At Norcros, sustainability is at the centre of our strategy. We aim to manage our societal and environmental impact by conducting business to the highest standards as well as using resources more efficiently.
We have a history of environmental and social leadership. We pride ourselves on reducing our operational environmental impact through energy saving, recycling and waste management schemes. We design and supply product that not only create commercial returns but also generate savings for customers on energy bills, carbon footprint, water consumption and waste. We also play an active role in our communities.
Going forward, as our customers, staff, other stakeholders and the communities in which we work place increasing importance on environmental, social and governance (ESG) issues, we will continue to develop our sustainability strategy. In the remainder of 2022, we will continue to work on our ESG plan, which will capture our existing ESG initiatives, a set of new activities and an overarching framework, through which we will give further consideration to ESG metrics and targets. We will continue to make a positive impact and difference to our customers, communities and employees.
continue to deliver the programme of initiatives we are undertaking across our business units to support their staff and their communities;
continue to focus on sustainability as part of our new product development programmes;
build on the work we have done with the Carbon Trust to develop Carbon Management Plans across the Group; and
develop our ESG plan that prioritises our effort on the ESG issues most material to Norcros and considers the right metrics and targets so that we can measure, continuously improve and report on our ESG performance.
Care for the environment and sustainability are at the forefront of all our activities and products. The Board recognises that the Group’s activities do have an impact on the environment. We seek to manufacture all our products in a sustainable way and many of the products themselves contain environmental features – for example, our taps and showers encourage water and energy saving and our tiles and adhesives use recycled products where appropriate.
Norcros is committed to minimising this impact by continually improving its efficiency in terms of energy, water and material consumption. One particular area of focus across the Group has been taking steps to reduce plastics, particularly packaging. We also have rigorous programmes to seek to ensure compliance with all environmental legislation and requirements relating to our operations and our products.
The Group aims to minimise its carbon footprint. Whilst there has been a significant decrease in overall emissions compared to last year, this has to be considered in the context of the impacts of the COVID-19 pandemic, which reduced the Group’s energy consumption markedly, particularly in the early months of the year. In the context of the overall growth in the activities of the Group, relative to revenue, emissions have fallen by 24.9% year on year. Examples of the principal measures taken to improve energy efficiency are given on this page, and also include the introduction of electric vehicles and the promotion of the energy-saving benefits of our products.
For the last 20 years, Johnson Tiles has had a continuous “green policy” with pioneering initiatives. Every aspect of the business is subject to a strict environmental policy, which also includes its suppliers.
Each year, Johnson Tiles recycles 14,000 tonnes of ceramic waste, grinding it and then adding it to the standard ceramic materials, to create a new tile body. Recycling this waste saves 16,800m3 at landfill, and an estimated 235,000 miles of HGV journeys per year.
Second-hand pallets are used and if damaged, they are repaired wherever possible. Pallets beyond repair are sent for chipping and recycling. This saves 1,250 tonnes of virgin timber, approx. 10,000 trees, per year.
Plastic shrink-wrap has been replaced with recyclable corrugated card and the polypropylene strapping used for production boxes has been substituted with a new sugar cane product for pallet stabilisation.
Energy and water
By re-using 32,000m3 of water per year (30% of the total factory usage) and removing water from another part of the production process, Johnson Tiles can save an additional 2,100m3 of water per year.
In 2001, the new single fired production plant was re-sited, dropping the annual energy consumption from 195 million kWh of energy to 130 million kWh, while raising production from 53,000 tonnes of ceramic tiles in 2001 to 56,000 tonnes by 2019. This is an energy saving of 35% per tonne of ceramic tile, equating to 68 million kWh per year. By speeding up its kilns, using automatic light sensors and re-using kiln exit heat, consumption has been cut even further, saving around 9% of gas.
Johnson Tiles is the only UK tile manufacturer to use the most energy-efficient production process of a single fire.
Following a successful period of activities to reduce its impact on the environment, Triton Showers has committed to a number of new, bold goals.
