Bribery & corruption

We will not give or receive bribes or participate in corruption

What do we mean?

We refuse to participate in any kind of corrupt activity, either directly or through third parties. This includes offering, giving or receiving bribes or improper payments including facilitation payments, even if such practices are perceived as part of local business practice.

An allegation of bribery can seriously damage our reputation. It is better to miss out on business than compromise our integrity.

Bribery – offering, providing or receiving something of value including cash, gifts, hospitality or entertainment as an inducement or reward for something improper. Usually, but not always, it is to obtain or retain business or gain an illegitimate advantage.

Corruption – dishonest practices including, but not limited to, bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement or money laundering.

Facilitation payments – sometimes referred to as grease payments, facilitation payments are usually small payments or gifts generally made to junior or lower level public officials to speed-up or “facilitate” actions that officials are duty bound to perform.

The payments can appear harmless as they are low in value or part of local custom or culture and are considered the way things are done, however they are illegal in most countries.

We make no distinction between facilitation payments and bribes. Any type of facilitation payment is prohibited, large or small, and even if others engage in such practices. There is one exception and that is when the facilitation payment is being extorted or you are being coerced to pay it. Extortion means if your safety or liberty, or that of your family, is under threat or you feel that you have no alternative to pay for personal or family peace of mind. In these circumstances make the facilitation payment, record it clearly and report it immediately to your Finance Director and your compliance, legal or business integrity team. In these circumstances it is the company’s duty to support you.

We always

  • Seek to avoid even the appearance of wrong doing

  • Record all payments and benefits provided to public officials

  • Report any attempts to bribe us or solicit bribes from us

  • Report any suspicions we have of bribery or corruption

We never

  • Participate in any form of corrupt behaviour

  • Engage public officials to provide services without approval from Group Head Office

  • Conceal or fail to record accurately and completely the true nature of our activities

  • Falsify or tamper with the company’s books or records

  • Pay more than the fair market value for goods and services