Policies and procedures

Croda International plc has a zero tolerance policy towards corruption in all its forms.  As set out our Code of Conduct, we are committed to upholding the highest standards of integrity in our business, ensuring that we operate in a responsible manner and that we communicate our ethics and anti-corruption programme to our employees. As part of our commitment to responsible and ethical business conduct, Croda signed up to the UN Global Compact in June 2021.

Our ethics and anti-corruption programme guides and supports our employees in living to our shared values and making responsible decisions.  It also helps our employees understand what is expected of them and creates an environment in which employees feel they can ask questions and raise issues and concerns.

Our programme is embedded through our key group policies and processes, including through our third party due diligence procedures. The programme receives both internal and external oversight and assurance. We have in place a monitoring and review cycle that drives improvements in the programme on an ongoing basis to respond to and mitigate new and emerging risks. We also use key performance indicators (KPIs) to monitor ethics and anti-corruption risks and activities on an ongoing basis.

Our Code of Conduct sits at the heart of ethics and compliance at Croda. Our Code of Conduct and our ethics and anti-corruption policies and procedures are communicated to staff through group-wide communications, our training programme, and related guidance.

Croda embarked on a refreshment of its ethics and anti-corruption programme in 2016, which included the engagement of external advisors on a review of the programme. Subsequently, we have adopted consecutive two-year action plans to further enhance our programme on an ongoing basis.
The Board of Directors is ultimately responsible for our ethics and anti-corruption programme.

At Croda, we are committed to conducting our business throughout the world with honesty and integrity.  We will behave ethically in all business transactions.  We will comply with the law in each country in which we do business.  These are the standards we expect from all of our employees, agents, distributors and any other third-parties we engage to act on our behalf. 

All organisations face the risk of things going wrong from time-to-time.  By adopting a culture of openness and accountability, we can prevent breaches of those standards and remedy failings when they do occur.   We encourage anyone to report any information relating to any suspected wrongdoing connected to Croda.  This may include: 

• criminal activity
• failure to comply with any legal or professional obligation
• miscarriages of justice
• danger to health and safety
• damage to the environment
• bribery
• financial fraud or mismanagement
• breach of our internal policies and procedures
• conduct likely to damage our reputation or financial wellbeing
• unauthorised disclosure of confidential information
• the deliberate concealment of any of the above matters.

How to report any concerns

For employees

For employees, we hope that concerns can be raised with line managers.  If that is not possible or the matter is more serious, employees should refer to the Whistleblowing Policy on the company’s intranet and consider contacting one of the following to raise their concerns:

• Group General Counsel and Company Secretary or any other member of the Executive Committee
• the Chief Executive Officer
• the Group Finance Director
• the Group HR Director
• the Croda SpeakUp reporting line/portal. 

For those outside Croda

We also welcome reports of wrongdoing from those outside our company.  We have created a web-portal to provide a safe place for any individual to share information in strict confidence, within the realms of local law.  This offers anonymous, web-based access for the reporting of ‘tip-offs’ to us. It is available in many languages and can be accessed via the following link: http://croda.ethicspoint.com or you can use the QR code found here.

How we deal with reported concerns

All reports from employees and third-parties will be handled by independent dedicated experts.  If concerns are raised in good faith, there will be no risk of suffering any form of detriment or retribution as a result. However, the portal must not be used to knowingly submit false or slanderous statements or information. Improper submissions of this nature can give rise to serious consequences under company policy, or under civil or criminal law.