The ambitious targets include a further reduction in gas and electricity use by 5%, as well as a 20% reduction in packaging.A concerted effort to reduce water usage by 7% has led to the introduction of two new water meters to help identify where the majority of water is being consumed. With production and the lab facility being singled out as key users, plans are now afoot to conserve the resource as much as possible.
Further developments to maintain its zero waste to landfill status has led to the purchase of a brand-new shrink wrap machine in 2019 which provides a 3,180kg reduction in material used, thanks to the equipment being able to stretch the existing shrink film two and half times more than the original.
Staying with packaging, Triton has pledged to minimise its usage by 20%. As a result, new tote boxes have been introduced to eliminate the repacking of items internally.Not resting on its laurels, Triton has challenged suppliers to remove unnecessary extras, such as tissue paper, bubblewrap and strapping used on the outer boxes. As a result, two out of three suppliers have invested in re-useable plastic containers, which has meant that Triton has seen significant reductions in the amount of cardboard being received from UK suppliers.
The problem with the introduction of the new 4 in 1 range, a rapid setting,antibacterial grout for walls and floors, Norcros Adhesives has seen a significant growth in demand for this product.The product has versatility with 15 different colours and the new efflorescence-free formulation helps to reduce the migration of salt to the surface of the grout.
The solution Norcros Adhesives has seen a programme of consistent investment in its manufacturing capacity with efficiency and environmental benefits. The latest being the installation of new "Form, Fill & Seal” equipment, to enhance both capacity and speed, as well as the new “blown air” in feed, which transports the powdered materials throughout the production line.It has also seen the introduction of a new ERP and warehouse system, in addition to the new packaging equipment.
The result The latest investment has resulted in new efficiencies and improvements in the production process. The new equipment is three times faster and brings with it a number of benefits,i.e. there is no requirement to produce labels for each pouch,saving both paper and operative time, and the machines enable the use of a new high quality bag, which exceeds the standard industry drop-test requirements keeping customers’ displays clean and free of grout dust.
Triton achieved the Carbon Trust Standard for Carbon in 2021 and Croydex achieved the new Carbon Trust Route to Net Zero Standard (Taking Action) in 2022 based on the progress it has made with carbon management and emissions. At Triton, some of the key carbon management initiatives have included installing LED lighting throughout 95% of its facility, reducing water usage by 38%, introducing electric vehicle charge points in the car park and a cycle to work scheme and using 100% recycled paper.
The way our products are sourced has a significant impact on our environmental and social sustainability. We are committed to encouraging our suppliers to minimise their environmental impact and we also expect all our suppliers to conduct themselves to standards equivalent with the Code of Ethics and Standards of Business Conduct. Environmental standards at Norcros Adhesives have been maintained in the year with the continued “Gold Standard” accreditation from the Supply Chain Sustainability School (which is partnered with the housebuilder Barratt).
Norcros does not accept and will not tolerate the use of child labour or forced labour (i.e. modern slavery) anywhere in its own business or its supply chain. The Company has issued a public statement to this effect, which can be found on its website at https://www.norcros.com/investor-centre/other-disclosures/. We also encourage our direct suppliers to promote human rights throughout the supply chain. Our supplier assessments include evaluation of policies and practices in this area.
Norcros is committed to designing, manufacturing and supplying products that are reliable and safe to use. All our products are tested to ensure that they meet safety requirements in the countries in which they are sold and information about safe use and disposal of Norcros products is provided through warning labels, manuals and other documentation where this is appropriate. The majority of our business units, covering 95% of turnover, are externally certified to the Quality Management ISO 9001 standard.
The Group is also committed to minimising the environmental impact of its products and services wherever possible. We have provided our customers with some environmentally beneficial products that are energy efficient, easily recyclable and durable to increase their longevity. To be a sustainable business, we need to continue to develop innovative solutions and we are always developing new products and technologies that align to customer and market demands as well as investing in research and development to stay ahead of our competitors. The impacts from climate change and the accelerated commitment to environmental legislation from governments, such as net zero by 2050 in the UK, has created opportunities for Norcros to capitalise on consumer and market demands for products that help customers reduce their environmental impacts. The Group offers a number of innovative products that already provide customers with solutions to reduce their carbon emissions while also saving money.
