Implementation

How are the policies cascaded?

The Group intranet, MorgaNet, is the primary means of making each of the policies, manuals and guidelines available to employees. It is acknowledged that not all employees can access MorgaNet, so hard copies are also made available locally. 

Education on the RBP policies is also built into each of the RBP eLearning modules and all face-to-face materials.

How is the training given?

The training is implemented every two years via ‘train the facilitator’ sessions for general managers, site level compliance officers and other key staff worldwide, with these general managers then delivering training on a site by site basis to over 2,000 relevant employees. The site level face-to-face training includes dilemma and scenario based discussions.

In the alternate years training is given by webinar to the general managers, site level compliance officers and other key staff worldwide, the materials then made available for local cascade. 

eLearning modules on human rights, anti-bribery and ethics, anti-trust and contract risk management supplement this face to face training with this eLearning suite being refreshed and updated in 2016.

The training materials and eLearning modules are available in 13 languages. 

What have the risk assessments shown?

The Group-wide bribery risk assessments, run since 2013, take into account a number of factors including: location of business, location of customers, the market sector and whether third-party agents were used. The results of these assessments at the end of 2014 created internal bribery risk rankings that were used to focus additional support, monitoring and training delivered in 2015 to a number of the Group’s businesses including those in China and South America. A similar assessment informs the programme going into 2016.