Consequence Management

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1 Group Standard Consequence Management Serco is committed to creating an open and transparent environment, where good behaviour is rewarded and where employees feel safe in the knowledge that poor behaviour can be reported without fear, and that all instances of such behaviour will be dealt with effectively SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

2 Document Details Contents Document Details erence SMS GS-G1: Consequence Management Approval Date July 2014 Serco Public Version 1 Date for next review July 2016 Applicability Serco Group covering all business regions, operating companies and business units throughout the world 1 Authority Chief Executive, Serco Group plc Accountable Policy Owner (Group) HR Director, Serco Group plc Additional Information Supporting standards, standard operating procedures and guidance relating to this Group Standard are available on Our World under Serco Management System Governance Our policies and standards, together with any regional or market requirements and enhancements to them, are authorised through a robust governance process. The SMS Quality Manual describes this process and is available on Our World under Serco Management System 1 As used herein, Serco Group and its affiliates, subsidiaries and operating companies are referred to as Serco, the Company or company, or we, us or our. 1 Objectives Policy Standards Compliance Addressing potential consequences Responsibilities & Accountabilities Processes and Controls Governance processes and controls Supporting documentation and guidance Definitions Further information and support SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

3 1 Objectives Serco is committed to creating an open and transparent environment where good behaviour is rewarded and where employees feel safe in the knowledge that poor behaviour can be reported without fear, and that all instances of such behaviour will be dealt with effectively, consistently and appropriately, without exception. This Standard covers how instances of non-compliance with legislation and regulations, Serco s Code of Conduct (the Code ) or the Serco Management System will be dealt with. This Standard should be read in conjunction with: Serco Group Policy Statements The Serco Code of Conduct The Speaking Up Group Standard 1 The Speaking Up-Issues Handling Group Standard Operating Procedure 2 2 Policy Standards 2.1 Compliance S1. Non-compliance with this Group standard carries risk to the business and the individual(s) concerned. Employees have a number of specific duties to minimise this risk, including the requirement to: a. comply with all applicable laws and regulations b. adhere strictly to all Policies and the SMS c. adhere strictly to the Code d. behave in a manner that is consistent with Serco s values and ethical standards e. report promptly any breaches that relate to any of the above f. enforce remedial action where a violation has taken place S2. It is an employee s duty to understand his or her obligations arising as a result and to act at all times in an open and transparent manner, in accordance with the Governing Principles (which are set out in the Code 3 ), and to exercise good judgement S3. The managers and supervisors of an employee must properly supervise or oversee their conduct and ensure systems of work enable employees to meet their obligations 2.2 Addressing potential consequences S4. Questions regarding the laws, regulations, the Code and Policies applicable should be raised in the first instance with an employee s line manager and, if necessary, with the relevant head (on matters concerning the Code and Policies) or with the Company s legal department (regarding law and regulations). It is an employee s duty to exercise good judgement when deciding whether to seek guidance or support on such matters, and to take the appropriate action to ensure compliance 1 See Speaking Up Group Standard : SMS-GS-BC3 2 See Speak Up Issues Handling GSOP : SMS GSOP BC3-1 3 See Serco Code of Conduct 2 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

4 S5. Reporting of concerns regarding breaches of laws, regulations, the Code and Policies should be raised in accordance with Serco s Speaking-Up Standard 4 and Procedure 5 S6. The provisions of the Code and the Policies apply to every employee without exception. If any employee violates the Code or the Company s policies, or otherwise acts illegally, or in breach of any applicable law or regulations, the violation will be investigated and, where the investigation has confirmed a violation, the employee will be subject to disciplinary action S7. The managers and supervisors of an employee who has violated these rules may also be disciplined if they have failed properly to supervise or oversee the employee s conduct or have created a system of work which led to or encouraged the employee to breach his or her obligations. Enforcement action will be taken in every case of a proven violation, regardless of the employee s position or seniority in the Company steps to conceal or cover up his or her actions or those of someone else g. the employee s willingness to assist in managing the consequences of the breach, including cooperating fully and frankly with any subsequent investigation h. the severity of the violation S10. Employees who are responsible for taking enforcement action in respect of breaches will themselves be in breach of the Policies if they fail to enforce these procedures rigorously and appropriately in every case and without exception. The enforcement process will be subject to regular assurance review and audit and remedial action will be taken promptly in response to any concerns raised S8. In determining the appropriate disciplinary action to take, the Company will have regard to the employee s contract of employment and will follow the Human Resources Disciplinary Procedures to ensure a proportionate, clear and consistent approach is taken to all violations S9. The nature of the disciplinary action will depend upon the facts of the individual case and the Company will consider all relevant factors, including the following: a. the employee s intentions when committing the violation b. whether the employee knew that he or she was acting in violation c. whether the employee has been disciplined previously for other violations d. if the employee acted dishonestly or with bad intent or was open and transparent in his or her actions e. whether the employee s conduct was criminal f. the employee s response to the violation including whether the employee self-reported the violation and sought guidance on what steps to take to remedy the position or whether the employee took 4 See Speaking Up Group Standard : SMS-GS-BC3 5 See Speak Up Issues Handling GSOP : SMS GSOP-BC SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

