Communication on Progress Our Sustainable Business Dec 15 - Dece 16

Participant
Published
  • 2016/12/15
Time period
  • December 2015  –  December 2016
Format
  • Stand alone document – Basic COP Template
Differentiation Level
  • This COP qualifies for the Global Compact Active level
Self-assessment
  • Includes a CEO statement of continued support for the UN Global Compact and its ten principles
  • Description of actions or relevant policies related to Human Rights
  • Description of actions or relevant policies related to Labour
  • Description of actions or relevant policies related to Environment
  • Description of actions or relevant policies related to Anti-Corruption
  • Includes a measurement of outcomes
 
  • Statement of continued support by the Chief Executive Officer
  • Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.

  • To our stakeholders:
    I am pleased to confirm that BaxterStorey reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption. In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.
    Sincerely yours,
    John Bennett
    Co-CEO, BaxterStorey

Human Rights
  • Assessment, policy and goals
  • Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.

  • BaxterStorey fully supports the Universal Declaration of Human Rights and is a proud supporter of the UN Global Compact.

    BaxterStorey is supported through robust board approved policy’s including Harassment Policy, Equality & Dignity Policy and an overarching HR policy.
    BaxterStorey’s Supply Chain policy states the company’s commitment to human rights in the supply chain specifically the Ethical Trading Initiative Base Code. This Code contains nine clauses that reflect the most relevant international standards with respect to labour practices (ILO Conventions):
    - Employment is freely chosen
    - Freedom of association and the right to collective bargaining are respected
    - Working conditions are safe and hygienic
    - Child labour shall not be used
    - Living wages are paid
    - Working hours are not excessive
    - No discrimination is practiced
    - Regular employment is provided
    - No harsh or inhumane treatment is allowed

    BaxterStorey has a large and diverse supply chain, sourcing primarily UK produce. It is BaxterStorey’s intention to develop reporting strategies to review risk associated with human rights to at least tier two supplier level during 2017.

    As part of the wider WSH family BaxterStorey is a key part of the ethics and integrity committee developing our strategy towards the requirements of the Modern Slavery Act and ongoing work on bribery and corruption. A position is to go beyond compliance.

  • Implementation
  • Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.

  • All BaxterStorey staff in client locations, mobile workers or at the support offices are afforded safe and sanitary work place facilities. Support office facilities are provided by BaxterStorey and location facilities are client owned.
    All BaxterStorey staff are protected from workplace harassment, including physical, verbal, sexual or psychological harassment abuse or threats via robust and enforced policy.
    Within BaxterStorey policy there is allowance for ‘whistle blowing’ and is explicit in that there will be no recriminations following such reports as long as they are justified and accurate.
    BaxterStorey take all expected measures to prevent injury or harm coming to any of their employees or stakeholders resulting from any business activities or associated operations
    BaxterStorey is fully accepting of the Modern Slavery act and is currently ensuring full compliance throughout the supply chain

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • If the company was made aware or became aware of any human rights abuses whether employee, stakeholder or supplier the appropriate director would be informed plus the CEO and chairman.
    All employees and suppliers are regularly reviewed which includes discussions on welfare, business activities and relationships within the organisation.
    These reviews are shared with and reported to senior management as required.

Labour
  • Assessment, policy and goals
  • Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.

  • BaxterStorey fully embraces the ILO conventions
    - Employment is freely chosen
    - Freedom of association and the right to collective bargaining are respected
    - Working conditions are safe and hygienic
    - Child labour shall not be used
    - Living wages are paid
    - Working hours are not excessive
    - No discrimination is practiced
    - Regular employment is provided
    - No harsh or inhumane treatment is allowed
    BaxterStorey operates under the remit of robust labour related policy including: harassment policy, equality & dignity policy, maternity, paternity, flexible working opportunity etc.
    All written policies state employee rights and responsibilities and their compensation and benefits.
    BaxterStorey’s supply chain policy required all suppliers to accept and adhere to ILO conventions as above
    All employees and suppliers are regularly reviewed which includes discussions on welfare, business activities and relationships within the organisation.
    These reviews are shared with and reported to senior management as required

  • Implementation
  • Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.

