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Ethical business conduct
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Ethical business conduct

Ultra is committed to ethical business conduct and requires all employees, businesses and third parties, who act on Ultra’s behalf, to comply fully with the Group’s standards of business ethics and with the applicable laws and regulations of the countries in which it does business, including those pertaining to

  • anti-bribery and corruption practices
  • competition and anti-trust laws

Ultra’s corporate ethics policy, encompassing gifts and hospitality, is the benchmark against which all Ultra’s businesses report on compliance on a monthly basis, with Board level review biannually.

Providing guidance and training to employees

The Group has continued to strengthen its policies, processes and training to ensure employees have the clear guidance they need in identifying and managing ethical matters.

A Group-wide independent, confidential web- and telephone-based hotline enables all employees to anonymously report concerns about possible improprieties and other compliance issues. 

Reports made to the hotline are compiled by the independent operator and forwarded to the Chairman of the Audit Committee (or for US businesses, forwarded to the Directors of the Special Security Arrangement Board or Proxy Board as appropriate) for action. Any employee found to be in breach of the ethics policy is subject to appropriate disciplinary action.

Independent Ethics Overview Committee

An independent Ethics Overview Committee provides guidance, advice to, and scrutiny of Ultra’s businesses. The Committee provides assurance that Ultra’s business is being conducted in line with the Group’s policies, processes and in accordance with relevant legislation. It does this through discussions with senior managers, receiving reports and visits to Ultra businesses.

The Committee comprises six permanent members, three of whom, including the Chairman, are independent. To maintain the highest degree of impartiality, the independent members of the Committee are self-selecting. The appointment of the Chairman is also exclusively within the remit of the independent members.

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