Reckitt Benckiser Group plc 103-105 Bath Road, Slough, Berkshire SL1 3UH, United Kingdom
Tel: +44 (0) 1753 217 800 Fax: +44 (0) 1753 217 899 www.rb.com
Code of Business Conduct
Reckitt Benckiser is committed to responsible corporate behaviour; this includes high standards of
business conduct in our relationships with employees, contractors, customers, consumers,
shareholders, suppliers, governments, competitors and the local communities in which we operate.
1. Introduction
The purpose of this Code of Business Conduct (‘the Code’) is to ensure that employees and
contractors across the Group have a clear understanding of the principles and ethical values that the
Company wants to uphold. It applies to all employees and contractors in all Reckitt Benckiser
companies globally. Where the Company participates in joint ventures the Code’s standards should
also be actively promoted.
Compliance with the Code is an important factor in maintaining and building the reputation of Reckitt
Benckiser as a responsible and trustworthy business partner, employer, client, supplier and corporate
citizen.
The Code forms the core element of Reckitt Benckiser’s Corporate Responsibility Framework; this
comprises a set of policies and control arrangements that govern how we act as a Company and how
we interact with our stakeholders in conducting the Company’s business.
It is not possible to anticipate every situation. The Code is necessarily broad and general in nature and
is not intended to replace more detailed policies and procedures. Nevertheless, these basic principles
and ethical values should serve as a guide to each person in his or her dealings with consumers,
customers, suppliers, governments & regulators, shareholders, competitors, colleagues and others
with whom the company has relationships.
The Code of Business Conduct outlines the way the Company wants business conducted now and in
the future.
2. Ethical Business Conduct and Fair Dealing
All employees and contractors must accept responsibility for maintaining and enhancing the
Company’s reputation for integrity and fairness in its business dealings. In its everyday business
transactions the Company must be seen to be dealing even-handedly and honestly with all its
consumers, customers, suppliers, employees, contractors, governments & regulators and others with
whom the Company has a relationship.
3. Compliance with Laws, Regulations and Company
policies
General Principles
There are many laws and regulations applicable to the Company’s business. All employees and
contractors must be aware of and observe all laws and regulations governing their activities. Some
specific areas of legal and regulatory attention include: health & safety; anti-bribery laws, employment
and work place practices; protection of the environment; competition; intellectual property; and, the
payment of taxes and social security. Compliance with the Company’s internal operating policies and
procedures is of equal importance.
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Regulatory Compliance
The Company’s global operations include products that are highly regulated by local laws, regulations,
and government agencies. Failure to comply with local registration, manufacturing, sales, and
reporting obligations can expose the Company, individual employees, contracting firms and individual
contractors to significant penalties, including personal fines and imprisonment. All employees and
contractors are required to support the Company’s regulatory compliance obligations, which include
the appropriate reporting of adverse events.
Competition Law
It is Company policy that all Reckitt Benckiser companies and their employees and contractors comply
with the competition, antitrust and anti-monopoly laws of all countries in which they conduct Company
business. Directors, managers and others with supervisory responsibility have a duty to ensure that
employees and contractors under their supervision are aware of and comply with this policy. Violation
of this policy may subject the individual to disciplinary action, including dismissal and cessation of
contract. Severe civil, and in some cases criminal, penalties may be imposed on the Company and
the responsible employee or contractors if you authorise or participate in a violation of competition
laws.
Without limiting the general Company policy stated above, there are several specific guidelines that
apply to all Reckitt Benckiser colleagues (employees and contractors) in every country:
• Reckitt Benckiser colleagues do not share non-public price information or sensitive product
information with competitors under any circumstances. Reckitt Benckiser colleagues also strive to
ensure that such information is not indirectly shared with competitors, whether purposefully or
inadvertently, through third parties.
• Reckitt Benckiser, as well at its customers and consumers, benefit from a competitive market in
which all companies are able to fairly present their product and benefits in the market. Reckitt
Benckiser competes actively in this marketplace, but Reckitt Benckiser will not use its market
position to illegal prohibit the legitimate activity of a competitor.
Anti-Bribery
It is Company policy that all Reckitt Benckiser companies and their employees and contractors comply
with the anti-bribery/anti-corruption laws of the UK and all countries in which they conduct Company
business. Directors, managers and others with supervisory responsibility have a duty to ensure that
employees and contractors under their supervision are aware of and comply with this policy. Violation
of this policy may subject the individual to disciplinary action, including dismissal and cessation of
contract. Severe civil, and in some cases criminal, penalties may be imposed on the Company and
the responsible employee or contractors if you authorise or participate in a violation of anti-bribery
laws. Employees and contractors must read the Company’s Anti-Bribery Policy and associated
documents.
4. Employees & Contractors
Working conditions - the Company believes the human rights at work of its employees and
contractors are an absolute and universal requirement (see Human Rights below). Reckitt Benckiser
subscribes to the International Labour Organisation’s (ILO) Fundamental Conventions (no forced
labour, no child labour, freedom of association and no discrimination); and the Organisation for
Economic Co-operation and Development’s (OECD’s) Guidelines for Multinational Enterprises.
