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The GKN Code and Policies
GKN’s Vision and Values guide our day to day activities and in doing so sustain the long-term development of the GKN Group. They also guide our relationships with all stakeholders, whether they be our shareholders, our customers, our suppliers, our employees or the communities in which we operate. All employees are expected to respect and uphold the Values in all activities undertaken for GKN.
In pursuit of the Values this Code provides a framework for the behaviour of GKN employees in the conduct of our business. By following the Code, GKN will be a company with which our customers and suppliers want to do business, it will be a company for which we all want to work and one in which the financial community will want to invest. It will also be a company which people will be proud to have within their communities. It will be a company which achieves its Vision.
The Code applies to all employees of the GKN Group, whatever their job, wherever they are located. It is the responsibility of all companies in the Group and all employees to ensure that it is followed and that we comply with the Policies which underly it.
The Main Principles of the Code
The Code is designed to ensure that our business in all its aspects continues to be run in an ethical, socially responsible and sustainable manner by:
- complying with all relevant laws and regulations wherever we operate and conducting our business with integrity and in such a manner as to reinforce its reputation;
- maximising shareholder value whilst safeguarding shareholders’ investment by combining high standards of business performance with high standards of corporate governance and risk management;
- providing excellent products and services to our customers and seeking to win new business through fair competition;
- dealing honestly and fairly with our suppliers and sub-contractors;
- treating our employees justly and with respect, recognising their abilities and differences, rewarding them for their achievements and providing them with a healthy and safe working environment;
- playing our part in the protection of the environment both in the operation of our facilities and the design of our products; and
- contributing positively to the communities in which we operate.
To ensure that we abide by the main principles of the Code it is the responsibility of all employees to uphold the following standards of conduct:
Our Ethical Standards
- All business will be conducted with respect for human dignity and rights and in accordance with the laws and regulations of the countries in which we are located and in which we do business.
- We support the Universal Declaration of Human Rights and we will not tolerate the use of child labour or forced labour in our own operations or those of our suppliers and sub-contractors.
- Corrupt practices of any kind will not be tolerated including the giving or taking of bribes or similar payments to or from any party.
- Company assets and confidential information will be fully protected and used only for the purpose for which they were intended.
- All employees must ensure that they are aware of and must avoid conflicts of interest or matters capable of being seen as conflicts of interest in their business relationships and personal activities.
- All companies and employees within GKN will act in compliance with GKN’s Ethical Standards Policy and Agents and Consultants Policy.
Our Reporting and Control Procedures
- All commercial transactions will be properly and accurately recorded.
- We will seek to achieve “best practice” standards of accuracy and clarity in our reporting, both externally and internally.
- We will operate strong financial controls and procedures to ensure both the accuracy of reported figures and careful stewardship of all of GKN’s assets. It is the responsibility of all employees to comply with our control procedures and reporting standards at all levels.
- We will deal openly and truthfully with our internal and external auditors.
Our Employees
- All of our companies must operate employment procedures which ensure that all the principles set out in this Code and in GKN’s Employment Policy and all applicable laws and regulations are complied with and are appropriate for local circumstances and conditions.
- All employment procedures must be fully communicated to and understood and upheld by all employees.
- We will treat all of our employees fairly and all of our companies and employees will ensure that there is no discrimination against any employee or prospective employee on the grounds of gender, sexual orientation, disability, religion, colour, race or national or ethnic origin.
- All of our companies will ensure that there is no discrimination against any employee or prospective employee on the grounds of age other than where, in accordance with applicable law, contractual retirement dates are agreed.
- All decisions relating to selection for employment and promotion will be based on ability and merit.
- All of our employees are entitled to work in an environment which respects their human dignity and rights and which is free from all forms of harassment.
- All of our employees are entitled to clear terms and conditions of employment, disciplinary procedures, and an effective complaints and consultation process.
- We will respect our employees’ right to freedom of association in accordance with applicable law.
- All of our employees will be given appropriate training for their work, and their individual development needs and career prospects will be reviewed regularly.
Our Workplace
- All working conditions in GKN must be safe, support accident prevention, minimise exposure to health risks and be in compliance with applicable occupational health and safety standards, laws and regulations.
- All employees individually have a responsibility for their own and their colleagues’ health and safety and must comply with all applicable occupational health and safety standards, laws and regulations.
- All of our employees will receive appropriate occupational health and safety training.
- All of our companies and employees must comply with GKN’s Health & Safety Policy.
