Ethics and compliance
The Group is committed to conducting its business with integrity. High standards of professional and ethical conduct are expected throughout its operations acting in compliance with the laws and regulations in jurisdictions in which the Group operates.
Employees and persons acting on behalf of the Group are expected to implement the Group’s policies and procedures such that the legitimate interests of the Group are advanced, having regard to the Group’s values and standards. All employees are expected to engage in ethical conduct.
As part of the work of the Risk Management Committee, Group policies are regularly reviewed to ensure these remain appropriate and effective. These policies include anti-bribery, supplier code of conduct and the prevention of the facilitation of tax evasion.
These policies are clearly communicated to all staff and training programmes in these areas, in some cases provided by external providers, continued during the year with key members of staff from each division completing relevant modules.
Internal review of systems and internal audits provide assurance there is no significant risk in these areas. The Risk Management Committee manages the programme of work which supports the implementation and compliance with these policies, reporting regularly to the Audit Committee on these issues.
The Group seeks to be honest and fair in its relationships with customers and suppliers and to source and supply goods and services in an efficient manner, in accordance with specifications, without compromising quality and performance. Each division is responsible for negotiating the terms and conditions of trade with suppliers. In doing so each division is expected to maintain high standards of integrity in all business dealings with suppliers and is encouraged to use the services of those suppliers whose values and standards are equivalent to Tyman’s quality management standards. Operating units are encouraged to gain and maintain accreditation to specific standards required by the markets they serve, with quality and production accreditations gained throughout the operations.
The Group is committed to respecting human rights across all of its operations and aims to work at the highest international standards as well as complying with local legislation. The Group fully supports the Modern Slavery Act 2015 and seeks to ensure that the Group's activities and activities within its supply chain do not infringe or encourage abuses of any human rights.
The Group manufactures product primarily in North America and Western Europe, distributing and selling products to markets globally. A proportion of the Group's products are sourced from third party suppliers, primarily China. The acquisition of Zoo has also brought suppliers from India and Taiwan into the Group’s supplier base. A formal audit programme of the Zoo supplier base will be completed in 2019, in conjunction with the ongoing ERA supplier improvement programme.
During the year each of the Divisions has carried out training for all relevant staff, and a programme of supplier audits, including site visits, has been completed.
Each Division is responsible for the ethical sourcing of all products used in the production of finished goods. As part of the work of the sourcing teams, there is a strong emphasis on ensuring the integrity of the supply chain, including verification of their suppliers. Supply chain teams seek to re-engineer products, reworking them to reduce the materials used, or to take advantage of improved production methods, using more environmentally sound materials.
The Group operates a confidential whistleblowing telephone helpline, which is available for all employees and any external person associated with providing goods or services to any of the divisions. Calls are received by the Group Company Secretary and each call is fully investigated, by an appropriate person, independent of the claim being made. These claims are reported to the Board, who are kept apprised of all actions being taken and the final outcomes. Management is always grateful to receive these reports, which provide an additional insight into the operations at these locations and investigates them fully. Each claim is fully resolved, with the necessary actions taken.
Engagement with all stakeholders is important and ensures there is a sound basis upon which the business is conducted. Each division has a relationship management programme with its customers and suppliers which provides the appropriate forum for open and transparent discussions.