  • BaxterStorey operates under the remit of a robust HR and associated labour related policy structure.
    BaxterStorey trains all employees on HR related matter including but not limited to diversity and equality.
    All employees and suppliers are regularly reviewed through an appraisal system which includes discussions on welfare, business activities and relationships within the organisation.
    The health & safety of all employees is safeguarded through the companies H&S policies which include a certified occupational H&S management system to ISO 18001.
    Labour rights and policy are managed via the HR Director and then ultimately CEO and Chairman.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • BaxterStorey operates a robust employee engagement and review programme based on a formal annual appraisal system framework.
    BaxterStorey do not formally monitor ethnicity or diversity, there are however voluntary questions at engagement time however these are not collated currently
    BaxterStorey operates a rigorous grievance procedure as laid out in policy
    BaxterStorey holds the classification of ‘world class’ for Hospitality Assured from the Institute of Hospitality which includes employee engagement, HR issues and welfare

Environment
  • Assessment, policy and goals
  • Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.

  • Our Sustainable Business Strategy starts with a robust baseline assessment spanning all aspects of operational activity on your sites. The baseline assessment process follows the structure as determined by our ISO 14001 accredited EMS including a site specific review of aspects and impacts that are focussed within our proposed services on two key areas; resource efficiency and waste management programmes in these areas cover everything from basic good housekeeping, through to more technical and potential financial investment to allow greater efficiency and savings in the longer term assuming an acceptable ROI plan is in place.
    Once we fully understand the key aspects and impacts of our service provision we can set in place robust and challenging objectives and targets built up from the monitoring and measurement of each manageable facet of the operations. In some instances simple processes for the recording of data can be implemented such as weighing and costing both kitchen and plate food waste and reviewing against a functional unit such as production volume or turnover can effect a significant focus on waste minimisation – in our experience from simple segregation and weighing we have seen up to a 25% reduction in food waste and therefore environmental impact and cost.
    Our environmental policy forms the foundation of our EMS and it is from this we have established Environmental Best Practice documentation for food service operations, Energy efficiency House Rules and the first three of our Green Flash Training programme; MSC Sustainable Fish Chain of Custody, Energy & Water Efficiency in your Location and Food Waste Prevention.
    BaxterStorey has also recently achieved accreditation for its energy management system to ISO 50001 which is the business’ chosen route to compliance to ESOS and also provides a framework for energy efficiency across the business and adds value to the client proposition
    Key impacts associated with our kitchen operations:
    Activity: Receiving and making deliveries
    Aspects: Fuel usage, packaging waste, vehicle emissions, congestion, noise pollution
    Impacts: Pollution, air quality degradation, climate change, waste generation
    Controls: Where possible purchase items from the same supplier reducing the number of deliveries
    Where possible receive larger deliveries reducing the number of deliveries
    Place orders every other day where possible to reduce number of deliveries
    Require suppliers to use reusable outer packaging once the items are decanted the supplier can take away the outer packaging for re-use e.g. bread trays
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Waste should be re-used or recycled where possible
    Activity: Food production /cooking
    Aspects: Water consumption, energy consumption, chemical usage, effluent produced, solid waste produced, raw materials consumption, packaging consumption
    Impacts: Water resource reduced, increased CO2e emissions, chemical pollution, and air quality degradation, global warming, waste generation, reduced raw materials stock, potential pollution of ground water and increased loading on water treatment leading to increase energy use and increased CO2e emissions
    Controls: Do not defrost items under running cold tap
    Ensure taps/plumbing is well maintained to prevent drips and leaks
    Lighting fitted with PIRs and LED fittings
    Stoves MUST NOT be turned on before required for cooking
    Other equipment should be turned on at the last practical moment
    Steaming should replace boiling as it is quicker and uses less water (added benefit of greater nutritional value and better quality)
    Batch cooking should be in place to reduce wastage
    Production records and wastage sheets to monitor production and wastage trends to enable production planning of varying dishes
