Smith & Nephew has multiple levels of ethics and compliance oversight to ensure managers, employees and business partners act with integrity.
Our compliance programme is supported by a Chief Compliance Officer, reporting to the Chief Executive Officer, and a global Office of Ethics and Compliance team.
Board Ethics and Compliance Committee
The Board Ethics and Compliance Committee oversees the Company's reputation for compliance, maintains the Company's policy for ethical and legal business practices around the world, and assesses and approves Group Ethics and Compliance Committee recommendations for changes to practice.
Group Ethics and Compliance Committee
The Group Ethics and Compliance Committee reviews the Company’s approach to compliance, recommends changes to compliance processes, agrees to actions to take, and ensures that Smith & Nephew business is fit and proper in its delivery of sales and other business products.
Business area and local compliance committees
The business area and local compliance committees oversee the compliance program for specific business areas and markets.
Training and education
We train all employees and third parties who have interactions with healthcare professionals or government officials on our Code of Conduct when they start working for Smith & Nephew.
We also provide annual compliance training and scenario-based training to our employees which we tailor to their roles within the company.
Compliance auditing and monitoring
The global Compliance Auditing Team routinely tests that the Company’s code of conduct and related policies and procedures are implemented.
Our compliance controls are designed following the three lines of defence model: local management, an operational monitoring body (the OEC), and an independent auditing body. The Regional Compliance Officers fill the role of the second line of defence for anti-bribery controls, while the Global Compliance Auditing Programme team fills the third line.
The Global Compliance Auditing team regularly tests the key controls in place to mitigate bribery risks, ensuring that they are implemented effectively. The programme is risk-based and all markets and operations are reviewed in rotation, with higher risk areas reviewed more frequently. Where the Global Compliance Auditing team identifies weaknesses in design or implementation of processes and controls, it works with the business to develop a corrective and preventive action plan which is tracked to completion through a structured process.
The Regional Compliance Officers conduct in-market monitoring through a variety of monitoring activities, some of which are market-specific based on the risks of the market. The local monitoring activities act as an early warning system.