Characteristics Dynamics of a successful ethics programme Engage with local teams to deliver key messages Act as a point of contact for ethical questions/queries Understand the local needs of different departments and the effective communication channels Collaborate with other champions on the creation and delivery of related material/events Share best practice Good communication skills Enthusiastic Role models required behaviour Approachable Provide employees with awareness and understanding of all ADtRT components Encourage and enable all employees to engage on ethical matters Be relevant for each individual/team, seek topics of interest Ensure commitment to maximise benefit of ethics champions network Communicate across networks to address common themes. (Ethics and Compliance) Boundaries No decisions will be made outside of your normal managerial responsibilities All communications delivered under the Ethics banner must be associated and relevant to ADtRT

32 How do we make it real for our employees Themed Communications Case Studies Based on real situations External examples Dilemma s What would you do? On-line training Discussion Topics What factors impact our decisions? 32

33 STOP, THINK, GO 33

34 How can we ensure we make the right decisions? Ask yourself the following questions is the action legal? is it right? Is it honest? (i.e. there is no intent to deceive or mislead) is the action within the terms or the spirit of these Standards, our policies and our values, and those of our business partners? does it avoid creating a sense of obligation? can I justify this to my manager, director and to my family? if I belong to a professional body, does it comply with its codes? would I feel comfortable reading about it in the press? If the answer to any of these questions is no, please seek advice from your manager or conduct offices. 34

35 How do you measure effectiveness? The rich tapestry Exit interviews Helpline statistics Survey Questions Benchmarking Engagement Disciplinary Statistics 35

36 Employee Opinion Survey 36

37 Challenges 37

38 National Grid Business Conduct

39 Business Conduct at National Grid We are an independent team sitting within Global Assurance. We report into National Grid s Group Counsel and Company Secretary. We also provide updates to National Grid s UK and Global Ethics and Compliance Committees, alongside reports to the Audit Committee and Group Executive 39

40 Who do we work closely with? Corporate Audit UK Legal Human Resources Directors Employees The Police Group Security Ethics and Compliance team 40

41 Anti-Fraud and Bribery Provide advice, support and training to the business in relation to anti-fraud and bribery measures including the implementation of adequate procedures to prevent bribery under the Bribery Act E-Learning Tailored training Group Policy on Anti Fraud and Bribery Guidance within Always Doing the Right Thing Support Legal/Corporate Governance Support Certificate of Assurance and Compliance returns 41

42 Investigations We are responsible for the implementation and delivery of a systematic and disciplined approach to the investigation and resolution of all:- Business conduct Whistleblowing Ethics and Fraud matters in the UK Investigations against Suppliers Various types of investigations We create awareness of issues and communicate lessons learnt. 42

43 Raising a concern We are also responsible for manning and maintaining National Grid s Business Conduct.box and the UK Whistleblower hotline. Provide support to Whistleblowers Responsible for National Grid s Whistleblowing Policy 43

44 Gifts and Hospitality Policy Enquiries Investigations System FAQ s Guidance MI Reporting Training and education 44

45 Conflicts of Interest Guidance Investigations Enquiries Training 45

46 Always Doing the Right Thing 46

47 Any Questions? 47