    Food waste to be monitored and reported as per BaxterStorey policy.
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Require suppliers to use reusable outer packaging once the items are decanted the supplier can take away the outer packaging for re-use e.g. bread trays
    Avoid cooking and reheating, cook fresh every time to reduce energy used and improve quality dish
    Fridges and freezers should be fitted with curtains to keep in the cold
    Endocubes to be fitted to freezers and fridges if they are switched on for 24 hours per day
    Waste should be re-used or recycled where possible
    Activity: Cleaning & Domestics
    Aspects: Water consumption, energy consumption, chemical usage, effluent produced, solid waste produced, raw materials consumption, packaging consumption
    Impacts: Water resource reduced, increased CO2e emissions, chemical pollution, and air quality degradation, global warming, waste generation, reduced raw materials stock, potential pollution of ground water and increased loading on water treatment leading to increase energy use and increased CO2e emissions
    Controls: Ensure taps/plumbing is well maintained to prevent drips and leaks
    LED Lighting and fitted with PIRs
    Chemical feeds must be calibrated correctly and well maintained to keep chemical use to a minimum and prevent pollution.
    Spill kits must be available in all areas where chemicals are stored and used
    Where possible biodegradable chemicals should be used e.g. BioSan
    Cleaning machines such as dishwashers should be well maintained and kept lime scale free to ensure maximum efficiency
    When replacing equipment energy and water efficient models should be sought.
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Waste should be re-used or recycled where possible
    Ensure certificate of compliance for release to control waters as required
    COSHH training to be completed with all data sheets up to date
    Activity: Pest control
    Aspects: Chemical usage, packaging, solid and animal waste
    Impacts: Chemical pollution, increased landfill, contaminated landfill, incineration of animal waste, air quality degradation increased CO2e emissions
    Controls: Pest control contractors must be licensed and have received environmental induction training
    ALL staff must be aware of pest control methods to prevent pollution and contaminated waste
    Dead insects and animals must be disposed by licensed operators not via general waste streams
    Waste should be re-used or recycled where possible
    Key impacts associated with our restaurant & café operations:
    Activity: Food & beverage service
    Aspects: Water consumption, energy consumption, chemical usage, waste water produced, solid waste produced, raw materials consumption, packaging consumption
    Impacts: Water resource reduced, increased CO2e emissions, chemical pollution, and air quality degradation, global warming, increases in landfill, recycling increased, reduced raw materials stock, pollution of ground water and increased loading on water treatment leading to increase energy use and increased CO2e emissions
    Controls: Equipment must be turned on at the last practical moment.
    Cold display units should have curtains or screens to keep in the cold outside of service times
    Cleaning machines such as dishwashers should be well maintained and kept lime scale free to ensure maximum efficiency
    When replacing equipment energy and water efficient models should be sought.
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Ensure taps/plumbing is well maintained to prevent drips and leaks
    LED Lighting and fitted with PIRs
    Ask suppliers to use reusable outer packaging once the items are decanted the supplier can take away the outer packaging for re-use e.g. bread trays
    Waste should be re-used or recycled where possible
    Activity: Cleaning & Domestics
    Aspects: Water consumption, energy consumption, chemical usage, effluent produced, solid waste produced, raw materials consumption, packaging consumption
    Impacts: Water resource reduced, increased CO2e emissions, chemical pollution, and air quality degradation, global warming, waste generation, reduced raw materials stock, potential pollution of ground water and increased loading on water treatment leading to increase energy use and increased CO2e emissions
    Controls: Ensure taps/plumbing is well maintained to prevent drips and leaks
    LED Lighting and fitted with PIRs
    Chemical feeds must be calibrated correctly and well maintained to keep chemical use to a minimum and prevent pollution.
    Spill kits must be available in all areas where chemicals are stored and used
    Where possible biodegradable chemicals should be used e.g. BioSan
    Cleaning machines such as dishwashers should be well maintained and kept lime scale free to ensure maximum efficiency
    When replacing equipment energy and water efficient models should be sought.
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Waste should be re-used or recycled where possible
    Ensure certificate of compliance for release to control waters as required
    COSHH training to be completed with all data sheets up to date

