The Management Structure for implementing the Business Principles:

Board: The Company’s Board has the responsibility for agreeing the Business Principles and monitoring the progress of implementation through their regular meetings.

Management: The Group Management team has the responsibility to implement the Business Principles including setting and reviewing targets for improvements. Group Management members are present in the following councils which develop policy, processes and monitor progress in specific areas:

• Commercial Ethics Council (Anti-Bribery & Corruption also Export Control);
• Health and Safety Council;
• Environmental Council.

Managing Directors of subsidiary companies have the responsibility to translate the Principles and associated policies into local rules and procedures in addition to those required for compliance with local legislation.

Line Managers have the responsibility to ensure that their employees understand the Principles and receive relevant education and training in order to implement them.

Employees: Each employee should have a good working knowledge of the Principles and policies relevant to their jobs and apply them in their work.

Audit: An independent internal audit function provides support in monitoring compliance with the Business Principles.