We place significant focus on governance issues, from the Board to our Partners and all employees.

• Upon joining the company, all new employees must participate, through the company’s learning and development platform the ERM Academy, in interactive, web-based training. The mandatory training courses cover international anti-bribery and corruption, the regulatory requirements specified by the UK Bribery Act, insider trading and practical ethics, as well as requirements specific to some parts of Latin America and North America, health and safety, and the UK Modern Slavery Act.

• Existing employees are required to take refresher web-based training through the ERM Academy.

• Every Partner must complete an annual self-certification on compliance with our anti-bribery and corruption policies.

• Outside legal counsel advises the Board on how to operate effectively and in accordance with its roles and responsibilities.

Our written Global Code of Business Conduct and Ethics sets clear requirements to ensure we conduct business with uncompromising honesty, integrity and compliance with laws and regulations. Our commitment to combat bribery and corruption is fundamental to how we operate and is embedded into our key systems and programs. We apply our business conduct and ethics commitments across every ERM office and activity, every day, with the involvement and awareness of all our employees. All employees and Partners are held responsible for compliance with our Code and policies.

For more on the location of anti-bribery and corruption-related disclosures in this report, see our UN Global Compact Index, which includes details of our reporting on Principle 10, Anti-Corruption.

Programs and initiatives

During FY19, we continued to strengthen our programs and initiatives associated with business conduct and ethics:

• We developed and deployed a mandatory online training module for all employees regarding modern slavery, pertinent to our specific industry and operations.

• We revised our internal policies and procedures on subcontractor management. We continue to expand and improve subcontractor management in the many jurisdictions where we operate.

• We participated in building external standards and providing education so that momentum not only builds in our sphere of business influence but beyond, fully aligned with our purpose of shaping a more sustainable future with the world’s leading organizations.

• We launched a global anonymous reporting system (helpline) so that concerns about our business operations, including modern slavery and any other form of unethical business conduct, can be reported without fear of retaliation. The system is available 24 hours a day, 7 days a week, by a web portal or call-in line, and is managed by a third party to protect confidentiality.