As a mark of the seriousness with which we treat business ethics, the company has put in place an Anti-Bribery and Anti-Corruption Policy. Under it we act with zero tolerance towards bribery and corruption, and undertake to conduct our activities fairly, honestly, lawfully and in accordance with ethical rules. The policy covers all company employees including the Board, the firms from which we buy goods and services and their employees, and all persons and organisations acting on our behalf — suppliers, consultants, lawyers and external auditors included.
Bribery and corruption
Corruption is a criminal offence in every jurisdiction in which we operate. Bribery may take the form of directly or indirectly obtaining, promising, authorising or requesting a personal advantage. Bribery and corruption of every kind are strictly prohibited, whether carried out directly or indirectly through another party.
Gifts
Gifts and hospitality must always be proportionate and reasonable. They must serve a legitimate purpose and must not create a conflict of interest or the perception of one. Excess and extravagance are always avoided.
Facilitation payments
Facilitation payments to secure or speed up a routine transaction or process with a public body — permits, licences, tender procedures and the like — are not permitted.
Donations
Employees must satisfy themselves that any donation is made to a genuine charitable organisation and is not being used to conceal a bribe. All charitable donations and social responsibility expenditure require the written approval of the Board.
Record keeping
All accounts, invoices and documents relating to dealings with third parties are recorded and retained completely, transparently, precisely, fairly and reliably. Internal control systems are in place to prevent off-the-record transactions. Care is taken that accounting and comparable commercial records are not altered and that facts are not misrepresented.
Representation and hospitality
Representation and hospitality may be undertaken to develop commercial relationships and build a business network. Such activity must be reasonable in scale and must not be arranged immediately ahead of a material decision-making process.
Training and communication
The policy has been communicated to all employees and is permanently accessible through the company website. Training is delivered to raise employee awareness of anti-bribery and anti-corruption.
Reporting breaches
Employees may report breaches through internal reporting channels. Where improper conduct is identified, the necessary sanctions are applied.