    Activity: Food and beverage production
    Aspects: Water consumption, energy consumption, chemical usage, effluent produced, solid waste produced, raw materials consumption, packaging consumption
    Impacts: Water resource reduced, increased CO2e emissions, chemical pollution, and air quality degradation, global warming, waste generation, reduced raw materials stock, potential pollution of ground water and increased loading on water treatment leading to increase energy use and increased CO2e emissions
    Controls: Do not defrost items under running cold tap
    Ensure taps/plumbing is well maintained to prevent drips and leaks
    Lighting fitted with PIRs and LED fittings
    Stoves MUST NOT be turned on before required for cooking
    Other equipment should be turned on at the last practical moment
    Steaming should replace boiling as it is quicker and uses less water (added benefit of greater nutritional value and better quality)
    Batch cooking should be in place to reduce wastage
    Production records and wastage sheets to monitor production and wastage trends to enable production planning of varying dishes
    Food waste to be monitored and reported as per BaxterStorey policy.
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Require suppliers to use reusable outer packaging once the items are decanted the supplier can take away the outer packaging for re-use e.g. bread trays
    Avoid cooking and reheating, cook fresh every time to reduce energy used and improve quality dish
    Fridges and freezers should be fitted with curtains to keep in the cold
    Endocubes to be fitted to freezers and fridges if they are switched on for 24 hours per day
    Waste should be re-used or recycled where possible
    Activity: Pest control
    Aspects: Chemical usage, packaging, solid and animal waste
    Impacts: Chemical pollution, increased landfill, contaminated landfill, incineration of animal waste, air quality degradation increased CO2e emissions
    Controls: Pest control contractors must be licensed and have received environmental induction training
    ALL staff must be aware of pest control methods to prevent pollution and contaminated waste
    Dead insects and animals must be disposed by licensed operators not via general waste streams
    Waste should be re-used or recycled where possible
    Key impacts associated with our office/reception environments
    Activity: Administration/ computers
    Aspects: Packaging, energy consumption, waste including hazardous or controlled waste produced, use of resources
    Impacts: Increased CO2e emissions, chemical pollution, air quality degradation, global warming, potential increases in landfill
    Controls: Computers, monitors and other electric equipment should be switched off at the end of each day
    Office lights should be LED and PIRs or timer switched
    Old monitors, pc and other equipment (WEEE) must be disposed of by a licensed operator
    Waste should be re-used or recycled where possible
    Ensure full compliance with WEEE directive and Battery and Accumulators regulations
    Key impacts associated with our housekeeping environments
    Activity: Cleaning, Domestics & Laundry
    Aspects: Water consumption, energy consumption, chemical usage, effluent produced, solid waste produced, raw materials consumption, packaging consumption
    Impacts: Water resource reduced, increased CO2e emissions, chemical pollution, and air quality degradation, global warming, waste generation, reduced raw materials stock, potential pollution of ground water and increased loading on water treatment leading to increase energy use and increased CO2e emissions
    Controls: Ensure taps/plumbing is well maintained to prevent drips and leaks
    LED Lighting and fitted with PIRs
    Chemical feeds must be calibrated correctly and well maintained to keep chemical use to a minimum and prevent pollution.
    Spill kits must be available in all areas where chemicals are stored and used
    Where possible biodegradable chemicals should be used e.g. BioSan
    Cleaning machines such as dishwashers should be well maintained and kept lime scale free to ensure maximum efficiency
    When replacing equipment energy and water efficient models should be sought.
    All staff to be trained in environmental awareness including energy efficiency, waste management and resource management using Green Flash modules.
    Waste should be re-used or recycled where possible
    Ensure certificate of compliance for release to control waters as required
    COSHH training to be completed with all data sheets up to date
    Activity: Driving/commuting, staff travel
    Aspects: Fuel consumption
    Impacts: Pollution, air quality degradation, global warming, congestion, noise pollution
    Controls: Journeys should be kept to a minimum and alternatives to car travel should be considered
    Speed limits should be observed to ensure maximum efficiency from the vehicle to reduce emissions.
    Vehicles must be well maintained
    Drive in the highest possible gear
    Avoid heavy acceleration and braking
    Unnecessary weight should be removed from the vehicles before driving to reduce fuel consumption
    Air conditioning should be used sparingly
    It is more efficient to have air con switched on in hot weather than windows open which causes drag and increases fuel consumption
    To cool a vehicle quickly in hot weather, switch to air recycling.
    Activity: Printing & copying
    Aspects: Paper usage, solid waste, copier toner residue, heat and potential polluting emissions
    Impacts: Increased landfill, recycling, chemical pollution, hazardous waste
    Controls: Printing and copying should be kept to a minimum, review documents on screen.
    Recycled paper should be used at all times
    If copying and printing must be done then duplex copying should be the default setting
    Toner cartridges must be recycled by sending back to the supplier
    Waste paper should be recycled
    Solid waste should be re-used or recycled where possible
    Key impacts associated with our waste and refuse areas
    Activity: General waste collection and storage
    Aspects: Solid waste produced
    Impacts: Increases to landfill, ground pollution, air emissions
    Controls: Solid waste should be re-used or recycled where possible
    Waste must be controlled and disposed of as required by duty of care regulations, hazardous waste and other controlled waste MUST be separated and disposed of by licensed carriers
    Activity: Recycling
    Aspects: Dry mixed recyclables produced
    Impacts: Reducing waste landfill
    Controls: Ensure all staff are trained in what can be recycled and the correct procedures for sorting and rinsing if appropriate in line with client and waste carrier requirements
    Ensure that staff are aware of the importance of keeping contamination with food waste to a minimum
    Activity: Waste cooking oil Storage
    Aspects: Used cooking oil stored prior to collection
    Impacts: Potential ground and controlled waters pollution
    Controls: Oil should only be stored in a designated area agreed by the client
    Where possible oil should be stored in a sealed container e.g. the original plastic drum
    Where possible oil storage areas should be bunded
    An inert absorbent spill kit must be readily available in kitchens and oil storage areas
    By breaking down each operation area into the key activities and their associated aspects and impacts we are able to work with our clients and propose SMART objectives and targets in order to continuously drive efficiency and effect improved performance and cost reductions. Two specific examples that have delivered financial savings for our clients include:

