Version 1
Version Date – August 2021 Approved by – August 2021 Last Review Date – August 2021
Policy Maintained by – Human Resources
1.0 Purpose
The purpose of this policy is to detail how Unipart remains compliant with legislative, regulatory, contractual and policy requirements associated with its activities in all territories in which it operates.
The policy provides the context for the management of our compliance obligations and provides guidelines and structures for all accountable persons under the policy.
2.0 Scope
This document applies to all Unipart people, in all territories in which we operate.
3.0 Policy Statement
The Board and senior management of Unipart are committed to ensuring the organisation meets its compliance obligations.
Compliance is concerned with not only externally imposed laws, regulations, codes and standards, but also with internal organisation standards, codes of conduct and ethics, and adoption of industry best practice.
Compliance and safety are defined at the highest level within Unipart as “Mandated”. Where appropriate, key compliance objectives will be incorporated into the strategic and operational planning processes.
A compliance framework is an important element of corporate governance and is intended to:
- Promote a culture of compliance within Unipart, highlighting its importance and connection to Unipart’s values;
- Foster continuous improvement in compliance processes, ensuring obligations are always met by establishing monitoring and reporting mechanisms that will assist in identifying instances of non-compliance and tracking remedial actions;
- Maintain the reputation of Unipart in the marketplace and to demonstrate its social and corporate responsibilities.
4.0 Definitions
Accountability – the obligation of an individual to account for their activities, accept absolute responsibility for them, and to disclose the results in a transparent manner.
Compliance Obligation – a requirement under legislation, regulation, contract or policy with which Unipart must comply.
Contractor – an individual who is employed directly by Unipart for a defined period of time.
Unipart People – all temporary and established employees, contractors, agency workers, and agents acting on the company’s behalf.
5.0 Responsibilities
5.1 Group Leadership Team
- has the primary responsibility for formulation and execution of this policy
- all GLT and Board members will complete mandated compliance training modules as and when required
- will review all compliance-related risk assessments as part of the annual risk review
5.2 Group Risk Committee
- ensure all compliance-related risks are understood and documented
- take oversight of the Group Risk register and ensure all functional and Divisional risk registers are adequately reflected at a Group level
- report annually to the GLT and Unipart Board of Directors on the effective management of our compliance obligations and risk register
- immediately flag any new/emerging compliance-related risks to the GLT and Unipart Group Board of Directors
- monitor completion of all mandatory compliance training and ensure appropriate steps are taken where gaps exist
5.3 Divisional Leadership Teams/Managing Directors
- ensure that this policy and all related policies are deployed effectively across their Division and to reinforce and enforce any mandatory training compliance requirements for their division
- identify any Division/industry-specific compliance obligations and ensure appropriate policies and training are deployed within the Division
- ensure suitable Risk Assessments are produced for their division
- establish appropriate management controls and procedures within their operations and ensure that heads of business units are held responsible for the effective implementation of the policies and procedures in their area of responsibility
- ensure that their senior management team have completed all mandated compliance training and that relevant information and training is cascaded throughout their organisation
- ensure suitable compliance standards and procedures and relevant training for contractors and agents are in place
- ensure that any employee or other person working on behalf of Unipart is not penalised for enforcing our compliance standards even if it results in the Company losing business
- provide suitable information annually to the Group Risk Committee to facilitate the creation of an annual, suitable and transparent Unipart Compliance and Risk report
5.4 Divisional/Functional risk and Compliance Managers
- ensure that suitable Risk Assessments are produced for their functions that identify any potential compliance issues
- ensure that appropriate management controls and procedures are implemented, monitored and enforced in their division and/or functions
- ensure that the appropriate Unipart People are identified to undertake mandatory training compliance training in accordance with this policy
- ensure that relevant compliance training is available across the division/function
- ensure suitable Compliance Procedures for consultants and agents used by their functions are in place
- will ensure that any employee or other persons working in their function is not penalised for enforcing our compliance standards even if it results in Unipart losing business
5.5 All Unipart People
- Unipart promotes high standards of professional conduct and compliance across global operations. As such all Unipart people are required to:
- Operate within Unipart’s compliance framework at all times
- Comply with all national and regional laws and regulations
- Complete all mandated compliance training within an agreed timescale
- carry out their job and/or contractual responsibilities in a professional, conscientious, and ethical manner, and in accordance with all applicable laws, regulations, rules, and policies
- report any actions or behaviours you believe, in good faith, violate ethical practices, compliance standards, law, or regulation using normal escalation procedures up to and including You may report such actions without fear of reprisal or retaliation. However, if you fail to report these violations, you may be subject to disciplinary procedures
- Cooperate in the investigation of any unethical or unlawful action and/or breach of our compliance standards and this policy
- Where there is uncertainty as to the most appropriate course of action to maintain compliance standards and/or report a breach of these standards, Unipart people should seek advice from their line manager or HR in the first instance
6. Compliance Training
Sometimes, conduct undertaken with good intentions but with inadequate knowledge may violate applicable laws or regulations. Training is required to provide all Unipart People with the knowledge and skills to carry out their responsibilities in accordance with legal, regulatory requirements and Unipart compliance framework. Proper and continuing training is, therefore, a significant element of an effective compliance programme.
