Today’s complex business environment demands that we firmly embed integrity in our values, our culture and our daily business practices. Integrity means that we always work to the highest professional and ethical standards and establish trust by being transparent, honest and responsible. Integrity is a fulfilment of our high standards of responsibility to our clients, shareholders, business partners and our people, the public, and to governments and the laws and culture of the countries in which we operate. The Arcadis General Business Principles (AGBP) further define our interpretation of business ethics and form our Code of Conduct. The AGBP have been developed by global leadership at Arcadis and set guidance for our business decisions and actions throughout the world at all levels and apply equally to company actions and to individual behavior of all our employees in conducting Arcadis’ business. Arcadis recognizes that true integrity in our daily business will be underpinned by the commitment to the principles of the AGBP of our employees and the third parties we do business with.
Arcadis acknowledges that the ultimate responsibility for the implementation and application of the AGBP lies with the Arcadis Executive Board and the primary responsibility with the operating entities (first line of defense). The Corporate Compliance Committee is composed of the Global General Counsel, the Chief People Officer (member of the Executive Leadership Team) as well as the Global Compliance Officer. The Global Compliance Officer reports on AGBP integrity, compliance and related (alleged) issues to the Corporate Compliance Committee, to the CEO of Arcadis and the Arcadis Audit and Risk Committee of the Supervisory Board (AARC) or directly to the Supervisory Board. At Regional level the Compliance function is composed of a Compliance Officer and a Compliance Committee. Each Compliance Committee includes the Compliance Officer as well as Legal and Human Resource/People expertise. The Compliance function is the second line of defense that assists and supports the first line of defense with identification and analysis of key Regulatory & Policy Compliance risks, trend spotting, mitigation of compliance risks through the introduction of policies, standards, procedures, and guidelines, providing training and awareness and with periodic assessment of the effectiveness of the risk mitigating controls.
The Internal Audit function provides the third line of defense and the priorities for Internal Audit are defined in an annual audit plan which could include AGBP integrity or compliance related risks. Anti-Corruption Specific Anti-Corruption Standards (SACS) provide specific guidelines related to gifts, hospitality and payments to third parties. Arcadis has embedded its commitment to the UN Global Compact principle on anti-corruption by referencing the SACS in the AGBP. Targeted anti-corruption training sessions by leadership and by Compliance Officers were held in various regions and countries throughout the year, tailored to local laws and regulations.
Dealing with dilemmas
The AGBP cannot anticipate the array of dilemmas we may face in our day-to-day operations in each jurisdiction and sector in which we operate. An active policy in this area means recognizing dilemmas and taking responsibility for resolving them. Arcadis encourages its employees to recognize and discuss business dilemmas with each other and with their management, to make integrity an integral part of our culture. Real life AGBP related scenarios are worked into anonymized dilemmas which are fed back into the business via training to raise awareness and ensure lessons learned are impactful and effective.
Value for customers
We are a reliable partner for our clients and aim to deliver our services without jeopardizing stakeholder interests. We offer services under terms that do not compromise our independent professional judgment and aim to create value for clients. We are transparent with clients about conflicts of interest that could emerge during the execution of our services.
Responsible employment practices
Arcadis employees are key to its success, and we respect human and labor rights so that our employees may work in a safe, healthy, professional and supportive environment. We encourage engagement and support personal development through comprehensive policies and initiatives. Every Arcadis employee has an equal opportunity for personal recognition, advancement, career development and compensation, regardless of background or beliefs. No form of discrimination is tolerated. The human and labor rights policy has been updated in 2021 and applies equally to recruitment, our supply chains and procurement.
The policy is supported by a three-year Human Rights Roadmap to drive implementation. This policy lays out our ambitions aligned with global expectations for our own operations, our supply chains, including procurement, and for the project work we do for clients.
Monitoring and accountability
Arcadis requires all employees to understand, sign off on and comply with the AGBP and SACS every other year when Arcadis employees complete online training aimed at increasing awareness of our AGBP and values. This training specifically addresses issues like corruption, bribery, conflicts of interest, anti-competitive practices, and other risks to which our people may be exposed. It was rolled out in November 2020 and made available in 16 languages. Employees that join Arcadis must successfully pass the AGBP training within 30 days of joining. In 2021, a total of 94% of all employees passed the AGBP training1. The next round of integrity training for all our employees will be organized in 2022.
Arcadis monitors compliance with the AGBP in all operating companies on a quarterly basis through reporting on AGBP (alleged) issues and mid-year reporting on progress against the annually established Global Integrity & Anti-Corruption Program. In addition, management of all operating companies certify compliance and the effectiveness of global controls relating to the Arcadis Risk Category of Regulatory & Policy Compliance through an annual Document of Representation.
Arcadis has a reporting procedure which includes an anonymous global Integrity Line managed by a third party for the event people are uncomfortable reporting through their line manager or further in the line, to their Compliance Officer or the relevant Compliance Committee. The Integrity Line is available to our employees 24 hours/7 days a week in 16 languages. Reports of potential or suspected misconduct or other AGBP issues can be made in native languages.
1. Employees who onboarded during the month of December or are on long term leave of absence on 31 December, possibly have not yet passed the AGBP training and test by 31 December. As a consequence, it is likely that Arcadis will not be able to reach a 100% success rate on 31 December of the relevant reporting year.
In 2021, a total number of 91 alleged breaches of the AGBP were reported through the various reporting channels, including to the Arcadis Corporate Compliance Committee (2020: 72). All alleged breaches were assessed and, where necessary, further investigated or advised upon, except for 24 alleged breaches that are still being assessed or, where necessary, investigated. In addition, there were 5 reports of alleged breaches from before 2021 which were still being assessed or, where necessary, investigated during the year. Inappropriate behavior (employment-related) was the category with the most reported issues.
There were no confirmed corruption or bribery incidents in 2021 based on our assessment and/or investigation. Violation of the AGBP may lead to sanctions, up to and including termination of employment. Company-wide Arcadis had 13 dismissals on grounds related to breaches of the AGBP. Arcadis will not hold employees accountable for any loss of business resulting from compliance with the AGBP and its reporting requirements Arcadis has also introduced a reporting procedure available for its external stakeholders (suppliers, clients and other third parties) to report any concerns they may have that the AGBP and/or related policies are being breached. This procedure includes an anonymous global Integrity Line managed by a third party.
This anonymous external Integrity Line is available 24 hours/7 days for the event our stakeholders are uncomfortable raising a concern or reporting suspected misconduct or irregularities related to the cooperation with Arcadis directly with their contact person within Arcadis. The availability of Arcadis’ External Integrity Line also ensures our compliance with new regulatory requirements (incl. the EU Whistleblower Directive) and UN Guiding Principles for Business and Human Rights. Reporting can be made in native languages and can be accessed through local telephone numbers or the internet.
Arcadis has also a reporting procedure available for its stakeholders to share any concerns they may have that the General Business Principles and related Policies such as the Specific Anti-Corruption Standards, the Sustainability Policy, the Human Rights and Labor Policy, and the Procurement Policy is being breached. This procedure includes an anonymous global Integrity Line managed by a third party. This Arcadis Integrity Line is available 24 hours/7 days for the event our stakeholders are uncomfortable raising a concern or reporting suspected misconduct or irregularities related to the cooperation with Arcadis directly with their contact person within Arcadis. Reporting can be made in native languages and can be accessed through local telephone numbers or the internet.
Last updated: 12 April 2022