Governance

INEOS is committed to maintaining high ethical standards and operating responsibly in accordance with the law and its Code of Conduct, which is regularly updated and shared with our employees and key external stakeholders. Individually and collectively our teams are accountable for legal compliance, and our requirements and behavioural expectations for all INEOS businesses and their employees are outlined in the code.

The board of each INEOS business is responsible for ensuring that it adheres to INEOS' policies and operates within the law at all times. Legal compliance is a regular item on board agendas. To assist the board, a compliance manager is embedded within each business. The managers lead legal compliance initiatives, are responsible for ensuring INEOS policies are followed, and support the board with the development and implementation of a business compliance plan.

There are four key areas to compliance management that businesses must address:

1. Anti-bribery & corruption
2. Anti-slavery, anti-child labour & anti-people trafficking
3. Anti-trust /competition law
4. International trade/sanctions

INEOS’ Sustainability Governance Structure

Networks are fundamental to INEOS’ system of sustainability governance due to our federal structure. As well as playing a critical role in developing group-wide policies, as mentioned above, our cross-business networks are used to disseminate information on group policies and targets, share sustainability best practice, and collaborate on managing cross-business sustainability issues.

1. INEOS’ climate and energy network (CEN) is coordinated at group level via a steering group that oversees eight issue teams working on a comprehensive range of sustainability topics. Issue and topic leads are experts from within our businesses; they have ownership of specific ESG areas and share expertise across the group through the network. Leads are also selected to represent each INEOS business and country of operation, and a dedicated future-looking group of young colleagues (yCEN) prepares post-2025 strategies and actions in dedicated calls every two months. Ultimate governance of CEN is provided by our CEOs and directors. News reports are distributed to all CEN members weekly, steering group calls and mailings happen monthly, and the network holds a globally attended annual meeting.
2. INEOS Operations Directors meet three to four times a year on manufacturing excellence days to discuss matters such as SHE performance, ISO management systems, energy efficiency audits, water and waste audits, and emission reduction plans.
3. INEOS Procurement and Business Directors meet every two months to discuss matters such as implementing INEOS' Supplier Code of Conduct, sourcing sustainable feedstock, purchasing emissions allowances, calculating product footprints, and exploring power purchase agreements (PPA).
4. INEOS HR directors have monthly meetings to discuss matters such as workforce data, the composition of INEOS' workforce, training and career development, working conditions, human rights, ethics, and INEOS' Code of Conduct.
5. INEOS CFOs meet on an ad hoc basis to discuss matters such as carbon pricing, carbon border adjustments, energy taxes, roadmap investments, investor relations, sustainable financing, and ESG disclosures.