Serco Group plc

Based on public information, there is evidence that the company publishes statements from both its Chief Executive as well as its Chairman strongly supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the Chief Executive or the Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company, for example through public speeches or interviews, or personal involvement with industry anti-corruption initiatives. TI notes the recent public statements made by the Chairman, acting CEO and now new CEO; but understands these to have been made in connection with the public scrutiny the company has recently been under rather than as part of ordinary business.

Based on public information, there is some evidence that the CEO demonstrates a strong internal facing commitment to the ethics and anti-corruption agenda of the company. TI notes the video message to staff from the CEO. The company therefore scores 1.

Based on public information, there is evidence of the company publishing statements representing high standards of business conduct, including integrity, trust, honesty, openness and transparency. The statements are published both in the Corporate Governance Report and also the Policy Statement on Governance and ethics.

Based on public information, there is evidence that the company is a member of the DII and IFBEC, as well as other bodies promoting anti-corruption and business ethics.

Based on public information, there is evidence that the company has appointed a Board level Executive Committee and a Corporate Responsibility Committee with responsibility for the company’s ethics agenda. There is evidence of Terms of Reference for these committees, as well as indications that they review and monitor the Company’s ethics and anti-corruption policies.

Based on public information, there is evidence that the Director of Business Compliance and Ethics is responsible for implementing the company’s anti-corruption agenda. The name of this individual is available on the company website: Robert Smith, Director of Business Compliance and Ethics.

Based on public information, there is evidence that the company monitors its ethics and anti-corruption agenda in a manner that is overseen and also reported back to the Board. Furthermore, TI notes that an independent review was carried out in 2013.

Based on public information, there is some evidence that the company has benchmarks and a review plan in place but its specific details remain unclear. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal process that is concerned with the improvement and update of the ethics and anti-corruption plan. This can be seen particularly based on the company’s response to allegations that were made in 2013.

Based on public information, there is evidence that the company has a formal risk assessment procedure for assessing ethics and corruption risks with plans and regular reviews in place.

Based on public evidence, there is evidence that the company has a formal risk assessment procedure and that it conducts an ethical risk assessment to inform business decisions.

Based on public information, there is evidence that the company does carry out a process of due diligence in reference to selecting or re-appointment of its agents. However, it is not clear that the due diligence is refreshed at least every three years or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour of agents with respect to countering corruption. However, the extent to which the company has monitoring and auditing rights is not clear. The company therefore scores 1.

Based on public information, there is evidence detailing the company’s policy to convey its stance on corruption to its suppliers and other associated parties and the consequences of breaches to this stance.

The company has informed TI that it does not engage in offset contracting.

The company has informed TI that it does not engage in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is evidence that the company has a zero tolerance against corruption. Its anti-corruption stance is clear and visible throughout the company’s policies.

Based on public information, there is evidence that the company’s anti-corruption policy contained in its Code of Conduct and Group Standard on Business Conduct and Ethics are easily available and accessible online. TI notes that the Code of Conduct is available in Arabic, Brazilian Portuguese, Chinese, Dutch, English, Flemish, French, German, Italian, Polish and Spanish.

Based on public information, there is evidence that the company’s anti-corruption policy easily is understandable and clear to Board members, employees and third parties.

Based on public information, there is evidence that the company’s anti-corruption policy applies to all employees regardless of their position. However, it is not clear from publicly available information that this also applies to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, and it applies to both employees and Board members. TI notes that a definition of conflict of interest is provided.

Based on public information, there is evidence that the company has a policy on the giving and acceptance of gifts that guards against corruption. However, information on upper limits or authorisation thresholds of the same is not clear. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on the giving and acceptance of hospitality that guards against corruption. However, information on upper limits or authorisation thresholds of the same is not clear. The company therefore scores 1.

Based on public information, there is evidence that the company has a clear policy against facilitation payments across the geographies it operates.

Based on public information, there is evidence that the company has a detailed policy in reference to political contributions. Whenever political contributions or appearances at political functions are required, the company provides guidance on the process and limits of the company policy for the concerned employee.

Based on public information, there is evidence that the company has a policy in place that regulates lobbying activity and also provides guidelines on its application.

Based on public information, there is evidence of guidance to control and regulate charitable contributions. TI notes that the company declared charitable contributions made to the Serco foundation in 2013.

Based on public information, there is evidence that the company provides written guidance to help employees and Board members understand and implement the company’s ethics and anti-corruption agenda. This includes access to an app designed to help employees implement the company’s ethics and anti-corruption agenda.

Based on public evidence, there is evidence available that the company has a training programme that covers anti-corruption as its component.

Based on public information, there is evidence that anti-corruption training is provided in all countries where the company operates or has company sites, to both new and existing employees. The company therefore scores 2.

Based on public information, there is some evidence of training being provided to members of the Board on matters of risk. However, it is not sufficiently clear that this training includes components on issues of bribery and anti-corruption.

Based on public information, there is limited evidence that the company provides specific and tailored training to employees in sensitive positions. The company therefore scores 1

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. However, it is not clear that the declaration should be made to an independent department. The company therefore scores 1.

Based on public information, there is evidence that the company commits to take disciplinary action against employees found to have engaged in corrupt activities. However, it is not clear that this also extends to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has several confidential and anonymous channels which are also well publicised through which an employee can report suspected instances of corruption.

Based on public information, there is evidence that the company whistleblowing channels are available to all employees and are also freely accessible on the internet.

Based on public information, there is some evidence from the company of putting in place an international standard whistleblowing process and practise. TI notes particularly that the company runs a periodic review of cases to monitor the impact on whistleblowers. However, to what extent employees are encouraged or treated in a supportive manner cannot be fully ascertained. The company therefore scores 1.

Based on public information, there is evidence that the company has well-publicised resources where advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company has safeguards in place to protect whistleblowers with disciplinary measures in place for cases of retaliation.