|Meetings eligible to attend||Meetings attended|
|Ian Strachan (chairman)||3||3|
|Helen Alexander CBE||3||3|
|John Rishton 1||2||2|
|1||John Rishton retired as a member of the ethics committee on September 30, 2010 on the announcement of his appointment as the next Chief Executive.|
The ethics committee consists exclusively of independent non-executive directors and met three times in 2010. Ian Strachan chairs the committee and its other members during 2010
were Helen Alexander CBE and Peter Byrom. John Rishton was also a member up to September 30, 2010. The Director of Risk, who has executive responsibility for ethics, attends the meetings as does the General Counsel and Company Secretary. The Chairman of the Board, the Chief Executive and other executives of the Group may be invited to attend meetings of the committee.
The Board strongly believes that the Group’s business should be conducted in a way that reflects the highest ethical standards. The ethics committee was established in 2008 to oversee the implementation of the Group’s global ethics strategy and the management of ethical and reputational risk.
The committee is responsible for reviewing compliance with the Group’s Global Code of Business Ethics (Global Code) and will, if appropriate, make recommendations to the Board for changes to the Global Code. The Global Code sets out the principles to be followed by employees when conducting business.
The committee reviews recommendations on ethical matters made by external regulatory authorities or other bodies and is responsible for making recommendations to the Board about whether these should be applied to the Group and, if so, to what extent. It also has responsibility for monitoring reports on issues raised through the Group’s confidential reporting line and for reviewing the results of subsequent investigations.
The committee ensures that ethical policies and practice are subject to an appropriate level of internal audit and, where necessary, will appoint auditors to conduct an independent external review.
During the year, the committee reviewed and enhanced relevant supporting policies and procedures that provide detailed guidance and support for the implementation of the Global Code. The committee also considered the impact of the new UK Bribery Act which is expected to come into force in May 2011. In response, the committee has thoroughly reviewed its policies in this area. In particular, policies on Gifts and Hospitality and Commercial Intermediaries were updated during the year with every relevant employee receiving training on the new arrangements and a new compliance organisation has been established.