  • Implementation
  • Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.

  • Mike Hanson is BaxterStorey’s Head of Sustainable Business and is responsible for all aspects of environmental management as part of the wider sustainability remit.
    Mike has 8 years’ experience in the field and worked previously as a professional catering operator in roles from chef to area manager; this brings Mike a unique insight into the issues around sustainability and CSR in the food service environment.
    Mike is qualified with an MSc in Corporate Environmental Management.
    In August 2014 we began a project to segregate, weigh and report nationally, the food waste arising from our entire business. In over 750 sites we are now segregating food waste by plate waste, production waste and spoilage waste and reporting through our on-line accounting system, following significant enhancements to functionality.
    We now have the ability to monitor actual food waste by weight, cost and environmental impact on a daily basis and also as a percentage of food and beverage purchases. The segregation, weighing and reporting process along with an interactive purpose built training session; part of our in-house modular environmental and behavioural change training programme ‘Greenflash’, has resulted in an 33% reduction in food waste arising, saving over £1.5 million 12 months of the project so far equating to a carbon saving of 8,259 tonnes CO2e based on full life cycle footprint, in real terms the equivalent of taking 2,200 cars off the road for a year! This has not only reduced costs in terms of food and beverage purchases but also delivered massive savings related to the cost of waste disposal or recycling.
    Where we have been able we have a programme for tracking energy consumption using distribution board real time monitoring (AMR). When we do this it is essential to monitor against a functional unit to take account of sales variations and seasonality. At RBS as an example, we elected to use the amount of energy consumed to generate one pound of sale, this gave us a baseline that allowed us to drive efficiency and savings. In the first eleven months of the collaborative project we have seen a 27% saving in energy consumption.
    Our collaborative relationships with our suppliers deliver real benefits in delivering the highest service standards & support for chefs relevant to each client. Our supplier agreements ensure that our Premier Partners deliver real innovation to our units and the freshest of produce arrives with the lowest number of road miles to deliver it.
    We purchase goods and services from a large number of suppliers (79% of which are SME); we operate under a decentralised buying model, whereby our chefs have the autonomy to purchase from any supplier within our dual supply framework. We have a team of experienced purchasing managers who cover defined product groups and manage the supplier relationship within those groups. We pride ourselves in our long term supplier partnerships ensuring food security, quality and consistency. We also monitor environmental performance of our suppliers using our Supplier CSR questionnaire.
    We also have a purchasing analyst who assists in the selection of local suppliers who can provide sustainable, locally sourced, fresh and seasonal ingredients to our locations. Alongside this, consideration is also given to the key pillars of sustainable business.
    New suppliers are introduced through various sources. A formal supplier approval process is in place to ensure that these suppliers meet our expectations with regard to food safety, health & safety, quality, financial stability and that commercial aspects of their business are suitable.
    New suppliers will complete our Food Contractor and Supplier Appraisal Questionnaire which includes questions on food safety, health and safety and quality. We require our suppliers to have a third party accreditation e.g. BRC, ISO 22000, IFS, NSF, EFSIS etc. For small, local suppliers, with an annual turnover of less than £1 million, we are happy for SALSA accreditation to be in place. For a new supplier in their first year of supply to WSH this may alternatively be provided by an audit arranged through our nominated external auditing company, the European Safety Bureau (ESB). We also require details of product specifications to be provided so that ingredient and especially allergen details can be made available to our locations. We will in addition carry out a programme of supplier audits, depending on our risk assessment of suppliers.
    BaxterStorey is committed to ensuring that all dealings with our suppliers are conducted in line with the guiding principles of ethical and responsible trading. We adhere to the Ethical Trading Initiative Base Code.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates environmental performance.

