Reality Check: Protecting Every Point in EcoVadis Ethics

Did you know that the Ecovadis Ethics theme is one of the worst-performing ones? For some reason, companies struggle; maybe that's why you're here, too. This blog post serves as a checklist to ensure you cover all critical ethics uploads, including documented policies, actions, and results. I'll show you a real company example by reverse engineering how Scott Bader (chemicals) approaches the ethics theme through their anti-corruption policies, whistleblower policies, and other Ethics management system elements. We'll talk about the importance of whistleblower reporting, non-retaliation guarantees, ethics-training completion and many more specifics that impact your score. So grab a coffee, sit back and let's get to it.

Quick Navigation

• 1. Why Ethics Scores Stall
• 2. Policy Must‑Haves
• 3. Action Evidence
• 4. Result KPIs
• 5. EcoVadis in Reverse: Scott Bader
• 6. Common Rejections & Fast Fixes
• 7. Ethics FAQ
• 8. Download Full PDF
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1. Why Ethics Scores Stall

Understanding why Ethics scores sometimes falter is the first step to improvement. Often, it's not a lack of ethical intent but gaps in how this intent is formalised, implemented, and evidenced. EcoVadis requires clear proof of a mature ethics management system. Common reasons scores stall include:

• Policy Gaps: Missing core policies (e.g., Anti-Corruption, Whistleblower, Data Protection) or policies that aren't comprehensive (e.g., an anti-bribery policy that omits facilitation payments or conflicts of interest).
• Lack of Evidence for Actions: Policies exist, but there's no proof of their communication to employees, no records of relevant training, or no documentation of due diligence processes.
• Insufficient KPI Reporting: Failure to provide measurable results, such as training completion rates or whistleblower system activity, makes it difficult for EcoVadis to assess the effectiveness of your ethics programme.
• Superficial Systems: A grievance mechanism without a genuinely confidential hotline or a non-retaliation guarantee raises doubts about its effectiveness.

Essentially, EcoVadis assesses the maturity of your ethics framework. Stalled scores often point to systems that are either not fully developed or not adequately documented.

2. Policy Must‑Haves

Formal policies are the foundation of your ethics submission. They must be comprehensive, officially endorsed, and actively maintained.

• Anti-Corruption Policy / Code of Ethics:
  • What EcoVadis Wants: A formal policy, signed by an executive and version-controlled. It must address bribery (including facilitation payments), conflicts of interest, and fraud.
  • Why It's Crucial: Demonstrates top-level commitment and a structured approach to preventing corruption. Vague statements are insufficient.
  • Upload Evidence: The signed and dated policy document. Ensure it explicitly covers the mentioned areas.

• Whistleblower Policy:

  • What EcoVadis Wants: A policy detailing an anonymous reporting mechanism (e.g., hotline URL/phone number), an explicit non-retaliation clause, and confidentiality assurance.
  • Why It's Crucial: Fosters a culture of speaking up, thereby increasing the likelihood of identifying and preventing potential misconduct.
  • Upload Evidence: The policy document, along with clear evidence of the hotline's existence and accessibility (e.g., a screenshot of an intranet page, communication materials).

• Data Protection / Information Security Policy:

  • What EcoVadis Wants: A policy demonstrating alignment with recognised standards like GDPR or ISO 27001, covering data privacy, security measures, and breach response.
  • Why It's Crucial: Shows commitment to protecting sensitive company, customer, and employee data.
  • Upload Evidence: The signed and dated policy document. If the organisation is ISO 27001 certified, the certificate is key.

EcoVadis also looks for evidence that these policies are communicated to employees. This could be training records or screenshots of intranet communications.

3. Action Evidence

Policies must be translated into tangible actions. EcoVadis requires proof of implementation.

• Certifications & Audits:

  • What EcoVadis Wants: ISO 37001 (Anti-Bribery) or ISO 27001 (InfoSec) certificates. Alternatively, internal audit reports on ethics management systems, showing findings and corrective actions.
  • Why It's Crucial: Provides independent or structured internal validation of your systems.
  • Upload Evidence: Valid certificates or detailed internal audit reports with proof of corrective action closure.

• Corruption Risk Management:

  • What EcoVadis Wants: A documented corruption risk-assessment matrix specific to your operations, plus a mitigation plan.
  • Why It's Crucial: Demonstrates a proactive approach to identifying and managing specific ethical risks.
  • Upload Evidence: The risk assessment document and the corresponding mitigation plan.

• Third-Party Due Diligence:

  • What EcoVadis Wants: A formal procedure for ethical due diligence on third parties (suppliers, agents), and a sample completed checklist or assessment.
  • Why It's Crucial: Extends ethical oversight into your value chain.
  • Upload Evidence: Your documented procedure and a filled-out sample assessment.

4. Result KPIs

Measurable results and Key Performance Indicators (KPIs) demonstrate the effectiveness of your ethics programmes.

