Integrity and ethics

A range of policies and procedures mandate that everyone who works at Carillion does so with high ethical and moral standards.

Our Board also expects suppliers and customers to share this commitment, as outlined in our Ethics and Business Integrity Policy. An independent committee of the Board, the Business Integrity Committee, reviews and oversees the implementation of the Group‘s Ethics and Business Integrity Policy. It also monitors Carillion‘s compliance with relevant legislation, such as the Bribery Act 2010 and the Competition Act 2006.

The Business Integrity Policy applies to all Carillion‘s businesses through a series of detailed procedures. They allow us to maintain our reputation for conducting business to the highest ethical standards, which are essential to its relationships with customers, business partners, our people, shareholders and the public.

Our Ethics and Compliance Office provides dedicated support for this work, and our Directors and senior managers complete annual compliance returns to ensure our approach remains appropriate.

Carillion‘s Ethics and Business Integrity Response Plan outlines the actions that should be taken in the event of a suspected policy breach. It ensures investigations are conducted fairly and decisions are taken by suitable individuals.

Investing in Integrity

Our international operations were awarded the Investing in Integrity (IiI) Charter Mark following a rigorous accreditation process involving 3,000 of our people. The Charter Mark enables us to reassure stakeholders that we commit to acting with integrity at all times: we are the only business in our sector to achieve it.

The independent accreditation included site visits, interviews and surveys carried out by an independent assessor (the Good Corporation), alongside analysis of ethical policies, procedures and practices.

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Zero tolerance approach to corruption

We absolutely prohibit bribery or corruption of any kind, including both the offering and accepting of bribes, through our Disciplinary Policy. We mandate our people and others to come forward if they witness or suspect unethical behaviour that is in potential breach of our policy. Gifts and hospitality and conflicts of interest must be declared and documented.

We continue to provide our people with face-to-face and online training on our competition, ethics and business integrity policies. In 2014 we delivered face-to-face training to over 330 senior employees, as part of a company-wide training rollout.

Carillion has a zero tolerance approach to fraud and corruption. Internal Audit works alongside independent managers to investigate allegations and prevent and detect improper behaviour. Carillion’s Audit Committee receives regular updates on all allegations reported, and investigation outcomes.

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Respect for human rights

We believe that human rights are universal and we support the United Nations Declaration on Human Rights, as laid down in our Ethics and Business Integrity Policy (PDF 98 KB). Employees are trained on this policy and we report performance through the Competition Act training statistics. All suppliers have to sign up to the policy and monitoring compliance is the responsibility of our Group Compliance Office.

We work hard to ensure that in all areas of interaction with employees, clients, suppliers, third parties, interviewees and joint venture parties, that everyone is protected and treated absolutely fairly. See the Promoting diversity section for more information.

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Whistleblowing

We actively encourage our people to raise concerns about fraud, corruption, or any other malpractice at the earliest possible stage. They can do this by talking to their managers or through monthly Team Talks and feedback sessions. We also have a confidential whistleblowing hotline provided by an independent third party. Details of our approach are in our Whistleblowing Policy.

In 2014, 210 whistleblowing cases were reported across Carillion. Of these cases, 122 related to fraud, 59 related to HR and 29 cases were categorised as ‘other’.

As at 31 December 2014, 164 cases have been investigated and closed, and among these closed cases, 51 resulted in either disciplinary action taken against our people, the reimbursement of losses or the implementation of control or process improvements to prevent or reduce the likelihood of the impropriety occurring again. The remaining 113 cases were either unfounded or required no action. As at 31 December 2014, 46 whistleblowing investigations were in progress.

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False claims about blacklisting

Along with other companies in the construction industry, over the past few years Carillion has been accused of being involved in the illegal blacklisting of workers. This is not true.

Blacklisting relates to the use of the Consulting Association database many years ago by companies in the industry. At Carillion, we pride ourselves on our strong Values and high standards of corporate governance and we do not condone or engage in blacklisting. A former Carillion subsidiary did access this database but this practice was stopped, voluntarily, over a decade ago and before it became unlawful. Since then we have apologised for our use of the database and any damage it may have caused. To provide an accurate picture we have set up a section of our website with regards to false claims about blacklisting.

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1,500 hours training delivered to 330 senior employees in competition, ethics and business integrity policies in 2014

By signing up to Investing in Integrity, Carillion has begun a journey which will be challenging and rewarding. They have worked hard across the UK, Middle East and Canada to gain accreditation. By achieving IiI, Carillion has demonstrated they are serious about behaving ethically.”

Philippa Foster Back CBE, Director, Institute of Business Ethics

Richard Tapp

Now more than ever, the public rightly expects businesses to behave responsibly and openly. For Carillion people, this is exactly how we operate – across our international operations – and this was key to us achieving the Investing in Integrity Charter Mark.”

Richard Tapp, Company Secretary and Legal

PwC Building Public Trust Award first FTSE company to retain the FTSE 250 Sustainability Reporting Award for a second consecutive year

We apply the same globally recognised standards of excellence to all our operations, whatever the jurisdictions. See how we have done this in Qatar.

Carillion plc, Company No. 3782379. Registered Office: Carillion House, 84 Salop Street, Wolverhampton WV3 0SR. Place of Registration: England and Wales

Copyright 2015 Carillion plc

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