Being “eco-friendly” means living in a way that is not harmful to the environment. We have seen an increase in sales of reusable coffee cups, plastic straws being banned in bars and restaurants and brands like Evian promising to manufacture packaging from recycled materials.
For Abode, this presents an opportunity to focus on the solutions that aid the fight against single-use plastics and underlie the development of eco-friendly products such as water filter taps with Puria and Swich.
The Puria tap is a slimline and cost-effective water filter tap giving consumers more design choice and a more inviting price base, encouraging upgrade from a standard tap to a filtered water tap, and replacing bottled water with unlimited fresh, filtered drinking water on demand.
The innovative Abode Swich water filter diverter can transform any tap, new or old, into a filtered water tap enabling households to live more sustainably by reducing their use of plastic water bottles.
Abode’s 4 in 1 range of taps provide hot and cold domestic water, steaming hot water on demand, and fresh filtered water meaning you can make a start to eliminate the use of single-use plastic in the home. Its Filter Recycle Scheme adds another advantage to the list, as the filter and the boiler can be recycled free of charge to the consumer. Abode’s recycle partner will oversee the separation of each component part with the plastic being ground down and the internal resin brought back to life, ready to be reused.
Abode’s aim is to reduce to amount of plastic waste going to landfill and not harming the environment is a key consideration for the brand. At the 2021 Society of British International Design (SBID) awards ceremony, Adobe’s Swich was recognised as an outstanding example of technical innovation, aesthetic creativity and fit-for-purpose functionality. The versatility and ease of Swich is an industry game changer for the modern home. With a revolutionary design, via a simple turn of the control handle, Swich can transform a new or existing kitchen tap into a water filter tap, removing the need to have bottled water in the house.
Workforce engagement We engage with employees throughout the Group through our divisional structure. This ensures that all communication and engagement are appropriate to each business and location. We have a very effective approach to cascading information about business changes, key issues and business performance updates through the organisation using a variety of channels including the line management structure, emails and Microsoft Teams calls. Our engagement methods were tested through 2021 as we successfully implemented new policies due to the COVID-19 pandemic and we engaged with more staff who were working remotely.
The Board stays in touch with employees via regular meetings with divisional management and site visits to its operations, as well as regular reports on employee matters. This area of focus is led by Alison Littley as the designated Non-executive Director for workforce engagement, together with the executive team. In the course of the year Alison Littley on behalf of the Board had direct engagement with representative groups from three of our businesses, and more such meetings have and will take place in the current financial year.
Talent and career management
All of our businesses have staff training programmes that are suitable for the development of appropriate technical and people skills. We are committed to education and career development, and for those in senior leadership roles, coaching and mentoring have been offered rather than attending courses or other developmental activities. The coaching is focused on the individual’s unique work challenges and opportunities as well as on the individual’s personal style and behaviour.
Employees are encouraged to be involved in the Company’s performance through employee share schemes, and other means of incentivisation and reward.
Diversity and inclusiveness
We believe that a diverse and inclusive organisation promotes greater innovation and more effective decision making. Our Code of Ethics and Standards of Business Conduct sets out our overall approach, in which all employees are encouraged to advance within the Group and have equal opportunities to do so subject to their possessing the necessary skills and aptitudes. The Board is committed to gender equality and is satisfied that there is no pay inequality at Norcros, where men and women are paid equally for equal work.
Norcros is committed to not discriminating in the employment of any person due to race, colour, national origin, family responsibility, trade union membership, sex or gender identity, sexual orientation, age, religion or belief, disability status or any other category protected under applicable legislation in any jurisdiction in which it operates. This commitment applies to all personnel actions including hiring, promotion, termination, transfer and compensation/benefits. We maintain external independent whistleblowing reporting lines where employees can report any concerns they may have in respect of discrimination confidentially and anonymously should they wish to.
In the event of existing employees becoming disabled, every effort is made to ensure that their employment with the Group continues, and that appropriate training is arranged. It is the policy of the Group that the training, career development and promotion of disabled persons should, as far as possible, be identical to that of an able-bodied person.