5 3 Responsibilities & Accountabilities S11. The following responsibilities will apply to the delivery of the defined standards. If these are not completed effectively, the person responsible will be accountable for any consequences. d. behaving in a manner that is consistent with Serco s values and ethical standards e. promptly reporting any breaches that relate to any of the above f. implementing remedial action where a violation has taken place Group S12. The Group CEO will appoint a Group Consequence Management Lead responsible for: a. developing and maintaining Group Consequence Management policy b. ensuring the Consequence Management standard and associated procedures and key controls remain fit for purpose, reflect legislative and regulatory requirements and effectively manage business risks c. providing oversight and reporting consequence management performance All managers and supervisors S13. All managers and supervisors of an employee must properly supervise or oversee their conduct and ensure systems of work enable employees to meet their obligations S14. All managers are responsible for: a. investigating all reported violations and, where proven, invoking the disciplinary procedure b. considering all relevant factors during an investigation when determining future action c. implementing remedial action and local controls where a violation has taken place to reduce the risk of violations occurring in the future All employees S15. All employees are responsible for: a. complying with all applicable laws and regulations b. strictly adhering to all Policies, including all systems and controls governing the business, such as accounting, billing and performance standards, procedures and work instructions c. strictly adhering to the Code of Conduct 4 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

6 Group (S12 - S14) Division Business Unit Contract All Employees (S15) 4 Processes and Controls 4.1 Governance processes and controls Process A set of related activities that must be carried out to achieve policy outcomes Controls The action we put in place to mitigate a risk(s) within a key process and/or the delivery of policy outcomes. These are mandated and are the minimum that should be implemented regardless of any local difference Responsibility for ensuring controls are in place and operating effectively P1 Responsibilities are defined and understood C1 The Group Consequence Management Lead is responsible for: Developing and maintaining Group Consequence Management policy Ensuring the Consequence Management standard and associated procedures and key controls remain fit for purpose, reflect legislative and regulatory requirements and effectively manage business risks Providing oversight and reporting consequence management performance 5 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

7 Group (S12 - S14) Division Business Unit Contract All Employees (S15) Process A set of related activities that must be carried out to achieve policy outcomes Controls The action we put in place to mitigate a risk(s) within a key process and/or the delivery of policy outcomes. These are mandated and are the minimum that should be implemented regardless of any local difference Responsibility for ensuring controls are in place and operating effectively C2 All managers and supervisors are responsible for: Investigating all reported violations and, where proven, invoking the disciplinary procedure Considering all relevant factors during an investigation when determining future action Investigating all reported violations and, where proven, invoking the disciplinary procedure Implementing remedial action and local controls where a violation has taken place to reduce the risk of violations occurring in the future 6 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

8 Group (S12 - S14) Division Business Unit Contract All Employees (S15) Process A set of related activities that must be carried out to achieve policy outcomes Controls The action we put in place to mitigate a risk(s) within a key process and/or the delivery of policy outcomes. These are mandated and are the minimum that should be implemented regardless of any local difference Responsibility for ensuring controls are in place and operating effectively C3 All employees are responsible for: Complying with all applicable laws and regulations Strictly adhering to all policies, including all systems and controls governing the business, such as accounting, billing and performance standards, procedures and work instructions Strictly adhering to the Code of Conduct Behaving in a manner that is consistent with Serco s values and ethical standards Promptly reporting any breaches that relate to any of the above Implementing remedial action where a violation has taken place P2 Establish policy C4 Policy, standards and group procedures are defined and published C5 Policy, standards and group procedures, defined in the Serco Management System and Serco s Code of Conduct, are communicated and implemented 7 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

9 Group (S12 - S14) Division Business Unit Contract All Employees (S15) Process A set of related activities that must be carried out to achieve policy outcomes Controls The action we put in place to mitigate a risk(s) within a key process and/or the delivery of policy outcomes. These are mandated and are the minimum that should be implemented regardless of any local difference Responsibility for ensuring controls are in place and operating effectively P3 Establish systems and process C6 Appropriate systems and procedures are in place to enable breaches to be reported, investigated and disciplinary action taken C7 Systems and procedures are periodically reviewed and updated P4 Compliance assessment and audit C8 A compliance plan is in place which includes assessment of systems and procedures to enable violations to be reported, investigated and disciplinary action taken C9 Compliance and audit reports have action plans to address non-conformities C10 Agreed actions are closed out 8 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

10 5 Supporting documentation and guidance 6 Definitions Term Definition The following should be read in conjunction with this standard: Document Serco Group Policy Statements Serco Code of Conduct SMS-GS-BC3 Speaking Up Group Standard SMS GSOP- BC3-1 Speaking Up Issues Handling Accountability Responsibility Group Division Business Unit Being accountable means being not only responsible for something but also answerable for your actions. A responsible person is the individual who completes the task required. Responsibility can be shared and delegated. All responsible persons will also be accountable for completing tasks effectively. Non-compliance will have consequences which may include disciplinary action as defined within the Consequence Management Group Standard. Serco Group plc is the administrative centre of the organisation, responsible for setting corporate strategy, defining governance requirements and supporting the business in its day to day operations The Group will define a set of business divisions which will be responsible for business delivery within a defined set of markets or geographies. A Business Unit is a cluster of Contracts which provide a similar service e.g. Health, Defence, Transport etc. Where appropriate, a separate legal entity wholly owned or where Serco has a controlling share may also be referred to as a Business Unit, where appropriate. This may also refer to Counties/Territories 9 - SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

11 Term Contract Contract Manager Definition A Contract provides specified requirements to a customer (either directly with Serco or to a consortium/joint Venture in which Serco is a party) A Contract will also refer to a corporate/functional area. Corporate/functional areas are functions which support the business and they include finance, HR, procurement etc. This refers to a manager with responsibility for managing the performance of a contract and can include a Contract Manager on a day-to-day basis (or Operational Manager with devolved responsibility), a Contract Director, Partnership Director and/or a Business Unit Managing Director 7 Further information and support If you require any further information or support regarding this Group Standard, or if you have any suggestions for improvement, please contact the Accountable Policy Owner (Group) or SMS GS-G1 Consequence Management July 2014 v1.0 Serco Public

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