- All of our companies must have a Business Continuity Plan in compliance with GKN’s Business Continuity Policy.
Our Customers
- We will strive to be best in class and to develop and deliver continuously improving products and services to our customers.
- We will compete fairly in all of the markets in which we operate and in accordance with all applicable competition laws and regulations.
- All of our companies must comply with GKN’s Competition Law Policy.
- Our customers’ intellectual property, such as copyrights, trademarks, patents or design rights will only be used in an authorised manner and with their express permission.
- Accurate and clear information about our products and services must be provided as necessary and in accordance with applicable legal requirements whether in relation to content, use, maintenance or disposal.
- All of our companies must have defined processes in place to review customer satisfaction and to respond to any issues which arise.
Our Suppliers and Sub-Contractors
- All terms of business agreed in relation to supply or sub-contracting will be respected and we will act fairly and honestly in respect of all dealings with our suppliers and sub-contractors.
- Our suppliers’ and sub-contractors’ intellectual property, such as copyrights, trademarks, patents or design rights will only be used in an authorised manner and with their express permission.
- Our suppliers and sub-contractors will be encouraged to comply with the same occupational health and safety, environmental and ethical standards as are applicable in our own operations.
- The use of child labour or forced labour by our suppliers and sub-contractors will not be tolerated.
- Defined processes will be in place in all of our operations to respond to supplier and sub-contractor comments and complaints.
- All of our companies must comply with GKN’s Supplier Management Policy.
Our Impact on the Environment
- We will comply with all applicable environmental laws and regulations wherever we operate and with the requirements of GKN’s Environmental Policy irrespective of whether or not those requirements are in excess of local requirements.
- We will assess the environmental impact of our operations, the use of resources and the production of waste and pollution and set priorities for their reduction.
- We will strive to understand the environmental impact of our products and will seek with our customers, suppliers and sub-contractors ways of reducing such impacts and ensuring sustainability.
Our Community Involvement
- We will support projects and activities in our local communities and will encourage our employees to do the same.
- We will seek to minimise negative impacts on the communities in which we operate.
- Our businesses will have processes in place to deal with any comments or complaints from local communities and to enter into dialogue with them as appropriate.
- All of our companies must comply with GKN’s Community Policy.
Our Shareholders and Providers of Finance
- Our shareholders are the owners of our business and for the purposes of protecting their interests we will have in place processes which assess and manage risk and, to the degree practicable, safeguard our assets against loss or fraudulent use.
- We will ensure that our risk financing strategy is commensurate with our risk profile, that all risks are recognised and understood and that, where appropriate, they are properly insured.
- We will communicate to all shareholders and providers of finance all matters that are material to an understanding of our business.
- We will comply with all applicable laws and regulations with regard to corporate governance and compliance and make available to shareholders all relevant information concerning our governance.
- We will ensure that we have in place procedures to protect against insider trading.
- We will ensure that we have procedures to deal with queries and complaints from shareholders in relation to all matters of governance.
Our Data Protection and Document Management
- Employees must keep confidential all data obtained during the course of their employment.
- All of our companies and employees must comply with applicable laws relating to data protection and with the requirements of GKN’s Data Protection Policy.
- All of our companies and employees must comply with all document retention requirements under applicable laws and regulations and have in place suitable document management procedures.
Employee Disclosures
- Employees must be able to disclose in good faith instances of wrongdoing by other employees at any level, including acts, failure to act or intention which may lead to:
- a criminal offence
- a failure to comply with legal obligations
- a miscarriage of justice
- danger to the health and safety of any individual
- damage to the environment
- inaccurate reporting or breach of the Group’s internal financial control procedures
- any other substantial breach of Group Policies referred to in this Code
- deliberate concealment of matters relating to the above.
- Disclosure procedures must be in place and communicated to all employees in accordance with GKN’s Employee Disclosure Procedures Policy which allows any employee to make a relevant disclosure in the knowledge that their concerns will be investigated and dealt with properly and sensitively and without fear of reprisal or disciplinary action.
The Code must be read in conjunction with the following GKN Policies and the requirements regarding their implementation.
Policy Schedules:
- Ethical Standards Policy and Agents and Consultants Policy
- Employment Policy
- Health & Safety Policy
- Business Continuity Policy
- Competition Law Policy
- Supplier Management Policy
- Environmental Policy and Energy Policy
- Community Policy
- Data Protection Policy
- Employee Disclosure Procedures Policy.
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