Gender of Directors and employees1
For the third time, Merlyn’s customer care team was awarded the highly coveted Team of the Year at the Irish Customer Contact & Shared Services Awards 2020. The company also won the National Buying Group (NBG) Supplier of the Year in the Plumbing, Heating & Showrooms category for the third year in a row.
The awards recognise the accomplishments of key individuals, team and brands within the contact centre industry, in sales, customer service and technical support.
“Our people are key to our success as a business. Merlyn staff have won praise for their focus on its customers throughout the pandemic, achieving high customer satisfaction levels, despite managing double the contact volumes.”
Technology is constantly changing, not least in the plumbing industry, with new trends such as the digital shower revolution seeing more and more installers returning to the classroom to get up to speed.
In 2019, Triton Showers trained more than 100 installers at its specialist facility in Warwickshire and visited a further 500 at colleges across the UK. Triton provides two-day courses covering electric, mixer and power showers.
Paul Rowley, Approvals & Training Manager, said: “In order to ensure all installers are able to access valuable resources, we want to be able to share information in a number of different ways. This includes producing video content and advice led pieces in the trade press and communicating in person. “We have found that the most effective way to build knowledge is to meet face to face with trade professionals.
This is why we place such importance on attending key exhibitions like Installer 2019. It gives us the chance to meet new people so we can boost awareness of our products and key technology. During such events, we can gain a better understanding of where plumbers need more support. “Our training doesn’t stop with qualified professionals though; helping apprentices to learn the plumbing essentials is also a key focus. We work closely with colleges across the UK to help educate the next generation, giving them hands-on practical experience.”
Almost half of UK women don’t regularly check for early signs of breast cancer, even though we know that early detection can make all the difference to the fight against this disease. Merlyn’s campaign with the Pink Ribbon Foundation urges women to use precious time behind the shower screen to check for early warning signs. In fact it is the most common place that women pick up on any changes to their bodies. That’s why the partnership with Merlyn, which was launched back in 2019 to support the Pink Ribbon Foundation, is such a vital one.
Merlyn is currently supporting the #WalkAMileInMay campaign with Merlyn donating £3,100 to get each employee started by sponsoring one mile per day for them. Employees and the local community are getting involved, with Lisa Allen from the Pink Ribbon Foundation arriving at Merlyn’s offices in Kilkenny to kick off the campaign.
Norcros SA is proud to participate in the ground-breaking, life-changing Youth Employment Service (YES). YES is a joint project between the private sector and government to assist young, previously disadvantaged South Africans to gain work experience through meaningful employment placements.
Norcros SA, through a number of employment and outreach programmes, already recognises and supports the local community; therefore, its engagement with the YES programme fits well with this framework and will see 65 young people employed by Norcros SA for a period of 12 months across all four of its businesses.
Our commitment to the society in which we operate is deep. Every Group business has programmes of social engagement, including many charitable activities, and will have a positive impact on the local communities in which they operate. We empower our businesses to support local charities and community projects, and provide local employment. Given our decentralised structure, business units in the Group are encouraged to become involved in and support local initiatives where possible. The Executive Management of the Group supports this commitment to our society and reviews each business’ activities monthly.
4GoodPPE, the COVID-19 relief charity, creates environmentally friendly eye visors using biodegradable acetate and MDF frames, which are then distributed to healthcare workers, shops and groups within the local community.
Croydex understands the importance of giving back to the local community and wanted to make sure it assisted wherever it could. It has been able to provide the charity with re-usable packaging to help it make and distribute boxes of visors to those struggling to obtain PPE.
Triton has donated much needed supplies to The Trussell Trust Nuneaton Foodbank, marking the beginning of a long-term commitment to supporting families in its local community.
The Trussell Trust has been running since 2013, supporting a nationwide network of food banks to provide emergency food for people dealing with poverty throughout the UK.
Triton’s initiative, which was developed by its employees, involved the team coming together to donate more than 226kg of food, toiletries and toys.
