An introduction to GoodCorporation

A short history The measure of a good company

GoodCorporation’s Business at a Glance o Founded in the UK in 2000, GoodCorporation is recognised worldwide as one of the leading organisations working in the field of corporate responsibility and business ethics o We conduct independent and confidential assessments of ethical management practices and have completed over 400 assessments in more than 60 countries o We also support our clients through training, consultancy and further compliance services and resourcing o We have over 100 clients ranging from 17 FTSE 100 and 6 CAC 40 clients to smaller, private businesses o We have worked in 60 countries globally 1

Examples of our Clients 2

Assessments around the world

Algeria Angola Argentina Belgium Bolivia Brazil Brunei Bulgaria Burma Cambodia Cameroon Canada Central African Rep.

China Congo Czech Republic Egypt France Gabon Germany Gibraltar India Indonesia Ireland Israel Italy Japan Kazakhstan Kenya Libya Malaysia Mexico Morocco Myanmar Netherlands New Zealand Nigeria Norway Poland Portugal Qatar Romania Russia Saudi Arabia Senegal Singapore South Africa South Korea Spain Sweden Switzerland Syria Tanzania Thailand Trinidad and Tobago Tunisia Turkey UAE Uganda UK USA Venezuela Yemen

The GoodCorporation assessments are applied intelligently in each cultural context, using expert assessors working with locally trained counterparts 3

GoodCorporation’s Business Checking

Assessment Consultancy, training and resourcing

Preparation for checking

Certification GoodCorporation support

Embedding practice and culture Identifying the gaps Filling the gaps 4

GoodCorporation’s Product Portfolio

Consultancy

o o o o o o o o o o o o Benchmarking Code of Conduct review Code of Conduct development Policy review and development Process and systems design Training design Training and embedding Setting up, managing/supporting compliance functions Due diligence Mystery customer reviews Bespoke ethics consultancy Development of industry-wide business integrity initiatives

Assessments

o o o o o o o o o o o o Anti-bribery and corruption high level review Anti-bribery and corruption site level review Bespoke assessment Community Programme Evaluation Ethics assessment Evaluations against established standards e.g. ISO26000, BS10500 GoodCorporation Standard certification Project Assessment Small Organisation Assessment Treating Customers Fairly BnEI founding partner and assessor IiI founding partner and assessor 5

The GoodCorporation Standard

The measure of a good company

The GoodCorporation Standard o The GoodCorporation Standard is a standard of responsible business practice, developed in conjunction with the UK Institute of Business Ethics o It covers an organisation’s management of its employees, customers, suppliers, shareholders, its environmental impacts and relationship with the communities in which it operates o GoodCorporation gives an independent assessment and accreditation of an organisation against the Standard o Company or sector-specific management practices can be added to the GoodCorporation Standard for inclusion in the assessment process o All GoodCorporation reports are reviewed and approved by its independent Accreditation Council, chaired by Simon Webley, Research Director at the Institute of Business Ethics 7

How does GoodCorporation Assess?

o Set-up o an assessment framework and the scope of work are agreed o a timetable is developed with the client project manager o samples of employees, customers, etc. are selected for the interview programme o Assessment o the assessor interviews key functional managers from HR, HSE, sales etc. to understand how practices are supposed to work, o o the assessor reviews records, documents and system outputs as necessary the samples of stakeholders are interviewed: face-to-face, by phone or by e-poll o Analysis and reporting o o the assessor uses all the evidence gathered to evaluate how effectively the practices are working in reality, grading each practice a presentation is given to management to explain the findings and grades o metrics are developed o report drafted, reviewed and finalised o Accreditation o For organisations seeking accreditation the report is sent to the Accreditation Council for approval 8

Assessment Metrics: Overall Results versus Benchmark

Top Quartile

8% 1% 8%

GoodCorporation Standard Benchmark

2% 3% 10% 20%

Bottom Quartile

5% 1% 42% 22% 83%

Your company

2% 14% 64% 32% 14% 68% 9

Assessment Metrics: Stakeholder Group versus Benchmark 1 2 Employees 0 Customers Suppliers and contractors Community Environment Shareholders or equivalent Management commitment 3 GC Benchmark Your company 4 5 10

The Use of GoodCorporation’s Assessment for Non Financial Reporting The company can report: o That it has a process in place to systematically assess its relationships with it key stakeholders: “We have a process to systematically and independently assess our stakeholder views about our business. We do this using the GoodCorporation assessment process.” o If required, it can use the assessment grades to show its performance for a particular stakeholder group or show results of an e-poll o An overall percentage can be given for each stakeholder group, based on a score of 1 for a fail grade and 5 for a commendation grade o Where applicable, the company can report that it has achieved GoodCorporation Membership (no fail grade in the assessment)

