In many of the countries in which the Company does business, Facilitation Payments are not permitted by law and are a form of bribery and a criminal offence.
Facilitation Payments are defined as a payment or gift given (usually to a government official) to cause him or her to perform a routine duty or function, or to expedite such performance, other than the payment of a lawful and official fee for such a duty or function.
In accordance with our approach of adopting the highest standards, the Company, its businesses and employees are prohibited from making Facilitation Payments irrespective of whether or not they are permitted by local laws, unless life or physical assets are threatened.
Our Policy covers the following requirements:
- Our employees must not make Facilitation Payments of any kind or allow others (including advisers, agents and consultants) to make them on behalf of the Company; and
- Employees receiving a request to make a Facilitation Payment must decline to make it and report the request to their local Legal Department.
Publication date: 20 May 2025
Governance and Disclosure