There are two additional areas of focus for 2011

Bribery Act

The UK Bribery Act is expected to come into force during 2011.

During 2010, the Anti-Corruption Steering Group has been developing plans for its implementation during this year. This will include:

• Adapting all current policies to ensure compliance with the Act
• Communicating the detail and implications of the Act with employees and other affected parties
• Developing and implementing training programmes to ensure all relevant staff are aware of their obligations
• Establishing an independent, global whistle-blowing facility for reporting non-compliance
• Conducting a risk assessment of key countries and business units
• Developing the current audit processes and content to incorporate additional requirements of the Act

Human rights

Whilst the group already takes its responsibility for human rights extremely seriously and we are clear about our obligations and requirements at a business unit or service level, we recognise that it would be beneficial to have a more systematic, global approach to human rights due diligence.

During 2011 we will conduct a risk assessment based on the countries in which we operate and the services that we provide and develop a human rights framework and strategy for implementation across the group.