As part of its commitment to support the government’s SAFE initiative, Tile Africa, a division of Norcros South Africa, over the last two years, has been working to upgrade school bathroom facilities for students at needy schools.Most recently Tile Africa assisted Nokwazi Junior Secondary School with new toilets for its learners. This is the first of five schools that the company has pledged to assist with providing bathroom facilities.
The Nokwazi School had no pre-existing bathrooms for its approximately 350 students. Located in rural Ladyfrere, Eastern Cape, the project presented some unique challenges, foremost being the fact there was no running water at the school. A two-fold approach was applied to solve this.Once construction was complete, Enviro-loo were contracted to deliver a sustainable waste management solution, the urinals and toilets operated on dry sanitation systems using sun and wind to transform human waste into a safe, stabilised material without the use of water, electricity or chemicals. For the basins, Tile Africa drilled a borehole in order to provide running water for the children.House of Plumbing, also a division of Norcros South Africa, supplied resin-based basins for the project, which are extremely strong and will not crack or chip, as traditional porcelainware can.
Norcros SA noticed that there was no formal kitchen space for school meals, so the team decided to go the extra mile and convert a storage container into a kitchen, with running water piped into the sinks from the new borehole. It trained community members in Ladyfrere on how to tile, in order to uplift their skills, and to enable future maintenance and repairs of the facilities. A supply of spare tiles and adhesives were left at the school for this purpose. Finally, a cleaner was also hired for the first three months and the division plans to return to the school by the end of the year to provide toiletries for the students.
The Donna Louise Hospice for children and young people provides a lifeline to hundreds of families across Staffordshire and South Cheshire who are facing every parent’s worst nightmare, the heartbreaking knowledge that they will almost certainly outlive their child.
April saw the completion of a striking vibrant blue butterfly sculpture in Trentham Gardens, Stoke on Trent, crafted by Johnson Tiles and Wade Ceramics.
Each butterfly is unique and has been crafted by Johnson Tiles, also the maker of the poppies for the internationally acclaimed Tower of London art installation. The butterflies were then glazed and finished by Wade Ceramics in Stoke on Trent. The project, which featured a total of 5,000 ceramic butterflies, was opened in May 2019 with the help of more than 30 businesses, which pledged their support.
The inaugural Vado Velo has raised a staggering £75,000 for charity after members of the KBB industry embarked on a gruelling 240-mile cycle ride through Northern France.Raising money for the African Children’s Fund (ACF), 38cyclists were challenged to a three-day voyage from Calais to Reims, via Arras and St Quentin. All participants were tasked with raising up to £2,250 each, with all funds to be donated to the ACF’s Kenyan Schools Programme to aid six schools located around Thika, a small town near Nairobi, Kenya.Departing Calais on 6 September 2019, cyclists travelled approximately 80 miles per day for three days, experiencing steep inclines, multiple punctures and various tyre replacements. To compensate for such arduous challenges, cyclists were treated to breath-taking landscapes, cultural land marks and well-deserved hospitality, courtesy of CCDGlobal Events.
Aiming initially to raise £55,000 for the ACF, the Vado Velo smashed its target sum, leaving the event organisers from the Vado sales team delighted at the event’s debut success.
Merlyn, the UK’s leading shower enclosure company, is delighted to be working with renowned breast cancer charity The Pink Ribbon Foundation in a partnership set to raise funds and awareness that will ultimately save lives.Keen to harness the positive power that a daily shower can have in our lives, Merlyn is initiating the campaign called “#justareminder…”, a simple, stickered prompt of the instantly recognisable Pink Ribbon symbol displayed on enclosures, accompanied by point of sale material and information in Merlyn’s bid to get the message across. Merlyn are also supporting The Pink Ribbon Foundation financially by organising and taking part in a series of fundraising events.
Our colleagues are fundamental to the successful delivery of our strategy and, as such, Norcros SA has partnered with the Gordon Institute of Business Science (GIBS) on a programme for management development for staff across the different divisions in South Africa. The aim of this 12-month programme is to develop colleagues so that they have a better understanding of the current and future global economic and social environment, and to develop their leadership and management skills in an ever-changing environment.