Equal opportunities / no discrimination - in employment related matters (including recruitment,
access to training and promotion, transfers, employment termination, discipline, compensation and
benefits), decisions are made on the basis of the qualifications, performance record and abilities
needed for the work to be undertaken, and relevant business circumstances. The Company is
committed to equal opportunities at work and in the work place; colleagues should not engage in or
support discrimination based on race, colour, language, caste, national origin, indigenous status,
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religion, disability, gender, marital status, sexual orientation, union membership, political affiliation, or
age.
Working environment and occupational health & safety - the Company is committed to providing a
safe and healthy working environment and to assuring, so far as is reasonably practicable, the health,
safety and welfare at work of its colleagues.
The Company’s Occupational Health & Safety (OHS) Policy and objectives are publicly available and
a Group Occupational Health & Safety Management System (OHSMS) is in place to coordinate the
management of occupational health & safety across the Company. Employees and contractors have a
duty to take reasonable care for their own health & safety and that of others who may be affected by
their acts or omissions. Employees and contractors must use all work items provided by the Company
correctly; in accordance with their training and the instructions they received to use them safely.
Colleague Communication - the Company is committed to providing timely and effective
communication with its colleagues.
5. Conflicts of Interest
Employees and contractors must avoid situations where their personal interests might, or might
appear to be, in conflict with the interests of the Company. In particular, employees may not exploit
knowledge or information gained from employment within the Company or take advantage of a
corporate opportunity in order to obtain a personal gain or benefit for themselves, family members or
any other connected person.
Any situation which gives rise, or might give rise to a conflict of interest should be disclosed as soon
as it arises and, where required, written authority to proceed should be sought from the Company.
Examples of situations where conflicts of interest may arise and the principles that should be applied
include, but are not limited to, the following:
Outside engagements - employees of the Company should not undertake any other business or
profession, be an employee or agent of any other company, or have any financial interest in any other
business or profession, other than: non-executive positions approved by the Company; community
voluntary activities; and, bona fide investment holdings of shares or other securities in entities that are
not direct competitors of the Company, or minor holdings in competitors. Any exceptions to this
requirement, which could for example apply to a part-time employee, must be approved by the
Company.
Dealings with related parties - employees and contractors should not enter into any business
dealings on behalf of the Company with a family member, any business controlled by a family member
or any other connected person with whom business dealings may result in a potential conflict of
interest without first disclosing this to the Company and obtaining approval.
Insider trading - employees and contractors in possession of information on the basis of which an
effect on the Company’s securities may reasonably be predicted, may not trade in any of the
Company’s securities as long as they could take advantage of such sensitive information. Additional
trading restrictions exist for senior executives during the two months prior to publication of the year-
end results and for one month prior to the publication of quarterly results, and at other times indicated
by the Executive Committee when the Company may be deemed to be in receipt of insider
information.
Gifts and entertainment - employees and contractors of the Company must ensure that they deal
with customers, suppliers and other business relationships in a way that avoids their independent
judgement on behalf of the Company being influenced by personal advantage, or any appearance that
this may be the case. Local Company entities shall have in place specific rules governing gifts and
entertainment, which reflects and is consistent with this Code and the Company’s Anti-Bribery policy
In no instance, however, will any local policy conflict with the goals of this Code.
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6. Suppliers and their Contractors
The Company is committed to proactively encouraging its suppliers and contractors to demonstrate
responsible business behaviour and high standards of business conduct. This commitment is
presently focussed on direct suppliers involved in the manufacture, assembly or distribution of
products on behalf of Reckitt Benckiser Group companies, and on those suppliers’ contractors who
are actively engaged in work at Company facilities.
The Company’s Global Manufacturing Standard sets out minimum levels of performance and
performance expectations in the areas of working conditions / human rights at work, occupational
health & safety and environmental management, for all suppliers manufacturing, assembling or
distributing products on behalf of Reckitt Benckiser Group companies.
The Company’s environmental and occupational health & safety management systems include in
their scope the activities of suppliers and contractors who are actively engaged in work at Company
facilities.
7. Sustainability and the Environment
Reckitt Benckiser views corporate responsibility and sustainability as one and the same and is
committed to moving its business towards greater sustainability across the economic, social and
environmental dimensions of its activities. The Company believes that a more sustainable business
will not only better fulfil our responsibilities to society but also contribute to delivering our vision of
better consumer solutions and greater long-term shareholder value.
The Company's Environmental Policy and objectives are publicly available and a Group Environmental
Management System (EMS) is in place to coordinate environmental management across the
Company.
8. Company Assets
Protecting Company assets - employees and contractors are responsible for the proper use, the
protection and the maintaining of company assets, including intellectual property (e.g. patents,
trademarks and designs). Company assets may only be used in relation to the Company’s business.
Authorities - the existence of an agreed authorities structure is an essential requirement for
establishing an effective financial and operational control environment. All business units are required
to establish and maintain appropriate levels of authority to cover all items of asset value / expenditure
and all transactions which need to be subject to management approval.
