This company has a zero-tolerance of bribery and corruption. This policy extends to all the company's business dealings and transactions in all countries in which it or its subsidiaries and associates operate. This policy is given force in a detailed anti-bribery programme, which is regularly revised to capture changes in law, reputation demands and changes in the business. All directors and employees are required to comply with this policy.
Facilitation payments policy
Our company prohibits 'facilitation' or 'grease' payments as these are bribes and illegal. Facilitation payments are small payments made to secure or speed-up routine actions, usually by public officials, such as issuing permits, immigration controls, providing services or releasing goods held in customs. It is also our policy that we work to ensure that our agents and other intermediaries, joint ventures and consortia, contractors and suppliers, do not make facilitation payments on our behalf. If you have any doubts about a payment or suspect that it might be considered a facilitation payment, only make the payment if the official or third-party can provide a formal receipt or written confirmation of its legality. If practicable, obtain senior management/legal approval for the payment. If the demand is accompanied by immediate threat of physical harm then put safety first, make the payment and then report immediately to senior management the circumstances and amount of the payment.
Criteria to test if gifts, hospitality or reimbursed expenses comply with the anti-bribery programme: