BT 2015 Annual Report Download - page 49

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Overview
The Strategic Report
Purpose and strategy Delivering our strategy
0ur lines of business Group performance Governance Financial statements Additional information
Changes over the last year Risk mitigation
ver the last ear we have seen reulator activit in a nuber of areas
which are suarised in Regulation on paes  and 9.
e have a tea of reulator specialists includin econoists and
accountants who toether with leal eperts and eternal advisers
continuousl onitor and review the scope for chanes in the reulator
rule set and potential disputes with other s. his tea aintains an
onoin dialoue with reulators and other e inuencers to understand
the reulator outloo and to ensure our positions are understood. e push
for fair proportionate consistent and evidenced-based reulation across
arets and urisdictions. e activel enae in supplin evidence and
analsis for all aret reviews chare controls and disputesinvestiations
to anae the riss arisin fro specific decisions in an iven ear.
e are also able to appeal an reulator decisions where we believe errors
have been ade. e will also raise disputes and coplaints under the
relevant reulator fraewor or copetition law where we face probles
ainin access to wholesale services  such as access to other networs or
towholesale pa- channels.
he iportance of conductin business ethicall is becoin increasinl
reconised across the lobe as ore countries pass anti-corruption and
briber leislation. n the UK deferred prosecution areeents are available
to the UK erious raud ce for fraud briber and other econoic
crie. n ters of enforceent there are et to be an sinificant cases
resultin fro the UK riber ct but there continue to be an sinificant
enforceent actions brouht under the .
e have a nuber of controls in place to address ris in this area.
heseinclude a coprehensive anti-corruption and briber prorae
andhea e or which is our stateent of business practice
and which is available in 1 lanuaes. e as all  eploees to sin
up to its principles and our anti-corruption and briber polic. e have
specific policies coverin ifts and hospitalit and charitable donations
and sponsorship. erun a trainin prorae with a particular focus on
rolessuch as those in procureent and sales.
e reularl assess our business interit riss to ae sure that the
appropriate itiation is in place. pea Up is our confidential hotline
which is operated b an eternal third part with all reports passed to the
irector of thics and opliance for review and investiation. ur internal
audit tea reularl runs checs on our business. e also use eternal
providers to carr out assessents in areas we believe to be hiher ris
to ensure our policies are understood and the controls are functionin.
eselectivel conduct due dilience checs on third parties includin
suppliers aents resellers and distributors. ur procureent contracts
include anti-corruption and briber clauses.
e have ipleented a polic to adhere to applicable sanctions and eport
control laws. he polic reuires approval on all contract bids involvin
a countr where sanctions are iposed b the U or the U. he polic
also andates that our internal shippin sste is used to arrane all
international eports. he sste conducts copliance checs and as
anorders which reuire an eport licence.