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Case study: How Noble combats corruption

Noble Group is a supply chain manager focused on purchasing physical commodities and transforming these into customised products for its customers. Noble is committed to operating with the utmost integrity  Tweet This!, implementing systems and processes to uphold accountability and responsibility throughout the organisation and across Noble’s relations with its stakeholders.

This case study is based on the 2018 Sustainability Report by Noble published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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Business integrity is firmly embedded in Noble’s values, with Noble’s Group-wide policies stating clearly that all its business functions must comply with the legal obligations and laws in every jurisdiction in which Noble operates. In order to combat corruption Noble took action to:

  • implement a Code of Conduct
  • promote compliance
  • apply a whistle-blowing policy
  • provide ongoing training

What are the material issues the company has identified?

In its 2018 Sustainability Report Noble identified a range of material issues, such as product quality, supply chain management, talent attraction, human rights, employee training and development. Among these, combatting corruption stands out as a key material issue for Noble.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups Noble engages with:

Stakeholder Group
Shareholders
Banks
Customers and suppliers
Governments and regulators
Employees
Local communities

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics Noble developed surveys to collect feedback from Noble’s senior functional managers, key customers, analysts and investors on the relative importance of different sustainability topics.

What actions were taken by Noble to combat corruption?

In its 2018 Sustainability Report Noble reports that it took the following actions for combatting corruption:

  • Implementing a Code of Conduct
  • Noble’s Code of Conduct sets out compliance requirements and guidelines on key ethical issues. The Code of Conduct imposes specific obligations regarding anti-corruption, anti-trust, anti-money laundering, combating financial crimes, counter financing of terrorism, sanctions and fraud. Every employee must acknowledge that they have read and understood Noble’s Code of Conduct and policies, as part of their induction and on an ongoing basis. Regular refresher training is organised, to maintain the effectiveness of compliance programmes and highlight some of the perception gaps and possible “grey areas”. Specific rules on securities trading when in possession of internal, confidential information are also circulated among employees and set out in a separate policy. This includes a procedure for the good faith reporting of any infringement of the Code of Conduct or other Noble policy. Concerned employees are encouraged to report without fear to the Compliance or Legal departments, when any suspicions arise.
  • Promoting compliance
  • Noble regularly reviews its policies and procedures to adapt to the changing regulatory landscape and, taking into account these developments, industry guidance, customer experience and societal expectations, implements internal controls that safeguard its operations against regulatory and reputational risk. Noble’s experienced Compliance Team is dedicated to making sure that its business conforms to applicable laws and regulations. Compliance Team personnel are based in Noble’s trading offices, and serve as a valuable resource for providing technical assistance and training in the regulatory sphere. Before entering into any contracts with new counterparties, Noble undertakes a World-Check risk search as a key component of its mandatory risk screening. Additionally, Noble employees worldwide are given explicit guidance on ethical business practices, such as conflicts of interest, entertainment and gifts.
  • Applying a whistle-blowing policy
  • Noble has adopted and implements a whistle-blowing policy through which employees may, in confidence, raise concerns regarding matters not only about workplace misconducts, but also any unlawful activities, policies or practices, suspected fraud, corruption, dishonest practices or other similar matters. There are also arrangements for an independent investigation of such issues and for appropriate follow up actions where necessary. During the reporting period, Noble had no confirmed cases of corruption in its operations.
  • Providing ongoing training
  • Noble’s corporate policies are reviewed and updated on a regular basis, while training on business ethics and conduct is regularly carried out in Noble’s offices, to reinforce the procedures for reporting potential violations. All relevant staff are given regular updates on rules and regulations relevant to their particular markets and jurisdictions, and important notifications are communicated via compliance emails to employees globally. Education and refresher trainings on compliance, financial crime, anti-bribery and anti-money laundering (AML) are delivered via e-learning programmes and classroom sessions. In 2017, 85 employees across Asia attended face to face training. Among these, around 10% of attendees were management level staff. This programme caters to the different needs of different business functions. For example, front office members receive training on financial crimes, bribery acts and market abuse, which is less relevant in other business areas. Other training includes regulations related to illegal conduct and references on anti-corruption laws and published cases.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standards addressed in this case are:

1) Disclosure 205-2 Communication and training about anti-corruption policies and procedures

2) Disclosure 205-3 Confirmed incidents of corruption and actions taken

 

Disclosure 205-2 Communication and training about anti-corruption policies and procedures corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption

 Disclosure 205-3 Confirmed incidents of corruption and actions taken corresponds to:

  • Sustainable Development Goal (SDG) 16: Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels
  • Business theme: Anti-corruption

 

80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.



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By registering for the next 2-day FBRH GRI Standards Certified, IEMA & CIM recognised course you will be taking the first step in gaining the many benefits of sustainability reporting.

Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP

 

References:

1) This case study is based on published information by Noble, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:

http://database.globalreporting.org/

2) https://www.globalreporting.org/standards/gri-standards-download-center/

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