Wherever we are in the world, we are committed to doing business the right way by acting honestly and fairly, complying with laws and regulations and adhering to policies and procedures.
In 2014 SITA created a dedicated compliance team which reports into the General Counsel and is accountable to the Ethics Ofﬁce. In 2014 SITA created a dedicated compliance team which reports into the General Counsel and is accountable to the Ethics Office. The initial priority for the team was the establishment of the Integrity, Compliance and Ethics (ICE) Program, which was successfully launched in March 2015 with endorsement from the CEO and the SITA Board.
ICE acts as an umbrella program bringing together compliance activities on anti-bribery and corruption, trade controls, data protection and competition. The governance of ICE is based on best practice guidance which identifies the following five key elements of a successful program: leadership, risk assessment, standards and controls, training and communication and monitoring.
Ethics training and communication
Standards are mandated across the business and apply to all our employees and contractors. The company intranet is the primary means of making each of the standards available to employees. Education on the standards is also built into each of the e-learning modules and all face-to-face materials.
Our standards currently include the new Code of Conduct, Anti- Bribery and Corruption Policy, Agents and Intermediaries Policy and Hosting and Gifting Guidelines. These and related resources are available on our company intranet site. Our Supplier Code of Conduct, together with summaries of our standards, is available on the public website. These standards also apply, to the extent appropriate, to our third parties and business partners.
Raising awareness of and educating employees on our standards and the applicable laws and regulations is a fundamental part of our compliance governance. There are a number of challenges in delivering a program of this nature across more than 200 countries and territories, including language, culture and logistics.
In 2015 our Legal, Regulatory and Compliance team provided face-to-face training sessions on anti-bribery and corruption in a number of locations around the world. Our Chief Ethics and Compliance Officer also delivered face-to-face sessions on compliance and ethics to the Senior Leadership Team and to the SITA Board.
All employees are required to complete mandatory e-learning on our Code of Conduct. Targeted mandatory e-learning on anti-bribery and corruption is provided to employees on a risk-based approach, which is further supported with face-to-face training.
The Ethics Office is responsible for oversight of compliance with our Code of Conduct, which includes the review of investigations into potential violations. The Ethics Office will periodically engage Internal Audit to assist in this role.
There are a number of different ways our employees can report a concern, including through their line manager, another manager in their function or a member of the Compliance or HR teams. Alternatively, an online report can also be made directly to the Ethics Office, anonymously if preferred.
All reports are investigated promptly and thoroughly and feedback on results of the investigation is provided in a timely manner. Where appropriate, disciplinary action up to and including dismissal is taken and/or additional guidance and training provided. SITA does not tolerate retaliation against anyone making reports in good faith and/or assisting in an investigation. Any retaliation will be treated as a violation of our Code of Conduct.
Since 2013 we have carried out annual standalone compliance risk assessments to identify those business operations which have the higher risk of a compliance breach, those areas often identified because of the type and location of the activities carried out. These areas receive additional focus and support including further training and guidance. Compliance and ethics risks are also reviewed as part of our annual corporate risk management process.
Risk management is also addressed in a new Standard Commercial Process (SCP) launched in 2015. The aim of SCP is to document ways of working on every SITA commercial opportunity in order to meet customer requirements while supporting SITA’s corporate objectives with regard to commercial, financial, governance and risk management criteria.
In 2016 we are planning a number of initiatives under the ICE program umbrella including:
- A roll out of the new Code of Conduct and supporting e-learning to SITAONAIR and our subsidiary CHAMP Cargosystems
- Targeted e-learning modules and face-to-face training on anti-bribery and corruption, trade controls and data protection on a risk-based approach
- A new externally hosted speak up facility to provide an additional way for our people to seek advice on compliance with, and raise concerns on any potential breach of our Code of Conduct
- Enhanced communications to raise awareness
- A Global Integrity, Compliance & Ethics (ICE) week of events and activities