Compliance with the Combined Code is just the start. Our own Code of Corporate Responsibility and Business Ethics defines how we do business. When the Code was communicated to employees, the Chief Executive, Keith Butler-Wheelhouse said: "We need to ensure that all Smiths employees throughout the organisation have a clear understanding of how the Company expects them to behave." He went on to make his point as follows: "…all our stakeholders – owners, customers, suppliers and communities – have high expectations of us. These need to be anticipated and satisfied."

Implementing the Code
Translated into 13 languages, the Code applies to all Smiths businesses and employees worldwide and provides the framework for policies, programmes and procedures for a range of corporate responsibility issues.

The Code is set by the Board and monitored by the Code Compliance Council, chaired by the General Counsel. The Council includes senior corporate directors for Human Resources, Communications, Internal Audit and Legal, and meets at least three times a year. Two representatives of the Council, General Counsel and the Director of Ethics and Compliance, brief the Audit Committee at regular intervals on how the Code is being implemented across Smiths.

We provide communication and training to all levels of management to reinforce the general principles of the Code and the policies and procedures that support it. All managers are measured on their understanding and support of the Code's principles as part of their annual appraisal process.

Communicating with employees
We communicate the Code and its importance for how we operate to every employee. All new employees are given training on the guiding principles and the importance of the Code to Smiths, including explaining potential disciplinary action for violating specific principles, policies or procedures.

The Code and corporate policies are available to employees on the Smiths intranet, and externally on the Group website, www.smiths.com. Legal representatives across Smiths host monthly internal web conferences, publish legal and compliance bulletins, and host other conferences and seminars. Our internal legal and compliance website includes additional training materials and links to external sources and materials to support the process.

The Code is not a static or lifeless document. All Smiths employees have access to an Ethics Helpline via telephone or email to raise any concerns or questions in confidence. These receive immediate attention, and any allegations of impropriety, whether made anonymously or openly, are investigated promptly. If appropriate, we report back to the employee who raised the issue. We maintain statistics for the categories of calls and how they were resolved, and these are reported annually to the Audit Committee of the Board.

Managing specific issues
Responsibility for managing specific corporate responsibility issues lies at different levels within the Group, depending on the nature of the issue and how it can most effectively be managed. Nonetheless we are committed to sharing best practice, not only within Smiths but also with our customers and suppliers.

• Environment issues are managed through a Group-wide steering committee and organisation.
• Health and safety issues are managed through the same committee.
• Employee issues are managed by line management and the Human Resources function.
• Supplier and customer programmes are managed divisionally.
• Community programmes are principally managed locally, with additional Group-level activity.