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Governance: Build a more Inclusive, Diverse and Engaged C&C

Global events in 2020, including the prominence of the Black Lives Matter movement, is creating an increased focus on strong diversity policies and fair employment practices.

Like other organisations which consider themselves wholly equitable and equal opportunities employers, we recognise the need for greater effort in these areas.

Diversity and Inclusion

C&C has introduced a Diversity, Inclusion and Wellbeing Policy across the Group, supplemented by shared learning resources. Diversity and Inclusion are a focus for our Executive Committee, who have received external coaching to support them in leading inclusion in a more meaningful way. To evolve our approach, we intend to understand more about the demographic and intersectional make up of our colleagues, their in-depth views on diversity and inclusion topics and evaluate the fairness of HR practices through improved insight. Understanding more about our colleagues and their views requires input from as many colleagues as possible and unfortunately plans have been delayed due to the majority of colleagues being out of work during COVID-19. This will be resumed in FY2022.

Employee Engagement Tracking

We view colleague engagement as the output of the relationship between colleagues and C&C Group, i.e. how they feel about their own experiences and interactions, as well as the culture and connection they feel with their respective business areas. We benchmark colleague engagement against other organisations and internally over time. Overall engagement improved during FY2021 within the Group and when compared to peers.

During FY2021, despite a high number of colleagues not being at work, we increased colleague engagement surveying across the Group to understand the impact of COVID-19. This included emphasis on C&C Group’s management of the situation, a greater focus on health and wellbeing, as well as support provided to colleagues.

Feedback has been used by business areas to understand what is working well, as well as where they could improve. COVID-19 has impacted different business areas in various ways and local action plans have been adopted in response to feedback received.

Communication, and a desire to understand more about the Group’s strategy, was a common focus across the Group. Within business areas, targeted action has included a focus on improving support for those balancing competing demands, such as home-schooling and providing the opportunity for informal learning for those working at home.

During FY2021, Non-Executive Directors increased their engagement with colleagues to better understand and represent their interests in the boardroom and extend their role in governing our corporate culture.

The approach also aimed to improve colleague experience and engagement, and the ‘Our Forum’ initiative (see page 64) was launched. When COVID-19 restrictions are eased, there will be greater in-person, including informal, interaction between NonExecutive Directors and colleagues across the Group.

Confidential Whistleblowing Helpline

C&C has an external, independently hosted and confidential hotline, where our people can share any concern or suspicion related to ethical or compliance related wrongdoing in the Group.

We use all our internal channels to encourage colleagues to raise their concerns on anything to do with how C&C is conducting its business and its adherence to our policies and codes. We constantly reassure colleagues that this is a safe and confidential way to raise concerns.

In FY2021, there were 35 instances of colleagues utilising our confidential whistleblowing hotline to raise concerns.

Human Rights

We do not condone and will not knowingly participate in any form of human exploitation, including slavery and people trafficking. We refuse to work with any suppliers or service providers who knowingly participate in such practices or who cannot demonstrate to us sufficient controls to ensure that such practices are not taking place in their supply chains. Our approach is reflected in our Sustainable and Ethical Procurement Policy, which we circulate to suppliers. We also carry out diligence audits and checks on our suppliers to ensure that they have in place and adhere to appropriate ethical policies including our Sustainable Ethical Procurement Policy, with KPIs for those areas where we believe the potential impact on the Group is material. A process is in place internally to address and remediate any instances of non-conformance with our Sustainable and Ethical Procurement Policy.

A copy of our Anti-Modern Slavery Statement is available HERE.

Anti-Bribery and Corruption

Our Anti-Bribery and Corruption Policy and accompanying training materials, referenced above in Embedding Key Codes, are designed to be straightforward and direct so that it is clear to all employees what they may or may not do as part of normal business transactions. The Policy applies to all colleagues in the Group equally. It is written to ensure that legitimate and honest business transactions can be distinguished from improper and dishonest transactions. This Policy and the accompanying training will be tracked as part of the internal audit monitoring process to monitor understanding and adherence to the Policy. KPIs have been established for those areas where we believe the potential impact on the Group is material. During FY2021, no incidences of bribery or corruption were uncovered across the Group.

Tax

The Group takes its responsibilities as a corporate citizen seriously. This includes respecting and complying with local tax laws and paying the required and appropriate levels of tax in the different countries where we operate. We claim the allowances and deductions that we are properly entitled to, for instance, on the investment and employment that we bring to our communities. We benefit from having always been an Irish company, established in the Republic of Ireland’s corporate tax environment, with our major cider production unit located in Clonmel and the Group is headquartered in Dublin. The majority of the Group’s profits are earned in the Republic of Ireland and the UK, which both have competitive corporation tax rates compared with the European average. In the Republic of Ireland and the UK, we remit substantial amounts of duty on alcohol production. The Company was grateful for the decision of the Irish Revenue and the HMRC to defer tax liabilities during the outbreak of COVID-19.

Protecting Customer and other Stakeholder Data

The Group’s wholly owned subsidiary, Matthew Clark Bibendum Limited (‘MCB’), became aware in April 2021 that it was the subject of a cyber-security incident, which impacted both Matthew Clark and Bibendum. MCB responded quickly, enacting its cyber-security response plan, and took steps to protect its IT systems. A eading forensic information technology firm and legal counsel were engaged to assist MCB investigate the incident and restore its IT systems as quickly and as safely as possible. The issue did not affect the IT systems of the wider C&C Group, which continued to operate as normal.s policies and processes.

The Group has a number of IT security controls in place including gateway firewalls, intrusion prevention systems, security incident monitoring and virus scanning. Regular communications are sent out to colleagues containing advice on IT security particularly in relation to home working. The Group’s approach is one of ongoing enhancement of controls as threats evolve with the target being to align controls, and in particular to implement any new services or changes to the environment.

The Group also has a suite of information security policies in place including Data Protection (‘GDPR’) and Electronic Information and Communications. The Group has enacted specific business continuity plans including co-ordination with key third party IT suppliers and consideration of keyman risk for the Group’s IT personnel.

We have implemented configuration changes to block phishing emails, increased awareness campaigns to help our people identify these types of attacks, and are identifying areas for further improvement in the development of our awareness campaigns.

The recent incident affecting Matthew Clark and Bibendum IT systems has emphasised the need for continued focus on information security. The Group has commenced a detailed review of its information security and cyber preparedness policies and processes.