The Board of Norcros plc is responsible for ensuring key sustainability policies, such as the Code of Ethics and Standards of Business Conduct, are communicated, understood and observed by all Group businesses, employees and associates. Day to day responsibility for promoting and implementing these policies is delegated to business unit senior management. This year, we established our ESG Forums to provide more structure to our sustainability management process, which will accelerate our sustainability ambition within the Group.
The ESG Forums use expertise across Group functions and allow us to prioritise our impact through organisational workstreams and to monitor progress against our plans across the Group. Our South African business, Norcros South Africa, has a well‑established Social and Ethics Committee of its Board, which oversees ESG in all South African business units.
Our Group Health and Safety Policy is driven from the top of the organisation with the Board having ultimate responsibility. The policy, which covers all employees, sets out our commitment to create, maintain and continuously improve a safe and healthy working environment for employees, contractors and visitors. Our working environment is designed to prevent occupational accidents and illnesses. We monitor key health and safety KPIs at operational board and management meetings.
Our health and safety organisational framework, outlined below, clearly defines those responsible and accountable for health and safety across our businesses. In addition, every employee is made aware that they have a responsibility for their own and others’ health and safety when engaged on Company business. The Group Health and Safety Managers’ Forum is chaired by the Company Secretary and comprises all the divisional Health and Safety Managers. Other members of Group management attend by invitation including the Group Head of Internal Audit and Risk Assurance.
Currently, Triton Showers, Vado, Johnson Tiles SA, TAL and Merlyn Industries are certified to the Health and Safety Management System ISO 45001 standard; together this covers 50% of our turnover.
Many of our employees have access to online health and safety training, which provides a range of training modules as required. In addition, where hands-on or specialist training is required, we use regular “toolbox talks” and provide more specific training where this is identified as being necessary.
We have a proud track record of safety performance, and we are starting to report on this as part of our ESG annual report. There were no fatalities recorded in the year (2021: nil) and there have been no fatalities recorded over the last decade when the current executive team have been in post. We record Accident Incidence Rate (AIR) monthly for each location and for the whole Group; this includes all reported accidents, however minor. Our Group AIR for 2022 was 3081 injuries per 100,000 employees in the year – which is consistent with levels in years when operations were not affected by the pandemic (2021: 222 per 100,000 employees; 2020: 303 per 100,000 employees). We recorded five serious reportable accidents in 2022 (2021: four, 2020: six).
We record the root cause of accidents and 80% of accidents in 2022 were caused by slips, trips and falls, or by handling, lifting or carrying. All accident statistics and their causes are regularly reviewed by the Group Health and Safety Managers’ Forum. We maintain externally managed whistleblowing reporting lines that are available to all employees where they can report confidentially, and anonymously should they want to, any concerns they may have in respect of health and safety matters.
1 The UK HSE’s all-manufacturing industry average AIR was 2,080 per 100,000 workers in 2021.
Response to covid-19
Health and safety during the COVID-19 pandemic has been of paramount importance to us as a responsible employer. As social lockdowns and travel restrictions have been lifted, the impact of COVID-19 on Norcros, our employees and our customers has reduced. We followed government legal requirements and advice closely throughout the pandemic, including when all restrictions were lifted in the UK, and responsibility for COVID-19 workplace safety fell solely upon employers. This rigorous approach to the protection of our people meant that, as with the previous financial year, in the year to 31 March 2022 there were no reported incidents of transmission of COVID-19 at any Norcros location. Instructions, such as “work from home wherever possible”, have now ended and we are encouraging our employees to return to the workplace when they feel comfortable doing so. Where practical, we have introduced flexible working policies for those colleagues who are able to effectively work remotely; this provides them with greater flexibility on a more permanent basis.
Health and wellbeing
We treat everyone with respect and encourage them to be themselves. We promote employee wellbeing and reduce stress through several initiatives and support mechanisms. Support is provided to all UK and Eire employees through our Employee Assistance Programme that extends to all aspects of wellbeing, including free access to various independent support helplines (e.g. stress, health, lifestyle, etc.).
