Photo credit: Robin Kennish, Hong Kong
We place a significant focus on ethical and responsible decision-making, from the Board to our Partners and all employees. Our training, systems and procedures provide the guardrails for making ethical decisions in every facet of work at ERM.
On a global basis, ERM requires all new employees to undertake a mandatory curriculum of training on compliance, health and safety as part of their induction. All such training must be completed within no more than 90 days of start date. As at the end of FY21, excluding acquisitions, for a new hire population of 1,253, 99% completed (end FY20 was 92% and FY19 was 88%). Additionally, refresher training occurred for all personnel who have been with ERM for more than three years for a population subset of 2,617 and a completion rate of 98% as at 6 April 2021. Existing employees are required to take refresher web-based training through the ERM Academy. Refresher training covers:
- ERM Code of Business Conduct and Ethics (which includes confidential information and computer security, conflicts of interest, promoting diversity and inclusion, reporting and non-retaliation, and electronic communications);
- Anti-bribery and corruption; and
- Key health and safety policies and processes.
Every supervisor must complete an annual self-certification on compliance with our global policies regarding conflict of interest, manager duty and anti-bribery and corruption policies. Our international Helpline, available in 18 languages, allows employees to raise concerns anonymously without fear of retaliation.
Our written Global Code of Business Conduct and Ethics sets clear requirements to ensure we conduct business with uncompromising honesty, integrity and compliance with laws and regulations. Our commitment to combat bribery and corruption is fundamental to how we operate and is embedded into our key systems and programs. We apply our business conduct and ethics commitments across every ERM office and activity, every day, with the involvement and awareness of all our employees. All employees and Partners are held responsible for compliance with our Code and policies. For more on the location of anti-bribery and corruption-related disclosures in this report, see our UN Global Compact Index, which includes details of our reporting on Principle 10, Anti-Corruption.
Programs and initiatives
Our approach to business conduct and ethics includes:
- Internal policies and procedures on subcontractor management. We continue to expand and improve subcontractor management in the many jurisdictions where we operate.
- Trade sanction and humanitarian screenings and risk analysis for clients, locations and opportunities.
- Participation in building external standards and providing education so that momentum not only builds in our sphere of business influence but beyond, fully aligned with our purpose of shaping a more sustainable future with the world’s leading organizations.
- Global anonymous reporting system (Helpline) so that concerns about our business operations, including modern slavery and any other form of unethical business conduct, can be reported without fear of retaliation. The system is available 24 hours a day, 7 days a week, by a web portal or call-in line, and is managed by a third party to protect confidentiality. Additionally, we have internal resources directly available and also have an email for subcontractors to address concerns. Overall, we received 6 reports during FY21 (through to 31 March 2021). The low reporting is likely attributable to pandemic circumstances (e.g., due to quarantine and little travel).