Employees and contractors have a duty to alert us (in confidence and, if preferred, anonymously) to any actual or potential breach of our Business Principles, Policies, Standards or legislation, using Speak Up – an independent telephone and online reporting service. This facility is available to anyone who wishes to make a report.

During 2011, 134 cases were reported under the Speak Up facility (2010: 151 cases). Each reported case is investigated or overseen by the ECCU.

More detail about the cases is given below:

• 38% related to reported malpractice (including allegations of breaches of the Group’s Ethical Conduct Policy and Standards, including corruption);
• 33% related to general workplace concerns (including allegations of harassment, discrimination, unfair hiring practices and unfair treatment);
• 19% related to fraud (including allegations of theft or misuse of funds); and
• 10% related to health, safety, security and the environment.

We take any breaches of our Business Principles very seriously. Investigations into 28 cases in the year resulted in actions against individuals, employees or contractors, ranging from training or disciplinary action (from formal warnings up to and including dismissal) to contract termination or other appropriate action. 37 other cases resulted in actions such as changes to procedures and to organisational controls.