We believe a comprehensive set of policies and procedures, including training on their application, is an important part of establishing and maintaining effective internal controls. Policies are prepared under the direction of the Board of Directors and the Chief Executive Officer. Easily accessible, up-to-date policies help provide an authoritative guide to Grace's business philosophy, headquarters structure, requirements for authorization of various transactions, as well as statements of business practices and policies in specific areas. All employees have access to our global corporate policies. In addition, each business segment, function, or site may also have policies that also are available at any time.
The Board of Directors has delegated the authority to the Chief Executive Officer to authorize, approve and issue policies and procedures, except in areas of responsibility reserved exclusively to the Board of Directors or a committee of the Board of Directors.
Grace maintains policies related to:
TRAINING ON LABOR RIGHTS AND ETHICS
Grace strives to ensure that all employees, across the globe receive centrally-defined training in ethics and related issues on an annual basis. Individual completion of the required training is tracked, and absent special circumstances, failure to complete required training will adversely affect an employee's annual bonus. Substantially all employees are subject to an annual training requirement; provided that in some offices where the standard ethics training modules are not available in the local language, local managers conduct individualized training of affected employees as an alternative to the standard training modules. Additional training on matters related to integrity, safety, anti-discrimination, cybersecurity, anti-harassment, workplace violence prevention, and more are required at different intervals.