Governance and Integrity

As one of our core values, integrity is reflected in the company’s culture of ethical behavior.  We conduct business activities in a large number of jurisdictions across the world and operate in a wide range of legal and business environments.  Our commitment to integrity ensures that consistently high standards are maintained.

Element is committed to conducting business in an ethical manner. With customers in diverse markets worldwide, it is essential that we conduct our business with the highest standards of integrity and adhere to international laws and regulations.   We are an equal opportunities employer and promote a working environment free from any form of discrimination, bias or harassment, no matter where in the world we are located.

Element has in place the necessary governance and organizational structures to provide appropriate levels of oversight in audits, risk management and potential conflicts of interest.  This is supported by a Group Internal Audit Director who heads a dedicated internal audit function which has significantly enhanced the review and governance of our operations.  We have established policies that underpin our values and reflect our commitment to conducting business with honesty and integrity wherever we operate.  These policies range from anti-bribery and corruption to trade compliance and whistleblowing.  Policies are widely communicated to all colleagues and reinforced through targeted programs and training, as required, to ensure they are understood and adopted.

Element is a member of the TIC Council, an international association representing independent testing, inspection and certification companies. Element was accepted as a member of the TIC Council with effect from 1 October 2020. Members of the TIC Council must implement and abide by the TIC Council Compliance Code (First edition) issued by the TIC Council in December 2018.

Element is committed to meeting the obligations that are laid down by the TIC Council and our Compliance Program reflects the requirements of the TIC Council Compliance Code:

• Integrity – to act in a professional, independent and impartial manner in all activities.
• Conflicts of Interest – to avoid actual, potential or perceived conflicts of interest. 
• Confidentiality and data protection – to respect the confidentiality and privacy of client information. 
• Anti-bribery - a zero tolerance approach to bribery and corruption in all business dealings and relationships. 
• Competition and Fair Business Conduct - to comply with all rules relating to fair competition, anti-trust and tendering.
• Health and Safety - to protect the health and safety of colleagues, customers and third parties. 
• Fair Labour - a zero tolerance approach to abuse, bullying or harassment in the workplace. Equal opportunities in the workplace, compliance with minimum wage legislation and prohibition of forced and compulsory labour.

Element has established a wide range of policies, procedures and guidelines which set out how we operate - what is expected of our people, and what they can expect from Element in return. They are regularly updated and routinely communicated to colleagues. The principal policies, procedures and guidelines have been brought together in an overarching Code of Conduct, which reflects our commitment to conducting business with honesty and integrity wherever we operate.

Element is committed to ensuring that our people are treated in accordance with the Universal Declaration of Human Rights and the UN Global Compact’s ten principles. We seek to prohibit forced, compulsory and underage labor and any form of discrimination based on race, gender, religion, age, disability, the right to collective bargaining or political affiliation.  Our Modern Slavery Policy states that Element has a zero tolerance approach to Modern Slavery and that the following principles apply to our business and supply chain:

• child labor must not be used;
• any form of forced or compulsory labor must not be used;
• passports, visas and other personal documentation should not be taken from employees unless requested to be held by the employee for safekeeping purposes;
• all forms of debt bondage are prohibited;
• compensation and benefits must comply with local laws relating to minimum wages, overtime hours and other benefits; and
• the formation of trade unions and powers of collective bargaining should be respected. 

As required by the Modern Slavery Act 2015, Element publishes a Modern Slavery transparency statement which sets out our approach to preventing Modern Slavery within Element's business and supply chain.

Element is committed to conducting business to the highest possible ethical and business standards. We have therefore adopted a Supplier Code of Conduct setting out the behavior and principles that we expect our suppliers to follow. Suppliers of goods and services, contractors, joint venture partners, consultants, advisers and all other third parties engaged by Element are expected to adhere to the principles set out in this Supplier Code of Conduct and are encouraged to develop their own codes, policies and procedures to adhere to the principles of this Supplier Code of Conduct.

We provide a confidential whistleblower service, which is managed by a specialist third party provider, across our global business, giving all colleagues and third parties the opportunity to raise concerns. The service encompasses a telephone hotline, email and web-based reporting facility and is available in relevant languages in all countries in which Element has a presence.   This service may be used to report incidents of wrongdoing including fraud, bribery & corruption, discrimination, bullying or harassment, supplier labor practices, modern slavery, tax evasion, breach of competition laws, health, safety and quality matters and environmental concerns. Any whistleblowing reports are reviewed and investigated appropriately.

Section 172 of the Companies Act 2006 (the “Act”) sets out the directors’ duty to promote the success of the company. In accordance with the Act and the Companies (Miscellaneous Reporting) Regulations 2018, qualifying companies are required to include a statement in the strategic report of their annual report and accounts which describes how their directors have had regard to the matters set out in section 172 of the Act (the “Section 172 Statement”).

The Section 172 Statement of Element Materials Technology Group Limited and its subsidiaries that also meet the qualifying criteria to publish a Section 172 Statement can be found below.

Element Materials Technology Group Limited - Financial Year 2019

Page 33 of the Annual Report 2019 and Consolidated Financial Statements (View PDF filed at Companies House)

Warringtonfire Testing and Certification Limited - Financial Year 2019

Page 2 of the 2019 Annual Report and Financial Statements (View PDF filed at Companies House) 

Element Materials Technology Environmental UK Limited  - Financial Year 2019

Page 2 of the 2019 Annual Report and Financial Statements (View PDF filed at Companies House)