At Drax, we are committed to conducting business ethically, with honesty and integrity, and in compliance with relevant laws and regulations. We do not tolerate any form of bribery, corruption, human rights abuse, or other unethical business conduct.
Drax Supplier Code
Click here to view the Drax Supplier Code of Conduct
Our Supplier Code sets out the commitments and standards we expect from our third parties, and any subcontractors they use, in relation to working for Drax. The Supplier Code, which was reviewed and updated in 2022, includes details of how any third party can ‘speak up’ about a concern over non-compliance with the Supplier Code.
During 2022, we continued to roll out our Supplier Code to relevant third-party suppliers, incorporating it into the associated contracts by means of specific business ethics clauses (including a termination clause for serious breach).
We take a risk-based approach to ethical due diligence, with appropriate suppliers being subject to the relevant checks prior to on-boarding. Our due diligence system enables the continual monitoring (i.e., in relation to international sanctions, regulatory enforcement action and as relevant, negative media) of suppliers during contract lifecycle. When concerning alerts are raised, they are investigated and, where appropriate, escalated to the Ethics Business Conduct Committee (EBCC) for consideration.
Our Framework
Our business ethics documentation framework consists of principles, policies, and guidance.
Our Business Ethics team takes steps to understand our risk profile. The team also works on developing, deploying, and maintaining the associated policies, procedures, awareness raising communications and training materials. In addition, the team monitors and evaluates compliance and investigates potential breaches of policy. Our Internal Audit function provides assurance on the robustness of our programmes. Our Anti Bribery and Corruption programme was the most recent to be audited (in September 2022).
Responsibility for Ethics and business conduct
Everybody at Drax is personally responsible for ethical business conduct. Managers are responsible for demonstrating leadership on ethical matters and supporting their teams to apply our ethical principles.
Our business ethics documentation framework consists of principles, policies, and guidance.
The Ethics and Business Conduct Committee (EBCC), a sub-committee of the Executive Committee, oversees our business ethics programmes.
The EBCC comprises senior leaders, meets quarterly, and was chaired by the Chief Financial Officer during 2022 until November, when the Group General Counsel formally assumed this role following ExCom approval.
The EBCC serves as an escalation route for higher risk ethical decisions, which is supported by an agreed Escalation Protocol. The Audit Committee provides an additional layer of oversight, receiving an annual summary on EBCC activity. It also receives quarterly updates on Speak Up reports.
Our Business Ethics team takes steps to understand our risk profile. The team also works on developing, deploying, and maintaining the associated policies, procedures, awareness raising communications and training materials. In addition, the team monitors and evaluates compliance and investigates potential breaches of policy. Our Internal Audit function provides assurance on the robustness of our programmes. Our Anti Bribery and Corruption programme was the most recent to be audited (in September 2022).
Anti-bribery and anti-corruption
We have a zero-tolerance approach to bribery and corruption. Our ABC programme is based on ‘Adequate Procedures’ guidance published by the UK Ministry of Justice and the EBCC oversees it (along with all other business ethics programmes). In 2022, our ABC programme was subject to internal audit, with controls deemed to be appropriate and working effectively to manage risks. This aligned to the internal risk assessment that was conducted in 2022. In 2023, we will be focused on addressing the due diligence related recommendations from the audit.
Fair competition
We are committed to conducting our business in accordance with all applicable fair competition laws and have adopted a zero-tolerance approach to any anticompetitive behaviour or activity. Our Fair Competition programme now covers UK competition law, US anti-trust law and Canadian laws, and includes mandatory e-learning for ‘at higher risk’ teams. During 2022 we engaged lawyers to provide an external risk assessment of the programme which they deemed as satisfactory (‘green’ traffic light rating).
Data privacy and security
The Data Protection team manages our Privacy programme. We take seriously the privacy and security of the personal data we control, working closely with our people, customers and third parties.
In 2022, the Data Protection team completed the annual review of policies and notices to confirm they remain in line with prevailing legal and regulatory requirements. The updates encompassed new jurisdictions where the group operates (i.e., Canada and Japan).
New system improvements were implemented to third-party onboarding for Data Protection and Information Security Due Diligence in the UK, with plans to roll out across other jurisdictions in 2023. These changes provide that contract assessments take place on the inclusion of the correct clauses supplied to the Procurement team. Other improvements include refresher training on data protection topics, improved working practices with the security function, and continued education within the Data Protection team.
Data Protection investigations into potential data breaches were investigated in a timely manner, with good support from operation teams. In some cases, timely resolution included sending a notification to relevant authorities if necessary (such as the Information Commissioners Office).
Individual rights requests from customers and employees were processed within required timescales, along with requests made by appropriate authorities (such as the Police).
Supply chain human rights
Drax has been a signatory of the UN Global Compact (UNGC) for five years and has embedded the ten principles of the Compact through our policies, culture, and ways of working. We also participate in the UNGC’s Modern Slavery Working Group.
We set out our human rights commitments in our Human Rights policy, the Drax Code, and our Supplier Code. Our Human Rights policy and codes are publicly available.
We have a long established cross departmental SCHR Working Group, which reports quarterly to the EBCC. You can find more detail about the activities of the Working Group in our Modern Slavery Statements.
Speak Up (whistleblowing)
We are committed to transparency, openness, and continuous improvement. We encourage those working for and on behalf of Drax, and our third parties, to raise genuine concerns (via our reporting channels) about practices that could breach laws, regulations, or our own ethical standards.
Drax has a zero tolerance of retaliation or victimisation. We have processes in place to apply appropriate consequences should an individual retaliate against, or victimise, a reporter in any way.
Of the reports raised (or carried over and closed out) in 2022 and considered by the Board, several related to safety standards and practices. Concerns were also raised about inclusivity and standards of behaviour.
Additional ethics and integrity data is available in our ESG Data Supplement
ESG Data Supplement 2022
Corporate Criminal Offences (CCO) (anti-facilitation of tax evasion)
Our ethical due diligence and payment procedures have been set up to facilitate the conduct of business which is compliant with applicable tax laws. These procedures are subject to regular internal audit. In 2022, we aligned our documentation for Canadian colleagues.
Financial and trade sanctions
Our ethical due diligence and contracting processes include the consideration of financial and trade sanctions risk. Risk-based monitoring of counterparties is also in place. An assessment of the Financial and Trade Sanctions policy programme in the second quarter of 2022 found the controls to be appropriate and working effectively.
There was heightened sanctions-related activity in 2022 due to the Russian invasion of Ukraine. The Financial and Trade Sanctions policy, coupled with the work of our Business Ethics and Legal teams, supported an effective response.
