In 2014, we continued with our 'Code Companions' campaign which raises awareness of a specific compliance area in our Code of Business Conduct. We have ten Code Companions in total and each of them is promoted periodically across the group. In 2014, we ran three Code Companions campaigns on: 'seek permission before dealing' (related to dealing in shares); ‘appropriate due diligence’; and ‘record all gifts and hospitality'.
As part of the campaign, we:
- Display a poster or banner in all offices;
- Communicate messages about the campaign theme on the company intranet;
- Prepare a presentation pack for all managers to disseminate to staff; and
- Work with Compliance Champions to deliver lunch and learn sessions.
We find that the Code Companions provide a well-received visual reminder to colleagues about the appropriate compliance behaviour that is required. We have also found that the promotion of the Code Companions directly by managers to their respective teams helps to demonstrate good examples of ethical leadership. In Ghana, for example, the Business Unit Manager communicated the need to record all gifts and hospitality ahead of the festive season and staff reacted positively to this message.