Croda’s stance on countering bribery is set out in our Code of Ethics.  The Code of Ethics was communicated to all employees throughout 2011 and 2012 via the Company’s website, intranet and through internal email distribution.

Croda regularly carries out a global key compliance audit of corporate governance which includes the Code of Ethics and Whistleblowing Policy and the results are reported to the Audit Committee.

Following the coming into force of the Bribery Act 2010 in the UK, Croda instituted wide ranging anti-bribery and anti-corruption training.  Senior management received training in all aspects of the Bribery Act 2010 together with the Company’s policies and procedures to enforce compliance.  All employees deemed likely to be at risk of bribery related issues (in excess of 50% of the entire global workforce) have completed training on-line in respect of bribery related issues.  This training involves passing a test.  All employees have read and acknowledged that they understand the Company’s policies and procedures in respect of bribery related issues.

The steps detailed above show that Croda has taken steps to ensure all employees are aware of the standards expected of them and individual managers have taken action as a result to communicate these expectations to their staff.  As a result of this action, Croda is ensuring that:

(a) the Code of Ethics is communicated to all current and new employees and training is taking place in respect of the policy;
(b) our Whistleblowing Policy is communicated to all current and new employees and training has taken place in respect of this policy;
(c) Our Supplier Code of Conduct is communicated to all our suppliers; and
(d) the ILO Declaration on Fundamental Principles and Rights at Work Acts are communicated and practised throughout the organisation.

Our management and training programmes implicitly cover our company approach and Code of Ethics.  This means we see the value of using an indirect approach in addition to the focussed training to embed standards by placing ethical practice and integrity into a day to day setting.  Through this, we achieve a targeted approach to ensuring that employees who have external interface are made aware of our counter-bribery standards.

Our induction programme guides new employees to understand the company policies and both the Code of Ethics and other compliance policies are expressly listed in the induction programme.   Further, those employees deemed likely to have external interface are also required to undertake specific online anti-bribery training.

Our internal audit specifically deals with anti-bribery and corruption issues which means, every Croda office and site is required to detail its anti-corruption stance on an annual basis and this is audited to ensure appropriate levels of compliance.