Policy of Business Conduct
As Covanta’s business continues to evolve, we know our ability to succeed and prosper will depend on strong governance procedures supported by the quality and character of our employees. Covanta’s Policy of Business Conduct, available to employees on the company website and intranet site, outlines the company’s expectations for the highest standards of personal integrity and professional judgment from all employees. Annually, each employee is required to review the policy, certify compliance for the prior year and commit to compliance in the coming year.
We put our vision and values into action through the following policies, which govern our business practices:
- Covanta Mission Statement and Environmental Policy
- Total Health and Safety Policy
- Policy of Business Conduct
- Sustainability Policy
- Community Outreach and Environmental Justice Policy
Covanta’s complete governance information, structure, annual filings and related charters can be found on the Investor Relations home page.
We encourage the reporting of concerns about Covanta or its employees, as detailed in our Policy of Business Conduct. Employees and others may report concerns, all of which are investigated, through an anonymous third-party hotline.
Protecting our digital information is crucial for our business operations. Led by our Chief Information Security Officer (CISO), our information technology team has developed cybersecurity policies and procedures that apply to all Covanta employees. Our Cybersecurity Awareness Training includes full security awareness training (mandatory for new hires), monthly optional microlearning videos, and simulated phishing campaigns. We have had zero breaches of information security in more than three years as of September 2021.
Supply Chain Management
Our supply chain is a strategic component of our business. We continually seek ways to improve our performance, reduce costs and ensure that we are working with a diverse base of responsible global suppliers that meet our high standards for conduct and performance.
In addition to cost-competitiveness and core competency in their business, we seek suppliers that promote a positive workplace culture characterized by long-term partnerships and sustainable solutions. The companies with which we partner support minority, women, and disabled veterans’ business enterprises.
We expect our suppliers to uphold Covanta’s Supplier Code of Conduct, which outlines our expectations of all our suppliers. We require suppliers to complete a detailed supplier qualification questionnaire and provide supporting documentation. Supplier responses are assessed according to the following categories:
- Company management
- Corporate social responsibility (including confirmation of appropriate environmental, social and governance controls)
- Product/process design
- Operational excellence
- Continuous improvement
The corporate social responsibility category includes, but is not limited to:
- Legal cases involving corruption or bribery
- Safety & health performance
- Environmental compliance
- Policy for business ethics
- Demonstration of a process to ensure compliance with internationally recognized human rights standards, including those pertaining to child labor
- Inclusion of environmental, health and safety and social requirements in subcontractor agreements
We review all new suppliers and repeat the process every two years for existing supplier relationships. We may use the assessment results to identify areas for improvement and develop and monitor progress against action plans.
Supplier quality assurance and control are critical for the success of our business. Our facilities rely on high-quality workmanship and materials to ensure proper operation, compliance with environmental standards, and reliability. We employ a risk-based approach to supplier QA/QC, focusing efforts on those suppliers that, either due to the volume or type of service supplied, carry high risk to our operations. Depending on the specific situation, we may require product quality testing, QA/QC plans, calibration records, and site visits to ensure quality standards are met.
We also focus on ethics and compliance through awareness training every three years and in monthly meetings with the global procurement team. Covanta complies with the Foreign Corrupt Practices Act (FPCA), in which bribes to foreign officials were made illegal. Furthermore, since Covanta operates in the United Kingdom (U.K.), all employees globally must comply with the 2010 U.K. Bribery Act.