Integrity of company financial records - the books and records of the Company must accurately
reflect the nature of the underlying transactions and no undisclosed or unrecorded liabilities or assets
shall be established or maintained. Books and records must be maintained in all respects according to
law and the accounting principles, policies and procedures that the Company has adopted. The
Company will not evade tax obligations and all taxable benefits which employees may receive will be
listed and declared for tax purposes.
Protecting confidential information - employees and contractors must ensure that confidential
information is preserved and protected. Confidential information is that which is not generally known
outside the organisation and either gives or could give the Company a competitive advantage or
disadvantage, or could lead to the loss of an existing competitive advantage, if it became known to
others or became known in the public domain. This kind of information may not be revealed to anyone
outside of the organisation unless an appropriate confidentiality agreement is in place and such
disclosure is necessary for business purposes. Employees and contractors are required to respect
these confidentiality provisions even after their employment with the Company comes to an end.
9. Other Issues
Product safety and quality - the Company is committed to delivering quality products to its
customers and consumers that are safe when used as directed for their intended purpose. We believe
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that this is implicit in our Company Vision and fundamental to our brands, our business and our long-
term success. The Company has in place:
• a Product Safety Policy, and comprehensive control arrangements including our Global
Ingredients Guidelines, to fulfil our commitment to developing and marketing products that can be
manufactured and used safely as directed.
• a Quality Policy, and Group / site-level Quality Management Systems (QMS), to control the quality
of our products.
Human rights - the Company believes that human rights are an absolute and universal standard. The
Company subscribes to the United Nations Universal Declaration of Human Rights and the
Convention on the Rights of the Child. In countries where the Company is present, we will aim to
support progress on human rights issues in accordance with what reasonably can be expected from a
commercial organisation.
Political activities - the Company is not a political organisation. It neither supports political parties nor
contributes to the funds of groups whose activities are calculated to promote party interests or the
election of a specific candidate. In some limited instances, where permitted by local law and
regulation and specifically approved by the General Manager, the Company may contribute funds
toward organizations or entities that engage in the political process to address an issue that directly
affects the Company and its business activity.
Privacy - the Company respects the privacy of its employees, contractors and consumers and it will
exercise appropriate and due care to legally ensure that sensitive personal information about
employees, contractors and customers is not publicly disclosed.
10. Compliance with this Code
All employees and contractors are required to comply with this Code of Business Conduct and are
personally responsible for doing so. It is the responsibility of the Board of Reckitt Benckiser to ensure,
so far as is reasonably practicable, that the principles and ethical values embodied in this Code are
communicated to all colleagues of the Company.
Employees and contractors must comply with any rules set out in this Code of Conduct. Breach of
any of the principles within the Code may result in disciplinary action, and a serious breach – such as
if an employee or contractor is found to be in wanton abuse of the code and their actions cause
reputational risk or damage and/or financial loss to the business – may amount to gross misconduct,
which may result in summary dismissal and contract cessation. Fines to a company or part of a
company within the group will impact on the P&L and performance payments of that business. In
addition, the Company reserves the right to seek redress and damages from the individual(s) who has
been found to have breached the code of conduct, irrespective of the position and location the
individual(s) might hold, in or out of the company, at the time the breach of this Code comes to light.
Employees and Contractors at all levels will be required to certify, annually, that they understand the
code and that they (and those they supervise who do not have a Company email address) are in full
compliance with this Code for the operations for which they have responsibility. On an annual basis
by Internal Audit, the Board monitors the findings of this certification. Those who do not have a
Company email address will have the Code communicated to them. Those that supervise these
colleague groups will be required to sign that these groups are in full compliance with the code.
The Board of Reckitt Benckiser will not criticise management for any loss of business resulting from
adherence to this Code. The Company undertakes that no employee or contractor will suffer as a
consequence of bringing to the attention of the Board or senior management a known or suspected
breach of this Code nor will any employee or contractors suffer any adverse employment or contract
decision for abiding by this Code.
Reckitt Benckiser has in place a confidential “whistle blower” policy and process, communicated
globally, to encourage the reporting of any non-compliance with this Code of Business Conduct. If in
any doubt, employees and contractors can obtain full information on this process from the local
Human Resources and Legal departments. Whenever needed, the Company provides a confidential
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“whistle blower” hotline that employees and contractors anywhere in the world may use to report any
violation of this code, as well as any violation of any local law or regulation or any unethical behaviour.
11. Commitments to International Standards
Reckitt Benckiser subscribes to a number of international standards and guidelines relevant to
corporate responsibility and business conduct, including: • the United Nations (UN) Declaration of
Human Rights (www.un.org); the United Nations (UN) Convention on the Rights of the Child
(www.un.org); the International Labour Organisation (ILO) eight Fundamental Conventions
(www.ilo.org); the Organisation for Economic Co-operation and Development (OECD) Guidelines for
Multinational Enterprises (www.oecd.org)
The principles and requirements of these standards and guidelines are incorporated into this Code of
Business Conduct and policies that support it are available for review in the House Rules section of
the Company intranet “The Biz”, or from the HR, legal or corporate communication and affairs
department. Combined this code and supporting policies comprise our Corporate Responsibility
Framework.
Rakesh Kapoor
Chief Executive Officer
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