Governance for ethical business
Our focus areas
We adopt a zero-tolerance approach to unethical behaviour and bribery and corruption, and have the processes in place to discourage, identify and prosecute wrongdoing. Our approach to ethics also covers our board of directors and third parties who act on our behalf. Our people are encouraged to express their concerns in an open and direct manner, and are required to report any circumstances that may indicate an infringement of laws and internal directives, including allegations of harassment and discrimination.
Respect for human rights is included in our code of conduct, our code of conduct – corporate and social responsibility procurement guidelines, various people and culture policies (for example those dealing with disciplinary action, grievances, and right to associate) and the climate change and environmental sustainability framework and strategy.
Responsibility for overseeing human rights implementation is shared widely, from our people and culture function (for example, freedom of association, diversity and inclusion, and employment conditions) and the procurement function (including supply chain practices and standards) to corporate affairs (stakeholder engagement and CSI).
Integrate ESG into governance and risk management processes
Management's assessment of our ESG maturity rated Imperial overall in the 'compliant' category. We aspire to improve this rating to the 'proactive' category by 2025, building on our strong compliance foundation. This means improving our governance systems, risk management and controls to ensure that effective, risk-based practices deliver sustainable results that, in turn, deliver long-term value for our stakeholders.
Embed information security and data privacy
We adhere to regulation that applies to the use of information and communication technology, as well as the collection, processing, sharing, retention and destruction of information in all forms. As new policies are published, they are supported by employee awareness campaigns, and training if required. Regular cybersecurity assessments and external audits ensure continual improvement in our information security controls.
Ensure high supply chain standards are upheld
Safety and quality control are standard requirements in our client and principal contracts. Our businesses are certified to various standards depending on the industry they are operating in and client requirements. To maintain these certifications our policies, standards and procedures are regularly updated and audited.
Our suppliers and subcontractors
Ethical behaviour and full compliance with all laws, including anti-bribery and corruption, health and safety, labour and environmental laws, and Imperial minimum standards, are requirements that all our suppliers and subcontractors are expected to meet. Our subcontractors are held to the same road safety standards as our businesses.
- 2 680 employees across Africa successfully completed anti-bribery and corruption training (F2020: 1 359), equating to 24% of this workforce to date.
- In Logistics International, 1 208 employees successfully completed code of conduct training, 1 214 completed corruption prevention training and 941 completed training on antitrust law.
- Included ESG as part of the formal due diligence process for mergers and acquisitions.
- Established a working group to review the ESG policy framework.
- Established the group privacy office and a data protection governance structure for Market Access and Logistics Africa. Appointed a data privacy officer, information officers and deputy information officers for the group and all businesses, as well as privacy custodians.
- Formulated data protection standards, and internal (between group entities) and external data transfer agreements to ensure we comply with the POPIA and all related legislation in Africa and Europe.
- There were no substantiated complaints or loss of client data, and one material successful cybersecurity breach occurred but did not lead to material data or financial loss.
- We conducted a supply chain study for the South African National Office of the World Wide Fund for Nature (WWF-SA) on the potential to produce sustainable aviation fuel in South Africa. The study aimed to identify the ideal supply routes for a number of alternative candidate feedstocks, considering eight different SAF-production pathways, in terms of cost, reliability of supply and GHG emissions.
- Group: continue to roll out the anti-bribery and corruption training programme to employees, and find ways to deliver training to those who do not have email addresses.
- Group: enhance our ability to identify and evaluate risks related to our ESG targets and objectives, and to respond and escalate these risks timeously.
- Group: mature our TCFD alignment, particularly around climate change scenarios and risk.
- Group: implement a group-wide information security strategy.
- Logistics Africa: develop the centre-led procurement approach that considers ESG in our procurement processes.