“Sound, well-understood risk and control processes
are critical to Inizio’s sustainability and fundamental
to our internal and external governance”
Ed Gallagher,
Group Head of Risk & Compliance
Business ethics continued
Ask Yourself, Speak Up,
and raising awareness
We trust our people to consider
unusual circumstances first, eitherby
themselves or with their colleagues.
Our Code provides them with an
“AskYourself” methodology to help.
Moreover, our people have a
responsibility to Speak Up if they
suspect wrongdoing or know
thatsomeone has broken a legal,
regulatory, or other Code obligation, or
have a critical concern regarding the
business’s conduct in its operations or
in its business relationships, including
but not limited to bribery, corruption,
or anti-competitive practices.
When our people Speak Up, we
ListenUp: The confidential reporting
process allows our people to make a
confidential report 24/7 via an online
platform or by telephone. A dedicated
and independent team reviews such
reports, treats each one seriously,
respects and protects the reporter’s
confidentiality, and investigates
thoroughly and professionally. We
prohibit any form of retaliation that
results in disciplinary measures up
toand including dismissal.
The Audit Committee monitors the
number of Speak Up reports and is
provided with high-level summaries.
Where a report could have a
significant impact on the business
orits reputation, it would be
escalated to the Executive Council
and/or the Board. During 2023, no
critical concerns arising from the
Speak Up reporting procedure
werereported to the Board.
Our compliance training and
communications program is
theprimary means by which
weremind employees of our
Code,Commitments, policies,
andprocedures. In 2023, there
werenosignificant instances
ofnon-compliance with laws
andregulations.
Risk assessments
Changes to our businesses, operations,
or our commercial environment
require us to undertake periodic
riskassessments. We have a risk
identification and mitigation process
which facilitates ongoing assessment.
Some of the risks we identify at a
local level are ultimately recorded in
our Group Risk Register, particularly
those which could affect our ability
to achieve our strategic objectives.
Our Board determines which risks
are most relevant to us and monitors
how effectively we mitigate them.
We identified sustainability risk as
aGroup principal risk in 2022 and
itremains so in 2023. Further details
can be found in our 2023 Annual Report.
Risk assessments also help
usidentify where our internal
financial and non-financial audit
resources should focus their
activities. Whether we’re on our
continuous improvement journey
ormeeting the audit demands
ofclients and stakeholders, we
always strive to beaudit ready.
24/7
confidential reporting
processvia an online
platformor by telephone.
Inizio Sustainability Report 202336