We have a Group Code of Conduct, and all our employees, our leaders and our board receive training in business ethics.
Code of ConductThe 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.
Anti-bribery and Corruption
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:
- Do not permit the making of any inappropriate promises, gifts or hospitality for any purpose, including to achieve an unfair advantage or benefit. Our Gifts and Hospitality Procedure sets out financial limits and approval levels for gifts and hospitality and requires that both gifts and hospitality must be recorded in a business’ Gift & Hospitality register
- Resist any efforts made by others to unfairly affect our business decisions in order to achieve an unfair advantage or benefit
- Support our chosen charities, but are careful to manage potential conflicts of interest, and recognise that some charitable donations could constitute a bribe if, inadvertently or otherwise, they procured an unfair advantage
- Do not make facilitation payments nor do we permit others to make them on our behalf
- Continuously assess the anti-bribery and corruption risks associated with the activities, geographical location and sectors of our business operations to continuously improve our anti-bribery and corruption compliance programme, which includes our policies, procedures and training. Principal risks, including those in respect of anti-bribery and corruption are monitored by the Risk & CSR Committee and are reviewed at least annually. Such risks are identified in a risk register, assigned to an owner with responsibility for assessing and managing the risk
- Conduct risk based due diligence on all third parties engaged by the company, including enhanced due diligence as required and establishing the ultimate beneficial ownership of entities to inform the bribery and corruption risk assessment. This applies to our customers, suppliers, joint venture partners, commercial intermediaries and other third parties
- Have procedures governing the approval, appointment and management of commercial intermediaries, which are applied in all countries and sectors where we use such intermediaries
- Engage commercial intermediaries to support our business activities only where:
- There is a clear business need and justification for the proposed remuneration
- Proposed remuneration levels align to industry/regional norms in recognition that remuneration of CIs is a risk factor in bribery and corruption
- The legal team have assessed the bribery & corruption risk level of the proposed intermediary
- Due diligence and enhanced due diligence for higher risk intermediaries is conducted prior to appointment and updated every two years or in the event of a significant change of circumstances
- The ultimate beneficial ownership of the proposed CI has been established
- Any risks identified through due diligence have being satisfactorily mitigated
- The proposed CI (without exception) agrees to clear contractual terms requiring them to comply with bribery and corruption standards and our Code of Conduct
- Include bribery and corruption provisions in relevant contracts with third parties (including Joint Ventures and commercial intermediaries), along with rights of audit and termination in the event of a breach
- May enter into offset arrangements where these form part of the country’s regulatory requirements. Such arrangements
- have a clear business rationale
- are overseen and monitored by the Commercial team
- are subject to review and approval, including risk-based anti-bribery and corruption due diligence
- include anti-bribery and corruption clauses in contracts
- are assessed for financial and non-financial risks and suitable mitigating actions put in place
- Expect our business partners (including Joint Ventures and commercial intermediaries) to implement and enforce effective systems to counter bribery and corruption.
- Commit to establishing governance frameworks that are consistent with our own with the Joint Ventures in which we are a shareholder. QinetiQ employees appointed as Joint Venture board members will seek to influence the adoption of ethical policies and procedures, including those to counter bribery and corruption. Joint Venture employees have access to our Ethics Helpline and confidential reporting line
Modern slavery and human rights
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:
- QinetiQ Group plc FY21 Modern Slavery Statement
- QinetiQ Group plc FY20 Modern Slavery Statement
- QinetiQ Group plc FY19 Modern Slavery Statement
- QinetiQ Group plc FY18 Modern Slavery Statement
- QinetiQ Group plc FY17 Modern Slavery Statement
- QinetiQ Group plc FY16 Modern Slavery Statement
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.
Help and advice
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.
Policy and process
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.