UNBOUNCE - EXAMPLE PAGE-REPORT-ENTERPRISE DOCUMENT-KINGSPAN - Flipbook - Page 83
Recommendation
Response
Develop a renewed compliance
and leadership strategy.
g Clear corporate mission statement and statement of purpose established – as
published on www.kingspan.com and as the foreword to the Group Code of
Conduct introduced in October 2020.
g Clear accountability for risk management in respect of testing, accreditation and
marketing material (the “Three Functions”) established through the creation of:
-
The Group Head of Compliance (“GHC”);
Product Compliance Officers (“PCO”) in each business;
Group Compliance Manual; and
Group Marketing Integrity Manual.
Appoint a third party expert
to audit and advise on best
practice on product fire testing,
accreditation and marketing
material.
g External consultants appointed by UK Insulation business to audit and advise
on best practice regarding the Three Functions and assist with design and
implementation of world class change management system.
Take steps to implement
consistent, well-documented and
effective controls in respect of
product testing. Develop failsafe
systems for the Three Functions
to implement the best practice
procedures, as may be advised by
the External Expert.
g The Group Compliance Manual documents the best practice procedures and
controls to be followed to secure ISO 37301 accreditation.
Implement controls in respect
of the Three Functions, ensure
there is communication training
to promote transparency around
product capabilities in the sale
process and also in respect of
engagement with third party
accreditation. Increase awareness
in risk accountability across the
organisation.
g The Group Marketing Integrity Manual introduces mandatory rules to ensure the
accuracy and transparency of marketing materials across the Group.
Review and enhance the system
and process for retaining
customer observations and data.
g Customer observations and data concerning a complaint or non-conformance
are reviewed in accordance with the process recommended in ISO 37301, and any
necessary corrective action is taken to prevent reoccurrence.
g Accreditation for the ISO 37301 Compliance Management Systems has been
achieved by the Group function and by nine manufacturing locations across four
of the five divisions. Work to secure ISO 37301 accreditation for all manufacturing
locations is underway.
g Implementation of a group-wide Product Information Management
(PIM) infrastructure to ensure control and accuracy of all product information
is underway.
g Awareness in risk accountability concerning compliance with the Three Functions
underpinned by the principles in the Group Code of Conduct, by the appointment
of the GHC, the PCOs and by the implementation of ISO standards and on-going
training across the Three Functions.
g Net Promoter Score surveys undertaken annually, and the customer trends and
feedback are shared with each business unit.
Establish a sub-committee of
the Kingspan Group Plc Board to
include non-executive directors,
to monitor compliance and the
Three Functions.
g The role of the Audit Committee has been expanded into an Audit & Compliance
Committee, with responsibility to monitor compliance in the Three Functions.
The Company should undertake a
review of the composition of the
boards of directors of subsidiaries
and the conduct and reporting of
meetings.
g The composition, conduct and reporting of the board of directors of subsidiaries
is governed by the updated Group Accounting Manual.
Prepare a bespoke directors’
duties manual for directors’ of
Kingspan subsidiaries.
g A director’s duties manual has been issued together with training on the same
being rolled out in Q1 2022.
g The GHC and the Head of Internal Audit & Compliance report regularly to the
Audit & Compliance Committee – with the role of the Group Internal Audit
function being expanded to incorporate product compliance.
g The composition of the board of directors of the subsidiaries will be reviewed
annually.
g Training on the manual will form part of every new statutory director’s induction
on appointment.
Kingspan Group plc Annual Report & Financial Statements 2021
Report of the Nominations & Governance Committee
