Our programme is embedded through our key global policies and processes including due diligence programmes. Our anti-corruption policies include:
- Advisers Policy – which governs the appointment, management and payment of third parties who are engaged to assist with our sales and marketing activities or the strategic development of the Group;
- Gifts and Hospitality Policy – which governs the offering, giving and receiving of gifts or hospitality;
- Conflict of Interest Policy – designed to ensure that personal conflicts of interest do not impair employees’ judgement and damage the Group’s integrity and interests; and
- Facilitation Payments Policy – designed to ensure that Facilitation Payments are not paid and that the Group and its employees seek to eliminate the practice of facilitation payments.
Other policies, include our Finance Policy, Fraud Prevention Policy, Export Control Policy, Lobbying, Political Donations and Other Political Activity Policy, Offset Policy and Procurement Policy, which include measures to address bribery and corruption risks.
The programme receives both internal and external oversight and assurance. Risk-based due diligence procedures have been implemented to address bribery, corruption and other financial and non-financial risk, and out policies include processes for risk-based internal and external approvals, ongoing monitoring and repeat due diligence. We drive improvements in the programme annually to ensure it continues to meet best practice.
The programme also includes our Code of Conduct and training which covers scenarios our employees may face, defines the standards and behaviours we should aspire to every day, and gives guidance on where to go for further advice. All employees are required to complete training annually.