The foundation of company’s culture lies in our history and our values. We believe that we
should always conduct ourselves and our business openly, honestly and in compliance with
all applicable laws.
Our reputation is built by the actions of our people and this is why what you do everyday is
so important. We believe that our success should be based on a common vision of shared
values and a consistent standard of conduct.
At company, we take a zero-tolerance approach to bribery and are committed to complying
with all applicable anti-bribery laws. This Policy sets out the rules and principles as they
relate to bribery and forms part of our Code of Conduct and Business Ethics. It has the full
support of our Board of Directors.
You should read and understand this Policy and apply it every day. If the laws in your
country are stricter, then you must comply with them in addition to this Policy.
If you have a question on anything related to this Policy, you should speak to your Grade 2
line manager. He or she will raise matters to the Branch Manager, the Hub Manager or the
Group Chief Compliance Officer as appropriate. Alternatively, you can send your query to a company nominated email eg. firstname.lastname@example.org. We also welcome any suggestions you may have for improving the prevention of bribery in our business.
2. THIS POLICY APPLIES TO EVERYONE IN THE COMPANY GROUP
This Policy is mandatory for the directors, officers and employees of all company
Group companies (company and all of its subsidiaries) no matter where they are
located or what their position (collectively, Associates).
This Policy also applies to all non-company persons or companies who perform services for
us or on our behalf anywhere in the world. We have called them Business Associates in this
The rules and principles under this Policy apply regardless of:
• the country in which you or the recipient are located
• whether the bribe is promised or given by you personally or by a third person (e.g. by an
agent or intermediary)
• whether the bribe is received by the recipient or through another person (e.g. a family
member or a friend of the recipient)
• local custom / locally acceptable practice
• the value of the bribe
• whether the decision relevant to the business of the company has already been made
(e.g. where the bribe is a reward for a decision already made).
The reason why this Policy has application worldwide is that some anti-bribery laws (such as
the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977) apply beyond their
national borders and to corporate entities from other countries. As a result, complying with
local anti-bribery laws alone will not necessarily ensure full legal compliance.
3. WHAT IS BRIBERY?
Bribery is when a person offers, promises or gives another person a benefit directly or
indirectly (e.g. through a third party) intending that benefit to influence that person to
perform their job improperly, or as a reward for doing so. Asking for, agreeing to receive or
accepting such a benefit is also bribery. It doesn’t matter if the bribe is offered or accepted
by a third party. It is still a bribe.
The benefit does not need to be in the form of cash – it can be any type of advantage. Some
examples are: gifts, meals or sports tickets, travel expenses, discounts, rebates, kick-backs,
donations, preferential treatment and favours.
Bribery laws concerning public officials are even stricter – providing a benefit to a public
official can be bribery even if no misconduct or improper motive is involved. Consequently,
great care needs to be taken when dealing with public officials. Please refer to the Guidance
Notes for further guidance on who are public officials.
Examples of bribery include:
• a payment from a factory to clear goods for shipment to the customer
• a payment to a building inspector official to encourage him to overlook the lack of a
• a payment made through a customs broker to a customs official for the release of
• an expensive gift to an employee by a telecom company after LF awards a contract
to that company
• requesting or accepting a payment from a factory in return for placing an order with
• free stays at a luxury hotel for arranging a conference at the hotel’s facilities
In many countries, it may be customary business practice to make small payments or give
small gifts to junior public officials in order to speed up or secure a routine action or process
to which the payer is entitled. These are sometimes known as “facilitation” or “grease”
payments. You should be aware that facilitation or grease payments are bribes.
4. WHAT ARE THE RULES?
(a) You must NOT offer, promise or give a benefit of any kind to a person if that benefit
is intended to or is likely to influence him or her to perform their job improperly or
to reward such improper performance.
(b) You must NOT ask for, agree to receive or accept such a benefit.
(c) You must NOT give or accept gifts or hospitality unless it is consistent with our
Guidelines on Gifts, Entertainment and Hospitality.
(d) You must NOT give gifts or hospitality where you know or suspect that they would
violate the recipient’s own internal rules, guidelines or policies.
(e) You must NOT offer or make facilitation payments. Any request for a facilitation
payment must be reported as soon as possible to your Grade 2 line manager.
(f) You must keep accurate financial and business records – see paragraph 6 below.
5. HOW DO I RAISE CONCERNS?
You have a responsibility to help prevent bribery and to raise concerns about any behaviour
that may amount to bribery. If you come across something that may amount to bribery (by
another Associates or by a non-company person), you must report it at the earliest possible
time. Raising concerns early may help us address problems before they result in serious
As an initial step, you should report your concern to your direct line senior management in
writing or by telephone. If for whatever reason, you:
• feel that you cannot speak with your direct line senior management about your
concern or complaint; or
• consider that your concern or complaint has not been handled by your direct line
senior management properly; or
• prefer to make the report anonymously,
you can direct your concern and provide all the relevant information and supporting
documents you have to the Group Chief Compliance Officer by e-mail at (GroupCCO@example.com), by Company Address.
