“At QinetiQ, trust is our most prized possession and is something that underpins our approach to ethics, integrity and reputation. This forms the foundation of how we do business and manifests itself in everything we do; our relationships with our customers and stakeholders, industry partners, and shareholders. It also drives how we work with each other.”
We have a Group Code of Conduct, and all our employees, our leaders and our board receive training in business ethics.
The Group Code of Conduct underpins how we do business. Its purpose is to clearly articulate our ethical standards and provide employees with a guide to what is expected of them in their behaviour and business activities. It provides information on how they can get help, and also guidance on their responsibility to report, if they identify a problem. Within the Code we provide guidance to ensure employees are aware of, and understand, their ethical and legal responsibilities, and cover issues relating to employees, customers, shareholders and the community. Employees are given support on a range of topics such as diversity; safety; managing information; anti-bribery and corruption; and the environment. The code was updated in April 2023.
We are committed to upholding the highest ethical standards and operate a zero tolerance approach to bribery and corruption in any form; acting professionally, fairly and with integrity in all our business dealings and relationships. We:
We seek to anticipate, prevent and mitigate potential negative human rights impacts through our policy and processes, which underpin our commitment to responsible business practices. For example, we address salient human rights issues (including modern slavery) through our Code of Conduct, ethical trading policy, international business risk management process and export controls process. Our approach is based on The United Nations Guiding Principles on Business and Human Rights and applicable national laws, regulations and standards. We monitor the application of these policies and procedures through our business assurance processes. We believe that this integrated approach is effective. We have in place formal grievance mechanisms with clear routes for people to raise concerns and they will be addressed (details can be found in our Code of Conduct, which is for our people, partners and suppliers).
As part of the requirement of the UK Modern Slavery Act, each year we are required to publish a statement setting out the measures QinetiQ Group plc takes to prevent slavery and human trafficking in our business and supply chain. The Act requires that we publish our most recent statement on our homepage but we think it is helpful that previous versions are made available; our statements can be downloaded here:
Annual business ethics training is mandatory for all employees across the Group and for the Board in all appropriate languages (currently English and German). It covers a range of issues such as anti-bribery and corruption, diversity, modern slavery and conflict of interest. The training also includes Information about the Code of Conduct, ethics decision making, how to get advice, and how to report an issue.
We monitor the effectiveness of our business ethics communications and training through our on-going internal assurance programme; employee feedback; lessons learned from ethical queries and through face to face dialogue with managers.
We also provide more in-depth anti-bribery training for those in higher risk roles,. Employees are also provided with refresher courses to ensure their knowledge is kept up to date. In addition, our values (Integrity, Collaboration and Performance) are formally part of our performance management system and end of year appraisal.
If employees need help or advice, they are advised to talk to their manager first but we also provide ethics email advice services a network of Ethics Champions and a confidential reporting line. The confidential reporting line is independently run and provides a confidential 24/7 service. The contact details of our Group General Counsel are also made available for reporting issues or concerns to. We respond to a number of queries through the ethics advice services each year and all communication through the confidential reporting line is investigated. All of this advice is outlined in the Code of Conduct.
The confidential reporting system is available to all employees of QinetiQ Group and externally to stakeholders and third parties (such as customers, suppliers, members of the public), either via the website or phone number. Cases are managed via an externally run confidential reporting system, and there is an option to remain anonymous when reporting. A response is sent to the reporter in all instances, and the system will allow access to view responses even if the report is made anonymously.
Confidential reporting is managed day-to-day by the Group Head of Internal Audit in order to facilitate independent investigations where required. Updates are provided to the Audit Committee and Risk & CSR Committee on the number of cases reported, the topics being raised in the reports, and the status of the investigations. We have policies in place to ensure the quality of investigations, which are reviewed at least annually.
Strong governance underpins responsible business practice and the Group has Board and Executive level commitment to corporate responsibility through the Group Risk & CSR Committee. The committee meets regularly and receives briefings on all material risk and CSR issues, including business ethics and anti-bribery and corruption.
Our Business Ethics Committee comprises member of our Executive committee and subject matter experts such as Governance, Corporate Responsibly, Trade Compliance and Operations. The Group meet monthly and their remit is to oversee our ethics programmes.
Oversight of our anti-bribery and corruption programme is provided by our Chief Ethics Officer who provides quarterly briefs of the programme status to the Chief Executive Officer and the Risk & CSR Committee. We adopt a zero tolerance approach to bribery and corruption.
Our policies, procedures and tools underpin our business ethics programmes. Included in these processes are risk assessment, due diligence, and sustainable procurement. How and what we buy is an integral part of improving our sustainability, so we continue to focus on the way we work with our suppliers. In the UK we are an active member of the MOD-Industry Sustainable Procurement Working Group. We have a robust process for undertaking due diligence, monitoring and audit of our use of commercial intermediaries; and we use expert third party due diligence providers to support our processes.
QinetiQ is an active Corporate Member of the Institute of Corporate Responsibility and Sustainability. We are a signatory to ASD (Aerospace and Defence Industries Association Europe) Common Industry Standards and a member of the ADS Business Ethics Forum.
QinetiQ upholds the principles and conventions of the ILO through the policies and processes that we operate such as ethical hiring practices, employee confidentiality and safeguarding, grievance and resolution mechanisms, compliance with labour laws and standards and freedom of association.
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