Sets the company's zero-tolerance position on bribery and corruption in every market in which it operates.
Scope
This policy applies to all directors, officers, employees, contractors, agents and intermediaries acting for or on behalf of the company, in every jurisdiction in which the company operates. It is read with the Gifts and Hospitality Policy and the Supplier and Third-Party Code of Conduct.
Position
The company prohibits bribery and corruption in all forms, whether direct or through a third party, and whether involving a public official or a private party. No director or employee will suffer any disadvantage for refusing to pay a bribe, even where that refusal results in the loss of business.
Facilitation payments
Facilitation payments, sometimes described as grease payments, are prohibited. Where a payment is demanded under duress and personal safety is at risk, the payment may be made and must be reported to a director on the same day and recorded in writing.
Political and charitable contributions
The company makes no political donations of any kind. Charitable donations require prior approval from the board and must not be made to secure or reward business advantage.
Third parties
Agents, introducers, consultants and joint venture partners are screened before engagement under the Anti-Money Laundering and Counterparty Screening Policy. Contracts with third parties who interact with public officials on the company's behalf include anti-bribery undertakings and a right of termination for breach.
Applicable law
The company complies with the Prevention of Bribery Ordinance (Cap. 201) of Hong Kong, the UK Bribery Act 2010, and the anti-corruption laws of every jurisdiction in which it operates, including Australia.
Records and reporting
All payments are recorded accurately in the company's accounting records. No off-book account or false record is permitted. Suspected breaches are reported under the Whistleblowing and Speak-Up Policy.
Consequences
Breach of this policy is a serious disciplinary matter and may result in dismissal, termination of contract, and referral to the relevant authority.
Reporting a concern
Concerns about any matter covered by this policy may be raised with any director or by email to compliance@inbox.case.sg. Reports made in good faith attract no adverse consequence.