ESG Report 2022 single pages web - Flipbook - Page 58
Governance
OUR GOVERNANCE
We are strongly committed to upholding the highest business standards and
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
We take a zero-tolerance approach to bribery and
corruption, financial 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 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 FY22 was 98% – the 2% is made up of new starters and
colleagues on long term leave of absence.
We believe that, with our exacting policies and procedures
and controls, together with the nature of our business, the
risk of the Group encountering financial, criminal, or other
criminal activity 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 specific policies in place which ensure that
professional integrity is adhered to covering the following
subjects – anti-money laundering, anti-bribery and
corruption, financial crime and fraud, modern slavery and
human trafficking, sanctions and whistleblowing, amongst
others.
Key policies published on our website include:
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Code of Conduct
Anti-Bribery and Corruption Policy
Corporate Sustainability 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 Trafficking Policy
Supplier Code of Conduct
Whistleblowing Policy
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 conflicts of interest.
RWS maintains a formal process whereby all members
of the Board, Executive Team, Senior Leadership Team,
office managers and any other colleagues in a decisionmaking role are required to sign a declaration on an
annual basis of compliance with the Code of Conduct.
This includes notification of any conflicts of interest known
to them. Training on conflict-of-interest matters has been
implemented and is available on the RWS training portal,
MyLX.
RWS works with external law firms and consultants to keep
up-to-date globally on any changes to ethical standards to
ensure that any new legal requirements are reflected in its
policies, such as new financial sanctions against Russia to
address the Russian-Ukraine conflict in 2022.
All confidential 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 regulations. RWS also adheres to
the retention and destruction of data as required through
the process.
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RWS — ESG Report 2022
GOVERNANCE