• Ethics Training Completion:

  • What EcoVadis Wants: Training completion statistics, especially for high-risk staff (target ≥90%).
  • Why It's Crucial: Shows active education of your workforce on ethical standards.
  • Upload Evidence: Training material, LMS reports, training attendance sheets, or summary statistics clearly showing completion rates for relevant employee groups.

• Whistleblower System Performance:

  • What EcoVadis Wants: A KPI table detailing the number of cases reported, substantiated, and resolved within a defined timeframe (e.g., <30 days). If claiming zero incidents, provide strong evidence of the hotline's existence and promotion.
  • Why It's Crucial: Indicates the system is active, trusted, and issues are addressed efficiently.
  • Upload Evidence: The KPI table. If zero incidents, include proof of hotline accessibility (screenshots, communications).

5. EcoVadis in Reverse: Scott Bader's approach to Corruption & Bribery

Analysing how companies approach corruption and bribery can provide valuable insights. Scott Bader, a global chemical company, has earned an EcoVadis Gold rating. Their public documents reveal a strong ethical framework, deeply rooted in their employee-owned model and comprehensive policies, suggesting a culture of sustainability where ethical conduct and responsible decision-making are foundational principles.

• Policy Evidence:
  • The Core Values, Guiding principles and the code of practice described in the Scott Bader Constitution emphasise acting ethically, respectfully, honestly, and with integrity.
  • The Whistleblowing Policy encourages reporting of concerns about fraud, misconduct, or wrongdoing. Key strengths include clear, Board-approved terms for confidentiality and non-retaliation, a regular review cadence, and a detailed procedure for the Whistleblower process.
  • The Modern Slavery Act Statement commits to acting ethically and with integrity in all business dealings, as well as zero tolerance for modern slavery.
  • The Ethical Purchasing Policy commits to maintaining the highest standard of integrity when building relationships with suppliers and rejecting any business practices that could reasonably be deemed improper.
  • The Supplier Partnership Manual explicitly states that Scott Bader does not tolerate any form of bribery and corruption and expects its supply partners to adhere to the same standards, complying with applicable legislation like the UK’s Bribery Act 2010.

• Action Evidence:

  • Robust Grievance Mechanism: Scott Bader ensures an accessible and credible reporting channel by operating an external anonymous hotline through "Safecall", which is available 24/7 in multiple languages. Using a third-party provider for such a hotline is often seen as a strength by EcoVadis, as it enhances anonymity and impartiality.
  • Targeted Training: Scott Bader conducts annual training on the Modern Slavery Act 2015 and other compliance topics. Their 2023 EESG Report confirms 95% completion for general compliance training, which includes ethics modules. Focusing training on high-risk roles and achieving high completion rates are strong indicators of effective ethics deployment.
  • Oversight of Ethical Risks: The explicit "Group" scope for core policies and the Modern Slavery Statement indicates a top-down, centralised approach to policy deployment, ensuring consistent standards across all entities and overseen through appropriate Committees indicates a formal process for monitoring and controlling potential conflicts of interest or undue influence, a positive sign for EcoVadis.
  • Scott Bader achieved full compliance with the QCA (Quoted Companies Alliance) Code in 2023, which promotes transparency and accountability.

• Results/KPIs:

  • Whistleblower System Effectiveness: Information in their Scott Bader EESG Report 2023 (page 44) demonstrates an active system. The report notes four reported incidents via Safecall in 2023, which were investigated. Showing data on reports, investigation rates (e.g., 100%), and timely resolution (within 28 days from the date of disclosure) provides tangible proof of an operational and effective system.
  • Training Impact: High training completion rates, such as 95% for "identified high-risk roles" or general compliance training, are a key KPI demonstrating commitment to embedding ethical awareness.

• Docs (Examples of publicly available documents that support these claims):

  • Scott Bader Constitution
  • Scott Bader Group Whistleblowing Policy PDF
  • Modern Slavery Act Statement
  • Ethical Purchasing Policy
  • Supplier Partnership Manual
  • Scott Bader EESG Report 2023 (see page 44 for Whisltleblower hotline KPI data)

Scott Bader – Key Ethics Wins

Learning from Scott Bader: Provide a stand-alone, Board-approved Whistleblowing Policy. Use an external hotline provider for credibility. Detail your training completion rates and whistleblower system KPIs. For EcoVadis, clearly defining the geographical and operational scope of policies and actions (e.g., "group-wide," "all manufacturing sites," "100% of procurement users") is critical. Companies should highlight how policies are translated into systematic programs, training, and communication across all relevant sites and employee groups, rather than merely stating the existence of policies.

6. Common Rejections & Fast Fixes

EcoVadis outlines several common reasons why Ethics submissions might be rejected or score poorly. Avoiding these is crucial:

Proactively addressing these points by ensuring comprehensive policies, robust implementation, and credible evidence will significantly strengthen your Ethics submission.

7. Ethics FAQ

8. Download Full PDF

To successfully navigate all four EcoVadis themes, comprehensive preparation is key. Download the EcoVadis Document Checklist for a complete overview of essential documents and common pitfalls across Environment, Labour & Human Rights, Ethics, and Sustainable Procurement.