Norcros SA runs a well-established Wellness Programme with an on-site Wellness Centre at the Olifantsfontein site, providing primary healthcare, occupational health, and professional wellness programmes and support.
The centre can dispense chronic illness and HIV medication and it is also partnered with Reality Wellness to provide professional counselling and support to staff on issues such as health, financial, psychological, trauma, substance abuse and more. The families of employees are also encouraged to make use of these support services.
The Code of Ethics and Standards of Business Conduct (the Code and Standard) applies in all areas of Norcros Group’s business and to all officers, Directors, employees, contractors and agency staff employed by or working for Norcros plc or any division of Norcros plc. The Board of Norcros plc is responsible for ensuring these business principles, such as anti-bribery and corruption and diversity, are communicated to, and understood and observed by, all Group businesses, employees and associates. This Code and Standard will be made available to every employee at the start of their relationship with Norcros and will also be communicated to all new employees of any business acquired by Norcros.
Norcros encourages an environment where honest and open communication is expected, with employees feeling comfortable bringing forwards any concerns or violations of Group policies. This is embedded into the Code and Standard and legal protection exists for all whistleblowers. Norcros maintains a whistleblowing policy and engages two independent and confidential whistleblowing service providers, one covering South Africa specifically and the other covering all other locations. Both lines operate 24/7 and 365 days a year in the whistleblower’s chosen local language. Concerns and reports can be made in confidence anonymously, and we will not discriminate or retaliate against any employee who reports suspected violations in good faith or who co-operates in any investigation or enquiry regarding possible violations.
Reports on the use of these services, any significant concerns that have been raised, details of investigations carried out and any actions arising as a result are reported to the Audit and Risk Committee at each meeting. The Committee also receives papers on incidents of fraud or attempted fraud and reviews them at each meeting. At least annually, the Committee conducts an assessment of the adequacy of the Group’s procedures in respect of compliance, whistleblowing and fraud.
Anti-bribery and corruption
Norcros prohibits bribery and all other types of fraud and will take disciplinary and/or legal action as appropriate in all cases of actual or attempted fraud across all operations. We have a strict Anti-Bribery and Corruption Policy, which applies to suppliers, set out in the Code and Standard and we conduct our business in a fair, open and transparent manner. The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those who have influence comply with it. We prohibit, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically unofficial payments made to secure or expedite a routine government action by a government official. All employees are required to undertake training under our Anti-Bribery and Corruption Policy at regular intervals and appropriate procedures are in place at all locations to mitigate the risk of any employee committing an offence of the policy.
Various day to day business situations are potentially sensitive in that they can create opportunities for corruption, particularly bribery, or a perception of improper practices. These situations include, but are not limited to the following and Norcros’ Anti‑Bribery and Corruption Policy sets out steps to prevent these situations occurring:
Our corporate values focus on respect, integrity and fairness. We are committed to respecting the dignity of the individual and to supporting the United Nations (UN) Declaration of Human Rights, the UN Universal Declaration of Human Rights, and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work and other core conventions. These principles are applicable across all our operations. As a result, the Directors do not consider human rights issues to be a material risk for the Group, principally due to the existing regulatory frameworks in place in the UK and South Africa, being the primary geographical locations in which we operate. In South Africa, the businesses are cognisant of their responsibilities under the Broad- Based Black Economic Empowerment legislation. In addition, the Group has its Modern Slavery Act statement and a policy in support of this.
All our employees are entitled to a fair salary and other terms and conditions of employment, as appropriate. Our policy is to comply, at the very least, with minimum wage legislation for any job role for all employees and we seek to be competitive as is appropriate to the role and business in question. Legally required benefits such as annual leave, sick leave, maternity leave and normal working patterns and hours are of course applicable to all.
Norcros plc is committed to trading within the law and conducting all of its business activities in an honest and ethical manner. Our Tax policy governs all of our business dealings and the conduct of all persons or organisations which are appointed to act on our behalf. Norcros plc and its subsidiaries has a zero-tolerance approach to all forms of tax evasion, whether under UK law or under the law of any foreign country.