Open door policy

At Bodycote, we are committed to maintaining an open and fair culture, conducting our business with honesty and integrity. We expect all employees and third parties to maintain high standards in accordance with our Code of Conduct and Supplier Code. However, we recognise that all organisations face the risk of things going wrong from time-to-time, or of unknowingly becoming associated with unethical conduct.

Anyone who is aware of or has a reason to believe that there may have been a potential violation of the Group’s Code of Conduct, the Supplier Code, policies, standards, or applicable laws is expected to report their concerns.  This principle does not just apply to employees. We also encourage anyone who is involved with or who engages with Bodycote, including casual and agency workers, consultants, contractors, customers, or suppliers, to report any such concerns.

Our Open Door Policy sets out the key processes for any individual to report perceived improper, unethical, illegal or inappropriate conduct in a confidential manner. This could include (but is not limited to):

• criminal activity, including the suspicion of a criminal offence;
• failure to comply with legal or regulatory obligations;
• threat or serious damage to the public interest;
• danger to health and safety or damage to the environment;
• bribery, corruption or anti-competitive behaviour;
• fraud or mismanagement, or inaccurate reporting, including, without limit, in respect of financial matters;
• the facilitation of tax evasion;
• conduct likely to damage our reputation or financial wellbeing;
• unauthorised disclosure of confidential information;
• discrimination, harassment, or abuse;
• modern slavery, human trafficking, forced labour or exploitation in any part of the Group’s operations or supply chain;
• a breach of the Group’s Code of Conduct or the Supplier Code or any other Group policies; and
• deliberate concealment of any of the above.

Reporting concerns

There are a number of ways to report a concern:

• For employees, the first point of contact should be to speak directly to their line manager or supervisor. If this is not practical, then concerns should be raised with a senior manager, the HR team, Company Secretary or the Legal team, as long as they feel comfortable doing so.
• Alternatively, contact should be made using the Company’s Open Door Line facility. This is available to all employees and third parties and is an outsourced, secure and confidential reporting system that provides a safe method to report concerns. The service is run by an external  third party and therefore reports can be submitted anonymously if so wished.
• This ODL service, which is available 24 hours 7 days a week, can be accessed by sending an e-mail to [email protected] or alternatively, via telephone.

This ODL policy encourages individuals to identify themselves when making disclosures.  However, we recognise that in certain circumstances the individual may prefer to make an anonymous disclosure, and this is possible for the ODL facility.

Once a concern has been raised, reports are saved to the secure server operated by the ODL facility.  Reports are made available to specific individuals within the Company, who are authorised to received and assess them.  All Open Door Line reports are held in strict confidence.

All incidents reported in good faith will be reviewed and/or investigated and all actions recorded. We will ensure that no individual will be disciplined or suffer any recrimination for raising a legitimate concern, even if it proves to be mistaken.  However, any employee whose disclosure is found to be deliberately false or made with malicious intent will be subject to disciplinary procedures. In addition, any external third party whose disclosure is not made in good faith and is found to be deliberately false or made with malicious intent may risk termination of the business relationship with Bodycote.

All reports made through the ODL together with the outcome of the investigations are reported to the Bodycote Board.