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Control mechanisms at the management level: Periodically, internal financial reporting audits are themselves audited to ensure they are effective. These high-level audits are signed off by ICL’s management and the auditor.
ICL maintains a Global Internal Audit (“IA”) unit which is responsible for performing internal audits at ICL’s companies worldwide. The IA unit operates according to acceptable internal audit standards and works according to a multi-year audit plan, which is updated based on a global risk assessment. The plan includes auditing compliance, operations, IT, HR, finance and other strategic projects at ICL. The IA unit reports to the Chairman of the Board of Directors and the Audit and Accounting Committee. All of the reports prepared by the IA unit are transmitted to the committee where material and cross-wide issues are discussed.
ICL operates a “Hotline” through which anyone- employees, contractors, customers, etc. can contact the Global IA and compliance units directly to report issues or events that they consider improper, problematic or deviating from the provisions of the law, procedures or the Code of Ethics. ICL published the opportunity to address the Hotline in various publications for employees and contractors (ethics oriented and others). ICL’s Hotline can also be reached directly from ICL’s public website. The Hotline is available in 18 different languages.
Complaints can be submitted anonymously so that employees, contractors and other stakeholders can act freely in identifying problematic issues. ICL’s Hotline is operated by a third-party vendor, under the auspices of the internal audit and compliance office and operates at ICL companies worldwide.
ICL has a Non-Retaliation policy, the company will not retaliate against any whistleblower regardless of the outcome of the investigation.
In 2021, the Company addressed 57 complaints. The complaints were addressed by different units in the company, including its Security, Compliance and IA and Contracted Employees Management units, and the data was consolidated by ICL’s Internal Audit unit.
ICL has implemented a global procedure to establish the requirements and process for handling complaints, including the specific workflow. The procedure includes guidance on how the complaint is received, reviewed, investigated and reported on. There is also a detailed explanation regarding what party needs to be held responsible, accountable, to be consulted with or informed.
ICL maintains global & regional compliance programs to ensure that the Company and its employees follow the provisions of the laws in the locations in which the Company operates, and in accordance with the Company’s policies and procedures.
These programs include Code of Ethics (which is comprised of anti-harassment & discrimination, hotline, and conflicts of interest, human rights), antitrust, securities, environmental protection, occupational health and safety, labor, anti-harassment (including sexual harassment), trade compliance, data privacy, building and construction, anti-bribery and corruption, anti-money laundering and fraud risk management.
Compliance programs are presented to ICL managers and employees on an ongoing basis. In some cases, there is a periodic assessment by external and internal entities to ensure that the programs are being implemented. A program manager is in charge of each program, and the Board of Directors of ICL and the GEC receive reports regarding their implementation throughout the Company.
IA refers to Ethical standards aspects in audits conducted annually at ICL sites and as part of dedicated reviews of processes, such as Sales & Marketing, Procurement, Contractors, and once every 3 years conducts a dedicated audit on different Ethical standards (e.g. Code of Ethics, Anti Bribery and Corruption, Anti-Harassment & Discrimination, etc.).
