To manage compliance day to day, we have appointed Compliance and Legal Managers in each Business. These are responsible for ensuring that Group policies on topics such as Competition / Anti-Trust Law, Anti-Bribery & Corruption ("ABC"), Sanctions, and Modern Slavery are adhered to.
Competition and Sanctions training is mandatory for all staff who could potentially be exposed to any risk. The training is developed and moderated by external international law firms specialising in that area of law. There is no limit to the number of staff a Business can enrol. We evaluate the implications of laws, regulations and sanctions as they change. We accompany this with additional training and update training modules to ensure ongoing compliance. We also conduct training on anti-money-laundering and prevention of terrorist funding, and on data security and compliance.
All our commercial contracts include provisions expressly prohibiting any transgressions of illegal behaviours.
The required level of behaviour for employees and businesses is captured in our Code of Conduct which is available to all employees on the company intranet.
We also have an independent “Speak up!” system whereby staff can report serious concerns (anonymously if necessary) across the INEOS group available in local languages 24/7/365 by toll-free phone or via an English language website. However, INEOS encourages staff to report instances of suspected malpractice to their senior manager in the first instance.