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Code of Conduct and Regulatory Issues

During 2009 twenty disclosures were made under the Whistleblowing Policy, all of which were thoroughly investigated. No substance was found to the allegations in four of the cases. In another thirteen cases employees were dismissed and two resulted in resignations. One case is still under investigation.

During 2009, there were no reported environmental releases. Howden’s operation in Mexico City, Buffalo Forge SA, paid a fine of MXP 37.5k (GBP1.9k) following an audit by PROFEPA in September 2005. No other regulatory actions, fines or penalties were reported. PROFEPA’s citation contained two corrective actions, both relating to hazardous waste. One related to a permit requirement and the other to labeling of drums. Actions were taken to comply with these requirements and a follow-up audit by PROFEPA concluded the actions were satisfactory.

Pre-registration under REACH (EU Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals) was completed by 30 November 2008. Charter has been preparing to participate in Substance Information Exchange Forums (‘SIEFs’) as required. ESAB has been revising product warning labels and safety information sheets to prepare for REACH compliance.

Consultants have been retained to help develop a programme to comply with the UK’s new, legally binding, climate change and energy saving scheme, the Carbon Reduction Commitment, where Charter will be a full participant. Registration was completed on 24 August 2010.


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