Please take a look at our Reporting of Concerns Guidelines as posted in companies
intranet site. These Guidelines should include multiple channels to raise concerns, including
The Company Group does not tolerate retaliation of any kind against Associates who
raise genuine concerns or who participate in the investigation of a report of suspected
misconduct. If you engage in retaliation you will be subject to disciplinary action, which may
include the termination of your employment.
6. WHAT ARE THE CONSEQUENCES IF YOU COMMIT AN ACT OF BRIBERY?
Company’s continued success is dependent on its reputation and this reputation is
dependent on the actions of its people. If you commit an act of bribery, you will bring the
entire company into disrepute. In other words, your action impacts all of us.
There are very serious consequences for bribery.
• disciplinary action (which will result in your dismissal or termination of your
• criminal sanctions by governmental authorities (which includes imprisonment and
unlimited fines in many jurisdictions)
For the Company:
• criminal sanctions by governmental authorities including unlimited fines
• serious reputational damage
• high value breach of contract claims by third parties
• blacklisting from public and private tendering opportunities
• termination of contracts by our counterparties
• further criminal sanctions for money-laundering offences
Full compliance with this Policy at all times is therefore extremely important.
We must keep accurate financial and business records that reflect our business dealings. If
we don’t, such failure (whether it was intentional or not) may result in our business breaking
the law and being subject to severe penalties. Accordingly, an employee’s failure to report and keep appropriate records could result in disciplinary measures. No accounts may be
kept “off-book” to facilitate or conceal improper payments.
You must submit all expense claims according to our expenses policy (which requires the
submission of original receipts or similar documents) and specifically record the details of
the expenditure. For gifts and hospitality expenses, you must include the following details:
• date, amount and description of the expense (e.g. location of function, item given)
• name, firm and title of all persons present
• business purpose/reason for the function or gift
8. OTHER THINGS YOU NEED TO BE CAREFUL OF
8.1 Engaging or contracting with Business Associates
We may be liable for the bribery of our Business Associates where the bribe was made for
the benefit of the Company’s business. For this reason, we need to be very careful when we
engage other people or companies to perform services for us or on our behalf.
Common examples of Business Associates (i.e. people or companies that perform services
for us or on our behalf) include:
• sales agents, consultants, intermediaries and other representatives
• finders and introducers
• vendors and outsourcers
• tax advisors, lawyers, sales and marketing firms
• lobbyists (of any kind)
• joint ventures, joint venture partners, consortia partners
• subsidiaries and affiliates.
Before a Business Associate is engaged (under a new contract or renewing an old one) and
before a Business Associate starts work, you should contact the Legal Department who will
work with you to ensure that we understand who we are dealing with and that the Business
Associate is aware of our zero-tolerance approach to bribery, the requirements of this Policy
and that the contract contains the necessary representations and undertakings.
8.2 Gifts, Entertainment and Hospitality
As explained above, bribery does not need to be in the form of cash – it can be any type of
advantage or benefit. In some cases, bribes may come in the form of gifts, entertainment or
hospitality. This is why we have developed a set of guidelines – the Guidelines on Gifts,
Entertainment and Hospitality – to help you determine whether you should give or accept
something. If it looks like someone is trying to influence your decision, you must decline.
8.3 Political Donations
The company Group is politically unbiased and does not associate with or contribute
to any political party. For this reason, you must not use company resources to support,
directly or indirectly, any political party, individual politicians or associates representing a
You are free to make lawful personal contributions, including the provision of services
outside working hours, to political parties or candidates. These contributions, however,
must not be linked to any business or potential business of the company Group. In
addition, you cannot use your job title or company affiliation in connection with political
activities unless required by law.
8.4 Charitable Contributions and Sponsorships
We care about the well-being of the communities in which we operate and support the
giving back to those communities in the form of charitable contributions and sponsorships.
However, we must be careful to ensure that any corporate charitable contributions or
sponsorships (whether they be cash, the donation of services, products or anything else) are
free from any suspicion of bribery. Accordingly, all corporate charitable contributions and
sponsorship proposals must be approved in advance by your Grade 1 line manager.
We take all reported concerns seriously. The Corporate Compliance Group will investigate
all reports of bribery in any way connected to a company company. The Board (or a
body or function to which it delegates such responsibility) will then consider what action to
take as a result of such investigation, including, where applicable, disciplinary action against
Associates (which may result in the termination of employment), termination of business
relationships and reports to relevant governmental authorities or regulators.
The Group Chief Compliance Officer will keep a record of all reports made under this Policy.
This will include a record of any investigation and the outcome of those investigations.
Public officials are people who perform a public function and includes people that you might
not necessarily think of as “public officials”. Public officials include:
• government officers, employees or other representatives (whether at local, national,
foreign or domestic levels)
• any person with a legislative, administrative or judicial function (whether appointed
or elected)(such as judges, tax officials, customs officials, regulators, government
personnel who issue licences or permits, planning officials and immigration officials)
• officers, employees and representatives of government-owned or government-
controlled organisations and publicly-funded organisations (such as employees of state-run hospitals and employees of central banks. In China, many businesses and organisations are State-owned enterprises and their employees would also be public officials)
• political party officials, politicians or political candidates (whether at local, national,
foreign or domestic levels)
• members of a royal or governing family
• employees, officers or representatives of international public organisations such as
the United Nations and the World Health Organisation