• It is our policy to conduct all of our business in an honest and ethical manner.
  • We take a Zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and will implement and enforce effective systems to counter bribery.

Facilitation payments and kickbacks

  • We do not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
  • If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt that details the reason for the payment.

Political donations

  • We do permit contributions from the Company to political parties in certain circumstances upon prior approval of the Board but these are never made in an attempt to influence any decision or gain a business advantage and will always be publicly disclosed. Such political donations will be subject to the laws of the country or state in which such donations are made, and subject to any financial limits contained in those laws. Individuals that desire to make political contributions are free to do so, but such a contribution must comply with Federal and State Laws, and must be made in the individual’s, and not the company’s, name.

Charitable donations

  • We do permit charitable donations but these must not be offered to gain a business advantage. In some jurisdictions, we permit our employees to volunteer for participation in community days.

How to raise a concern

  • If you have any doubt or concern about any situation relating to the policy, seek guidance from your manager before doing or omitting to do anything that could compromise your position within the Company.

What to do if you are a victim of bribery or corruption

  • It is important that you tell your manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.