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As a multinational group, Imperial is subject to a wide range of legislation. It monitors legislative developments on an ongoing basis and has a legal compliance programme to increase awareness of, and enhance compliance with, applicable legislation.
Legal compliance is reported regularly to divisional boards and risk committees and quarterly to the group audit and risk committees.
To maximise synergies and cooperation, the compliance and legal officers meet in a quarterly forum. Key objectives of the forum are to:
Business units have dedicated legal functions to review contract terms and conditions, and to monitor compliance with these on an ongoing basis. Existing contracts are monitored to ensure they are up to date and in line with legislative and commercial changes.
The group has a formal conflicts of interest policy that guides directors to act in the best interests of the company, with due care and diligence in discharging their responsibilities as directors. The policy requires directors to declare and avoid conflicts of interest in accordance with the Companies Act, 2008 (the Act), and to account to the company for any advantages gained in discharging their duties on behalf of the company.
No group director or employee with inside information about the group may deal, directly or indirectly, in Imperial’s securities, which include allocations of and dealings in the group’s share incentive schemes. Imperial’s closed periods are from the 1st of January until interim results reporting date and the 1st of July until full-year results reporting date. In addition, the group has adopted a policy requiring directors, executive committee members, the company secretary and directors of major subsidiaries to obtain permission from designated individuals before trading in the group’s securities.
No infringements were reported during the year.
Whistle-blowing hotlines are in place in all regions in which the group operates. This service, operated by independent service providers, enables all stakeholders to anonymously report concerns.
It is the responsibility of all employees and stakeholders to report known or suspected unethical or illegal conduct. Retaliation against whistle-blowers is not tolerated.
Internal audit coordinates all reported matters. Tip-offs are also sent to the CEOs of the respective divisions and investigated accordingly. Detailed feedback is given at the respective financial and risk review committees and group audit committee.