Imerys supports human rights as defined in the Universal Declaration of Human Rights and requires that they are respected in its operations worldwide. The Group verifies that these principles are observed through audit assignments carried out by internal auditors.
The Imerys Code of Business Conduct and Ethics, published in 2006, summarizes the principles that the Group expects of all of its employees, and the contractors, suppliers and other partners with whom it has forged close relations. The Code is regularly amended to take into account the geographic expansion of the Group’s activities, developments in its regulatory framework and compliance with the best practices of comparable corporations. It is designed to lead everyone, in his or her daily work, to behave in accordance with local legislation and observe the principles of responsibility, integrity, fairness and openness that are the Group’s values.
Published in 10 languages, the Code of Business Conduct and Ethics is available to anyone from Imerys web and intranet sites. It is presented in internal seminars and regularly covered in the Group’s magazine. In addition, online training is regularly followed by all employees in the United States and at least once by all of the other main managers and employees of the Group. As of the end of 2013, approximately 3,000 employees have been trained in the Group’s Code of Business Conduct and Ethics. The Group has also put in place a process of electronic certification in order to communicate internal control rules and policies. Managers and other relevant employees must certify that they have read the communication and that they have committed to ensure that internal controls are implemented in the areas under their responsibility. In 2011, this certification process was used to communicate the Group’s management authority rules which define the allocation of internal responsibilities and the approval workflow for its most important decisions and transactions. In 2012 and 2013, this process was used to issue detailed communications on the risks of fraud.
Since 2010, Imerys has established a simplified annual reporting process that enables Group activity managers to report any breaches of the Code of Business Conduct and Ethics, particularly fraud, corruption, or violations of human rights. In the context of this process, the Group Internal Audit and Control Director, the Vice President of Human Resources and the Group General Counsel are informed of any reported violation. After reviewing the results, these individuals determine whether there is a need for further investigation and potential grievance actions.
Imerys complies with the Universal Declaration of Human Rights and monitors the risk associated with the Group’s swift growth in emerging countries. The Group has placed special importance awareness and prevention of child labor since 2009: Operations managers on all Imerys operations in zones where vigilance is particularly recommended by indices such as FTSE4Good are trained in the relevant regulations. Application of the Child Labor protocol is systematically checked in the internal audits performed in those countries. In 2012, five suppliers operating in zones determined to be sensitive in terms of child labor underwent an audit to evaluate their compliance with international standards. In 2013, the Group conducted supplier screening based on location and spending at the business divisional level. A formal supplier query and confirmation letter for compliance with the ILO Conventions on Child Labor and Force Labor was used to engage the suppliers that comprised more than 10% of the divisional spending and that were located in the “Countries of Concern”. In 2014, the threshold will be lowered from “10%” to “5%” of the divisional spending.
|2013 Objectives||2013 Performance|
Ensure compliance to international standards related to Child labor
We have placed special importance on the prevention of child labor since 2009: operations managers on all Imerys sites in zones where vigilance is particularly recommended by indices such as FTSE4Good have been trained in the relevant regulations. In parallel, the biggest suppliers of those sites have been asked to certify that they comply with the International Labour Organization convention on child labor. Finally, application of the Child Labor protocol is systematically checked in the internal audit assignments performed in those countries (9 sites audited in 2011).
Engage suppliers on Group's Ethical Principals
More generally, the Group intends to involve its suppliers in its Sustainable Development process, particularly through its internal qualification system. The system was set up in 2008 and is designed to keep supply risks to a minimum and to qualify suppliers. Supplier self-appraisal was expanded in 2011 to a scope representing 20% of the Group’s purchases (compared with 15% in 2010).
Download the last Code of Business Conduct and Ethics