Putting our Business Conduct and Ethics commitments into action across every ERM office and activity, every day, depends upon the involvement and awareness of individual employees and the leadership of every manager and Partner.
We have established several mandatory online training courses on ethics and risk management, which are delivered through the ERM Academy.
In FY14, we strengthened and expanded our Business Conduct and Ethics training program by updating the international bribery and corruption module to address international contracting issues, both with clients and subcontractors. We also developed and introduced an additional, specific training module on trade sanction and anti-money laundering compliance.
Our improved systems and processes enable us to respond more quickly to changes in regulations in the countries where we operate. For example, Brazil made substantial changes to its anti-bribery/corruption legal framework as part of the implementation of the Brazil Clean Companies Act this year. Prior to the effective date of the new law, we were able to introduce an ERM Academy training module for employees members connected with our Brazil operations.
Given the importance we place on such issues, we introduced more rigorous mandatory training requirements for new starters in both Business Conduct and Ethics and H&S in FY14. Our integrated and improved systems now enable us to track training progress on a weekly basis and communicate this internally to work toward our goal of 100 percent compliance.
During the last year, we specified that within 90 days of joining the company, all new employees must participate in an interactive web-based training series that covers international bribery and corruption, insider trading, practical ethics and the regulatory requirements specified by the U.K. Bribery Act. In FY14, we achieved a 92 percent compliance rate, an improvement from 85 percent in FY13. Reaching our target remains a priority for FY15.
Anti-Bribery and Corruption
ERM supports governmental and societal efforts to combat bribery and corruption. Our commitment, which is detailed in our Code of Conduct and supporting policies, is fundamental to how we operate and is embedded into our key systems and programs.
In FY14, we continued to focus our efforts on management systems and training for preventing bribery and corruption in our global activities. For more on the location of anti-bribery and corruption related disclosures in this report, see our UNGC Content Index, which includes details of our reporting on Principle 10 — Anti-Corruption.
As a global business that has worked in more than 160 countries in the past three years, we recognize our responsibility to support and respect the protection of internationally proclaimed human rights, as defined by the United Nations Guiding Principles on Business and Human Rights.
ERM supports international efforts against child and forced labor and has a specific Child or Forced Labor Policy. Our policy prohibits the use of child or forced labor or involvement by ERM with entities that support prohibited labor practices, including slavery, bonded labor or debt-bondage and other types of coercion or corruption. As our Contractor Management Program (CMP) is implemented progressively around the world, we can now take a more consistent approach for mandating contractors and suppliers to adhere to this requirement and track their compliance.
In addition to making this commitment across our own business, we take the opportunity to work with our clients across the world to improve their practices. As part of our service offerings, ERM has a Human Rights Working Group that focuses on providing advice to our clients on their human rights risks and obligations. Our social and health consulting services teams work with clients around the world to identify and provide advice on labor, supply chain management, land access and indigenous rights issues.
ERM is also involved in global initiatives to advance the adoption of the UN Guiding Principles by the business community. During 2013, we were a Co-Chair of the Basic Needs and Rights Working Group in the World Business Council for Sustainable Development (WBCSD) Action2020 platform, working to develop a number of business solutions, including responsible employment practices, developing land use criteria in supply chains and operationalizing the Guiding Principles.
The details of our approach to human rights are included in the United Nations Global Compact (UNGC) Content Index.
Respect for Human Rights in Papua New Guinea
There is a growing extractives industry in Papua New Guinea (PNG), located in the Asia Pacific region, with a number of petroleum projects in the exploration or operational phases. PNG is a complex and challenging operating environment, in part due to historical environmental damage, ethnic tensions, evidence of poor treatment of women, alleged human rights violations and other social and political factors.
ERM has worked with a number of clients in PNG to understand the local operating context, identify and assess potential risks and impacts, and develop strategies to minimize potential negative impacts (e.g., environmental damage), maximize benefits (e.g., local employment opportunities), and minimize potential risks (e.g., delays in government approvals).
As part of our ongoing commitment to thought leadership, representatives from ERM shared their experience working in the oil and gas sector in PNG at the 2014 Society of Petroleum Engineers (SPE) HSE Conference in Long Beach, California. The focus was on sharing lessons learned from past experience in an effort to influence and improve further performance in the oil and gas sector.
David Snashall, Sydney, Australia
Key Role in WBCSD
I am currently the Asia Pacific Commercial Director, having worked in many different roles during my 25 years with ERM. I also serve as ERM's Liaison Delegate with the WBCSD and, in 2013, was Co-Chair of the Basic Needs and Rights Working Group as part of the Action2020 platform.
ERM has hosted and participated in a range of meetings and forums in the past year as part of its commitment to Basic Needs and Rights. Issues addressed including adoption of the United Nations Principles on Business and Human Rights, sustainable land tenure in supply chains and responsible employment strategies.
My expertise in advising clients on economic, social and environmental issues, both at the strategic and operational levels, has allowed me to work with companies developing unique solutions that bring benefits both to their business and to the host communities. This reflects an increasingly important aspect of our work with clients, helping them to understand the social context of their operations.