All Unipart People :
- will not have an identical amount of training, nor will the focus of training efforts be the same for all. Compliance training will be targeted at Unipart People based upon their role and/or their level of seniority in the organisation and based upon an assessment of risk as set out in Appendix 1 of this policy.
- must, as a condition of their employment, complete any compliance training (including policy affirmation and achievements of 80% pass mark in any test) required by Unipart within 30 days of commencement of employment or engagement contract
- must, as a condition of their employment, further complete any additional training relating to new laws or regulatory requirements (including policy affirmation and achievements of 80% pass mark in any test) within 30 days of such training being requested
- must, as a condition of their employment, complete any required refresher training (including policy affirmation and achievements of 80% pass mark in any test) within 30 days of it being issued. The frequency of refresher training will vary, but unless otherwise required to be different, shall be every 2 years as a standard
Records of compliance training will be retained for the duration of employment/contract.
7. Key Related Policies and Documents
- Whistle-blower Policy Disciplinary Policy
- Data Protection Training Policy Anti Bribery and corruption
- Modern Slavery and human trafficking Human Rights
- Equal opportunities Anti-racism Competition law
- The prevention of facilitation of criminal financing
8. Further information and guidance
Where clarification is required on any aspect of this policy, this may be obtained from the Group Chief Risk Officer, Company Secretary or Group HR Director.
9. Monitoring and review
All persons mentioned in this policy are required to abide by its terms as a condition of employment.
The Unipart Group Leadership Team will review the implementation of this policy in respect of its suitability, adequacy, and effectiveness and make improvements as appropriate.
APPENDIX 1 COMPLIANCE TRAINING MATRIX
| Compliance area/legislation | Functional Owner | GRC
member |
Employee group for mandatory training | UK or Global? | Frequency |
| Anti-bribery and Corruption | Company Secretary | TR | All employees in Finance, Sales, Purchasing and all Execs U92/Equivalent managers and above in all other areas | Global | Starter – 1 month Refresh -2 yrs |
| Modern slavery and human trafficking | Company Secretary | TR | All employees in HR, Finance, Sales, Purchasing and all Execs U92/Equivalent managers and above in all other areas | Global | Starter – 1 month Refresh -2 yrs |
| Criminal Finances Act | Finance | DL/CW | All employees in Finance, Sales, Purchasing and all Execs U94 and above in other areas. | UK | Starter – 1 month Refresh -2 yrs |
| Data Protection | HR/IT | JG/YL | All employees in HR, IT, Finance and all Execs U92/Equivalent managers and above in all other areas | Global | Starter – 1 month Refresh -2 yrs |
| Competition Law | Legal | RC | All employees in legal, commercial and finance and all Execs | UK | Starter – 1 month Refresh -2 yrs |
| UK Immigration | HR/Global mobility | JG/DL/ CW | All employees in HR and finance and all Execs U94/Equivalent managers and above in all other areas | UK | Starter – 1 month Refresh -2 yrs |
| Diversity and Inclusion | HR | JG | All employees in HR and all Execs
U92/Equivalent managers and above in all other areas |
Global | Starter – 1 month Refresh -2 yrs |