Page 34 - Infinity Power Report

Infinity Power 2023 Sustainability Report
Creating an ethical
business culture
Managing socio-economic and
political risks requires everyone at
Infinity Power to remain vigilant and
to do their part to identify and
respond to potential ethics issues.
Our ethical business culture is guided by a robust
set of standards and policies, which ensures
everyone at Infinity Power knows what is expected
of them in acting with integrity. We go beyond
minimum and legal requirements and look to
international best practice frameworks to inform
our standards. This includes the UN Guiding
Principles on Business and Human Rights, the IFC
Performance Standards, the International Labour
Organization (ILO) Core Conventions, and the
Universal Declaration of Human Rights.
We have brought together the best policies and
standards from our founding companies to create
a robust approach at Infinity Power. Our ethics
framework includes our group code of conduct,
with supporting policies on anti-bribery and
corruption, anti-money laundering, screening
counterparties, and our whistleblowing (speak up)
policy. In 2023 we developed a group Ethics Toolkit
that brings together all our policies into one easy-
to-read document for staff, with worked examples
that bring the policies to life.
THE INFINITY POWER ETHICS TOOLKIT
INCLUDES:
• Infinity Power Code of Conduct
• Anti-Bribery and Corruption (ABAC)
Policy
• Anti-Money Laundering (AML) Policy
• Counterparty Screening Procedures
• Group Speak Up Policy
We are rolling out the new ethics toolkit this coming
year, with a full training programme planned for
2024, led by our legal and compliance team. Every
new joiner receives training on the code of conduct
and supporting polices, with a programme of
annual refresher training for existing employees.
We are investing in an online training portal to
improve our training and employee engagement
processes in 2024.
Our employees are encouraged to raise questions
and discuss any concerns on specific situations
with our legal and compliance team. Areas
of particular risk in our operating context and
industry include facilitation payments, gifts and
hospitality, and risks arising from working with
other businesses.
Our Speak Up helpline is independently operated
by a third party, is available 24/7 and free for
anyone to call and report a concern, including
our contractors, partners, suppliers and others.
We also have additional grievance mechanisms
in place for anyone from the local community
around our sites to raise a concern. There were no
ethics breaches reported for investigation in 2023.
While there were no calls to our Speak Up helpline
in 2023, we have a clear process in place to
investigate any whistleblowing reports. Any
reports to the helpline are investigated by our
legal team and any serious ethics breach would
be reviewed by an investigation committee
and escalated up to Board level for appropriate
response and disciplinary action.
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Managing bribery and
corruption risks
The location, industry and scale of our operations
brings potential bribery and corruption risks. We
have a strong approach to mitigate and manage
these risks and a zero-tolerance position on
bribery and any form of corruption. This is set
out clearly in our Anti-Bribery and Corruption
(ABAC) policy. Our policy goes beyond minimum
requirements and local laws and is modelled on
the strict standards in the UK Bribery Act.
Every Infinity Power employee receives mandatory
training on the policy during onboarding, and
receives periodic refresher training. Those in
particularly relevant roles such as in our legal
team, receive additional training.
Our ABAC approach and policy is also
communicated to all contractors, partners and
suppliers. With external associates, we carry
out an additional risk-based due diligence,
which may include assessment by external risk
consultants, to help identify risks of corruption or
political exposure. We also include contractual
protections in our counterparty agreements, as a
standard practice.