  • As part of BaxterStorey’s ISO 14001 accredited EMS and ISO 50001 EnMS, the business operates a legal register to ensure compliance and has robust plans regarding emergency preparedness. The management board regularly review the systems and outcomes and is influential in developing environmental plans and strategies for the coming period.

Anti-Corruption
  • Assessment, policy and goals
  • Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.

  • BaxterStorey operates a robust Anti-Corruption and Bribery policy which is managed by the ethics committee and as such has risk assessed the risk of corruption when doing business
    Discussion and or text around Anti-corruption and ethical behaviour forms part of all contract negotiations with clients and suppliers
    As part of BaxterStorey’s Anti-Corruption and Bribery Policy all employees are bound to the procedures as laid out in the policy and all internal activities and procedures are bound by that policy
    BaxterStorey take their responsibility as a business to prevent slavery and human trafficking very seriously. As such, the Integrity and Ethics Committee is working closely with Supply Chain, HR and Legal to ensure that there is sufficient policies and procedures in place and that there published statement is meaningful to the public, clients and customers.

  • Implementation
  • Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.

  • BaxterStorey operates a robust Anti-Corruption and Bribery policy which is managed by the ethics committee and as such has risk assessed the risk of corruption when doing business
    Discussion and or text around Anti-corruption and ethical behaviour forms part of all contract negotiations with clients and suppliers
    As part of BaxterStorey’s Anti-Corruption and Bribery Policy all employees are bound to the procedures as laid out in the policy and all internal activities and procedures are bound by that policy.
    A key role of the ethics and integrity committee is to develop a training strategy for all employees to include all areas of ethics, integrity, risk, bribery and corruption.
    The Bribery Act Compliance Committee was established with the approval of the Board on 6 June 2011. The functions of the committee were to (i) meet to discuss progress against a step plan and (ii) be involved in the ongoing monitoring of anti-bribery policies and procedures. In 2015 the remit of the committee was extended to include data protection, competition law, other legal risks as well as the Bribery Act, PCI compliance and integrity.
    BaxterStorey’s business ethos is to “do the right thing” and act ethically, with integrity. As a result the Bribery Act Compliance Committee was re-named as the Integrity and Ethics Committee.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates anti-corruption performance.

  • The ethics and integrity committee is engaged in measuring outcomes and is responsible for reporting to the BaxterStorey board on all issues and reports regarding ethics and integrity.