Business conduct and ethics
Applying our Business Conduct and Ethics (BC&E) commitments across every ERM office and activity, every day, depends upon the involvement and awareness of individual employees and leaders.
We have established several recommended and mandatory online training courses on ethics and risk management, which are delivered through the ERM Academy. We continue to update our bribery, corruption and ethics training to address existing topics in greater detail for certain employees, deep reviews for specific jurisdictions, data privacy requirements (as part of implementing ISO 27001, the industry standard in this area) and other topics as required.
Upon joining the company, all new employees must participate, through the ERM Academy, in a set of seven interactive, web-based training courses covering international anti-bribery and corruption, insider trading, practical ethics and the regulatory requirements specified by the UK Bribery Act. In FY16, we achieved 97 percent training completion for all "new joiners" within the required timeframe with follow-up efforts to ensure those who did not meet the original timeframe ultimately completed the training.
Anti-bribery and corruption (ABC)
ERM supports governmental and societal efforts to combat bribery and corruption. Our commitment, which is detailed in our Code of Conduct and supporting policies, is fundamental to how we operate and is embedded into our key systems and programs. For more on the location of anti-bribery and corruption-related disclosures in this report, see our UN Global Compact Content Index, which includes details of our reporting on Principle 10 – Anti-Corruption.
In FY16, we began refresher training for the ERM workforce on the UK Bribery Act. Training was provided for all staff who had passed two-year milestone since their prior anti-bribery and corruption training. As a result, 82 percent of the targeted population completed refresher training in FY16, and the remainder will complete the training in FY17.
As a global business that has worked in more than 160 countries in the past three years, we recognize our responsibility to support and respect the protection of internationally proclaimed human rights, as defined by the UN Guiding Principles on Business and Human Rights.
ERM supports international efforts against child and forced labor and has a specific Slavery, Child Labor and Human Trafficking Policy. Our policy prohibits the use of child or forced labor or involvement by ERM with entities that support prohibited labor practices, including slavery, bonded labor or debt-bondage and other types of coercion or corruption. As our Contractor Management Program is implemented progressively around the world, we have a more consistent approach for mandating contractors and suppliers to adhere to these and other similar requirements, and also track their compliance.
In addition to making this commitment within our own business, we work with our clients globally to improve their human rights practices. Our social and health consulting services teams identify and provide advice on labor, supply chain management, land access and indigenous rights issues.
In September 2016, ERM released its Slavery and Human Trafficking Statement for FY16. This is our first annual statement in alignment with the UK Modern Slavery Act 2015 and reflects our commitment to international efforts to abolish all forms of modern slavery - including slavery, servitude, forced or compulsory labor and human trafficking, as well as child labor. The statement sets out the measures in place in ERM and the further steps to be taken, to ensure there is no slavery and human trafficking in our business operations and supply chain.
The details of our approach to human rights are included in the UN Global Compact content index.
ERM's Code of Business Conduct and Ethics and other key policies are available on erm.com.