Anti-Corruption Policy — Our zero-tolerance commitment to bribery and corruption in all business activities.
1. Purpose
This policy sets out our approach to preventing bribery and corruption across all operations. It applies to all employees, directors, contractors, agents, and any third party acting on our behalf, regardless of location.
We have a zero-tolerance stance on bribery and corruption. No business outcome justifies a breach of this policy.
2. Key Definitions
For the purposes of this policy, the following terms apply:
Bribery
Offering, giving, receiving, or soliciting anything of value to improperly influence a decision or action.
Corruption
Abuse of entrusted power for private gain, including fraud, embezzlement, or undue influence.
Public Official
Any person holding a legislative, administrative, or judicial position, or acting in an official capacity for a government body.
Third Party
Any individual or organisation engaged to act on our behalf, including agents, consultants, and joint venture partners.
3. Prohibited Conduct
The following are strictly prohibited under this policy:
- Offering or accepting bribes, kickbacks, or improper payments in any form
- Making facilitation payments, even where customary in a local market
- Using a third party to make payments that would be prohibited if made directly
- Offering gifts, hospitality, or entertainment with the intent to improperly influence
- Making political donations on behalf of the organisation without prior approval
4. Gifts and Hospitality
Reasonable and proportionate gifts and hospitality are permitted where they are transparent, infrequent, and not intended to influence a business decision. All gifts or hospitality above the threshold set by the Compliance team must be recorded in the Gifts Register.
If you are unsure whether a gift or invitation is appropriate, consult the Compliance team before accepting or offering it.
5. Reporting a Concern
Anyone who suspects a breach of this policy — or is pressured to act contrary to it — must report this immediately. Reports can be made to your line manager, the Compliance team, or anonymously via the whistleblowing channel.
Retaliation against anyone raising a concern in good faith is a breach of this policy and will be treated as a serious disciplinary matter.
This policy is reviewed annually. For the current version, contact the Compliance team or refer to the internal policy library.