|- Appointed Ethical and Compliance Manager and established global committee.|
|- All Employees and Directors completed Anti-Bribery and Corruption training.|
|- Modern Slavery & Human Trafficking Policy implemented.|
|- Modern Slavery & Human Trafficking Questionnaire Implemented for new partners and suppliers.|
|- Code of Conduct comprehensive review and bench-marking exercise.|
|- Code of Conduct includes Group Compliance Policies and schedule for each region where we operate, setting out the local laws and penalties, as well as local rules around gifts and hospitality.|
Mainstream's business results must always be achieved ethically and legally and the Group’s comprehensive Code of Conduct clearly defines the standards and expectations set for all colleagues. All employees, including Board Directors, sign an annual statement confirming their acceptance and observance of it. The Code is published on our website and sets out what we perceive as acceptable behaviour for employees, agents, partners and all those acting on behalf of Mainstream. The Code of Conduct was substantively reviewed in 2019 and revision includes a specific anti-bribery and corruption schedule for each region where we operate, setting out the local laws and penalties, as well as local rules around gifts and hospitality. The revised Code of Conduct includes our group compliance
policies and was adopted by the board in September 2019.
The polices included in the Code are around Fraud, Bribery, Corruption, Lobbying and much more to help inform and direct employee behaviour. We also provide a whistleblowing facility for employees with concerns to report these anonymously to 'SafeCall'.
In 2019, a Global Ethics and Compliance Committee was established which is tasked with promoting ethical standards and compliance awareness throughout the company. The committee is comprised of members from each of our regions, who serve as a local point of contact for any ethical or compliance related issues, as well as a guide on aspects of local culture which can conflict with Mainstream standards.
Mainstream operates within the (UK) Modern Slavery Act 2015 and our Modern Slavery Statement is published on our website. Our Code of Conduct is substantively in alignment with the aims and the spirit of this Act. As a company, we abhor human trafficking and modern slavery in all its forms and guises. We are committed to actively ensuring that there is no room for such inhumane conduct in our own business and that of our partners, contractors and associates. In 2019, we required potential new partners and key suppliers to complete Modern Slavery and Human Trafficking Questionnaires. These questionnaires also require that anti-bribery and corruption risk measures are in place. Where we feel the results are not robust, we may insist that Mainstream’s anti-bribery training is undertaken, which is especially relevant for prospective partnership.