NCC Group has a zero-tolerance position in relation to bribery, wherever and in whatever form that it may be encountered. Our position is communicated internally with all colleagues, and anyone who performs services for or on behalf of NCC Group or any of its subsidiaries. The NCC Group Anti-bribery and Corruption Policy sets out the requirements.
Responsibility
NCC Group’s Compliance department, overseen by the Director of Risk and Governance is responsible for maintaining and monitoring the Anti-Bribery and Corruption Policy.
The NCC Group Executive Committee members are individually responsible for ensuring that appropriate processes are implemented in their part of the business to meet the requirements of the Policy.
Every single person acting on or behalf of NCC Group is responsible for living the values and principles outlined in the Policy and undertaking training to ensure they can meet our high standards outlined in the requirements.
Risk assessment
Assessing the risk of bribery and fraud is an integral part of our general risk management and is documented on our NCC Group risk register. Risk identification pinpoints the specific areas in which the Group, our colleagues, directors, and associate persons could be exposed to bribery and corruption risks. This allows us to evaluate and do everything practical to mitigate these risks.
Monitoring and review
We maintain an effective system of internal control and monitoring of our transactions. If a bribery or corruption risk is identified and highlighted via the risk assessment process, procedures are developed within a monitoring programme to help mitigate these risks on an ongoing basis. Additionally, financial controls and procedures are in place to detect inappropriate or potentially corrupt expense claims.
Training and communication
Anti-bribery and corruption training is mandated for all new colleagues and contractors, with annual refresher training conducted. Each colleague has an individual record of training completed in our human resource management system – Workday, which enables us to report on and follow-up any non-completion (for colleagues who may be on long-term leave or on long-term off network customer assignments at the time of the training).