ESG 23 Final Single pages - Flipbook - Page 62
Governance
We are strongly committed to
upholding the values of good
governance as we believe it is
important for the long-term success of
the business – our clients can depend on
us, we can attract the top talent we need
to help us innovate, our suppliers can rely
on us, and it helps us secure the support
of our investors. RWS is committed to
promoting transparent, fair and timely
decision-making that considers the needs
of all our stakeholders.
BUSINESS ETHICS
Key policies published on our website
include
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Code of Conduct
Anti-Bribery and Corruption Policy
Client Entertainment and Gifts Policy and Procedure
Corporate Sustainability Policy Statement
Environmental Policy
Diversity, Equity and Inclusion Policy
Harassment, Bullying and Victimisation Policy
Health and Safety Policy
ISMS Policy
Labour and Human Rights Policy
Modern Slavery and Human Tra昀케cking Policy
Speak-up Policy
Supplier Code of Conduct
Sustainable Procurement Policy
We take a zero-tolerance approach to bribery and
corruption, 昀椀nancial crimes, and other violations against
professional integrity.
RWS is committed to acting professionally, fairly and
with integrity in all our business dealings and does so
in compliance with the RWS Group Code of Conduct.
The Code of Conduct is reviewed annually to remain
consistent with ever-changing regulatory standards
and guidance. All colleagues must complete the Group
Code of Conduct and undertake ethics training on an
annual basis, and we require that everyone in our supply
chain adheres to the same ethical standards as RWS.
Completed training for RWS colleagues for FY23 was
98%.
We believe that, with our policies, procedures and
controls, together with the nature of our business,
the risk of the Group encountering 昀椀nancial crime or
corruption is low. Nevertheless, we must always be
vigilant and prepared to identify such activity and know
how to deal with it if encountered.
RWS has speci昀椀c policies in place which ensure that
professional integrity is adhered to covering the
following subjects – anti-money laundering, anti-bribery
and corruption, 昀椀nancial crime and fraud, modern
slavery and human tra昀케cking, sanctions and speaking
up, amongst others.
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RWS Holdings plc — ESG Report 2023 GOVERNANCE
RWS takes its sanctions obligations seriously and
continues to ensure awareness of sanctions issues across
all its teams and remains vigilant in combatting sanctions
breaches.
RWS requires all colleagues, contractors, and partners to
operate in a professional, ethical, and diligent manner and
be transparent on all possible con昀氀icts of interest.
RWS works with external law 昀椀rms and consultants to keep
up-to-date globally on any changes to legal and regulatory
standards to ensure that any new legal requirements are
re昀氀ected in its policies.
All con昀椀dential and personal data is governed by terms of
engagement between RWS and its clients, suppliers, and
partners. Data is handled only by authorised personnel
in a secure manner in accordance with GDPR and other
applicable data privacy and data security regulations and
standards.
RWS maintains a governance framework which describes
the company’s structure and governance, roles and
responsibilities, review of strategy and risk, and
appropriate delegations of authority.
We encourage any form of corrupt or suspicious
behaviour to be reported either through an independent
third-party portal or via internal processes speci昀椀ed in
our Speak-up Policy. The investigation and response to
any reports received are overseen by members of the
Executive Team and reported to the Audit Committee.