The assessor awards grades: commendation

the policy and system are examples of best practice

merit

the policy and system work well

observation

there is a policy and system that works but potential improvements have been identified

minor non-compliance

there is a policy and system that work but it is not always working

fail

there is no policy or system, or it has largely broken down 11

Accreditation o A grade is awarded for each of the business practices assessed o Accreditation is achieved by obtaining no ‘fail’ grade anywhere in the assessment o The ‘accredited’ logo for the year in question (e.g. ‘accredited 2013’) may be used indefinitely o Re-accreditation can be achieved in subsequent years as required o Good performance allows the organisation to be re-accredited in subsequent years, subject to a successful ‘surveillance’ visit (short audit of management processes only) 12

3. The GoodCorporation Framework on Bribery and Corruption

The measure of a good company

The GoodCorporation Framework on Bribery and Corruption o o o o o o o The Anti-Bribery and Corruption (ABC) Framework is based on emerging international best practice It includes input from the OECD, Transparency International’s checklist, Ministry of Justice Guidance on the UK Bribery Act and the Basel Institute on Governance It covers an organisation’s policies and systems to reduce the risk of the company or its employees being involved in corrupt practices It can be used both at headquarters and at site level It addresses corruption risks broadly, covering not just bribes but: conflicts of interest, transparent purchasing, ethical risks in sales and marketing, relationships with the public sector, as well as management structure and processes The Framework is very adaptable: company, sector-specific or individual scheme requirements can be added to the GoodCorporation ABC Framework for inclusion in the programme and/or assessment process It aligns with BS10500 14

The GoodCorporation Framework on Bribery and Corruption o The Framework aims to ensure adequate procedures, in the sense of the UK Bribery Act, are followed, and principles are grouped under the six Ministry of Justice Guidance headings: o o o o o o Top-level commitment Communication and training Risk assessment Due diligence Key business functions Compliance and monitoring o GoodCorporation has been conducting anti-bribery and corruption work across a variety of industries including: telecommunications, oil and gas, defence, logistics and extractives o This information is used to benchmark organisations within and/or across sectors 15

4. Industry Initiatives

The measure of a good company

5. The Banknote Ethics Initiative (BnEI) o o o o o o o Banknote industry initiative (BnEI) Launched May 2013 Initiative to promote ethical business practice within the banknote industry Focus on the prevention of corruption and on compliance with anti-trust law Members sign up to a Code of Ethical Business Practice (developed with the IBE) They are audited against the BnEI Audit Framework (based on The GoodCorporation Framework on Bribery and Corruption) A robust test that is practical and realistic for companies in the industry 17

5. GoodCorporation’s Support Services

The measure of a good company

GoodCorporation’s Due Diligence Services GoodCorporation supports organisations to design a process adapted to their needs/risks to ensure adequate ethics safeguards in their supply chain We can also help implement due diligence processes by facilitating three levels of screening using the GoodCorporation Due Diligence Questionnaire as a base o Initial screening o Preliminary risk assessment to screen for: low, medium, high risk o Risk-based due diligence based on:    Identifying red flags from questionnaire Independent background checks On-site interviews 19

3 stages: Initial Screening, Preliminary Risk Assessment, Risk-based Due Diligence 20

GoodCorporation’s Due Diligence Services GoodCorporation’s due diligence screening service is based on direct interaction with the proposed supplier, with three levels of check available: o One hour check – we ask the supplier to complete the GoodCorporation Due Diligence Questionnaire and check responses o One day check – we phone and speak to the supplier and complete the missing details from the questionnaire o One week check – we visit the proposed supplier and interview the directors/senior managers 21

GoodCorporation Compliance Support Beyond high level and site level reviews, GoodCorporation offers a range of support services to help businesses manage compliance effectively: o Reviewing and developing policies o Reviewing and developing systems o Training: including tailored and highly interactive face-to-face training of individuals or teams based on relevant and current case studies o Interim compliance support: fulfilling the ABC compliance function on a short-term basis as a fast way of setting up a reliable compliance function e.g.

o o moving into new international markets working on a short-term project o engaging in a joint venture partnership This type of support can be used to: o Write local policies and procedures o Conduct due diligence on local entities o Conduct and document a local risk assessment o Review local books and records to ensure a local entity is operating in line with the company’s policies and procedures.

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6. Background Information

The measure of a good company

GoodCorporation Debates Since 2002, GoodCorporation has held a series of high-profile debates on corporate responsibility… 24

Founding Advisory Panel Panel members provided general guidance to GoodCorporation at its launch: o Lord Sharman, former Chairman of Aviva Group plc and former global head of KPMG chaired GoodCorporation’s Founding Advisory Panel o The panel contained representatives from business, NGOs and trade unions who supported GoodCorporation’s aims o Founding members of the panel included Sir Alan Budd, Sir Anthony Cleaver, Julia Cleverdon OBE, Baroness Greengross, Will Hutton, Baroness Pauline Neville-Jones, Sir Peter Walters, Mike Leahy and Rory Murphy.

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Contact For more information, please contact: Leo Martin, Director Debbie Ramsay, Director Business Development GoodCorporation Limited Blades Court 121 Deodar Road, London, SW15 2NU United Kingdom Tel: E-mail: +44 (0)20 8877 5300 [email protected]

[email protected]

www.goodcorporation.com

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