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Case study: How WSP promotes business integrity

WSP is a leading global professional services firm, providing engineering and design services to clients in the Transportation & Infrastructure, Property & Buildings, Environment, Power & Energy, Resources and Industry sectors. WSP’s reputation notably depends on its ability to be world class professionals, which means acting with honesty, integrity and transparency  Tweet This! in its daily dealings with employees, clients and other business partners.

This case study is based on the 2018 Global Sustainability Report by WSP 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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WSP has a number of objectives focusing on strategically positioning Compliance and Ethics matters by increasing the governance surrounding its Compliance and Ethics programme, which includes its anti-corruption and privacy policies, as well as on creating high-impact communications to give policies and programmes strong visibility. In order to promote business integrity WSP took action to:

  • implement a Code of Conduct
  • show zero tolerance for corruption
  • encourage employees to raise concerns

What are the material issues the company has identified?

In its 2018 Global Sustainability Report WSP identified a range of material issues, such as employment practices, environmental compliance, occupational health and safety, climate change resilience, employee training and education. Among these, promoting business integrity stands out as a key material issue for WSP.

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 WSP engages with:

Stakeholder Group                Method of engagement
Employees

 

 

 

 

·      Employee surveys

·      Townhall meetings

·      Information cascaded from leadership, via team meetings

·      Global internal communications (intranet, emails) and local intranets

·      Annual and Sustainability Reports

·      Leadership interviews

Investors and analysts

 

·      Investor relations activities including: investor days, meetings, roadshows, conferences, discussion with senior executives and market sector experts, conference calls

·      Website postings

·      Financial reports

·      Press releases and media relations

·      Annual Information Form and Annual Report

·      Annual Meeting of Shareholders

·      Site visits to explain WSP’s project work

Clients

 

 

 

·      Project communications

·      Project feedback received from clients

·      Client interviews

·      Thought leadership communications

Business partners, including subcontractors, joint venture and consortium partners ·      Project communications

 

Suppliers ·      Procurement
Governments, including regulatory authorities ·      Project work communications involving government agencies

 

Industry bodies ·      Participation on key industry association committees

·      Attendance at industry functions

·      Sponsorship of industry events and research

·      Trade show displays

·      Thought leadership

Local communities

 

·      Consultation on behalf of clients within projects

·      Local community involvement/charity work

·      Sponsorship and donations

How stakeholder engagement was made to identify material issues

To identify and prioritise material topics WSP reviewed sustainability topics with external and internal stakeholders via questionnaires and individual conversations. External stakeholders were comprised of investors and clients, while internal stakeholders included employees, regional sustainability leaders and corporate function leads overseeing areas related to WSP’s environmental, social and governance impacts.

What actions were taken by WSP to promote business integrity?

In its 2018 Global Sustainability Report WSP reports that it took the following actions for promoting business integrity:

  • Implementing a Code of Conduct
  • On a global level, WSP has a Code of Conduct, a Gifts, Entertainment and Hospitality Policy, a Working with Third Parties Policy, an Anti-Corruption Policy, and a Global Privacy Policy (collectively, the “Code”), which apply to all operating entities as well as WSP’s directors, officers, employees and contract workers. The Board of Directors is responsible for approving the Code of Conduct, which was last amended and approved in March 2019. The Code is accessible to all employees through WSP’s intranet sites, and to the public via its website. It is available in several different languages, to facilitate its use in regions where WSP primarily operates. Additionally, WSP’s Third Party Code of Conduct summarises the values set out in the Code as they apply to third parties, providing a set of governing principles for ethical behaviour when interacting with WSP or on its behalf.
  • Showing zero tolerance for corruption
  • WSP has a zero-tolerance policy to all forms of corruption, whether direct or indirect. It is subject to strict anti-corruption laws, including the Canadian Corruption of Foreign Public Officials Act (CFPOA), the United States Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act (UKBA). WSP’s commitment to maintaining zero tolerance to all forms of corruption extends beyond regulatory compliance and includes an extensive e-learning onboarding and refresher training, live training sessions for key employees, communications with employees, and tailored compliance tools. WSP manages and assesses risks for corruption in several ways, which include the following:
    • Enterprise Risk Management
    • Due diligence procedures for business partners, as described in the Working with Third Parties Policy. These are notably based on country, transaction, and relationship risks.
    • Global and regional Delegation of Authority policies
    • Global and regional project risk committees
    • “Guidelines for High Risk Countries and Regions”, which list the countries and regions deemed “high risk” for corruption, safety and security and establish requirements to conduct business in such locations. The guidelines are available to all employees via WSP’s intranet, are updated regularly and were last updated in February 2019.
  • In addition, to identify and manage Gifts, Entertainment and Hospitality (GEH) and Conflicts of Interest, WSP uses the GEH and Conflicts of Interest Registry. The link to the online Registry is available on WSP’s intranet sites, and user guides, video tutorials and regional guidelines on using the Registry are also available.
  • Encouraging employees to raise concerns
  • WSP’s “Confidential Business Conduct Hotline” provides a means for employees as well as the public to raise issues of concern anonymously, with a third-party service provider. Access to information about the hotline is highly visible through a direct click from the front page of global and regional intranets, the website, regular internal communications, videos, presentations and poster campaigns in certain regions.

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

The GRI Standard addressed in this case is: Disclosure 205-2 Communication and training about anti-corruption policies and procedures

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

 

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 and IEMA approved Course you will be taking the first step in gaining the many benefits of sustainability reporting.

 

References:

1) This case study is based on published information by WSP, 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/

Note to WSP: With each case study we send out an email requesting a comment on this case study. If you have not received such an email please contact us.

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