1. 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 implementing and enforcing effective systems to counter bribery.
  2. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by local and national laws.



  1. This policyapplies to all Employees and relevant Third Partiesof the Company and shall be communicated to them at the outset of our business relationship and as appropriate thereafter.
  2. This policy applies in all countries or territories where the Company operates. Where local customs, standards, laws or other local policies apply that are stricter than the provision of this policy, the stricter rules must be complied with. However, if this policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this policy shall apply.


  1. This policy does not prohibit normal and appropriate hospitality (given and received) to or from Third Parties.
  2. You are prohibited from accepting a gift or giving a gift to a third party in the following situations:
    • (a) it is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
    • (b) it is given in your name and not in the name of the Company;
    • (c) it includes cash or a cash equivalent (such as gift certificates or vouchers);
    • (d) it is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process); and
    • (e) it is given secretly and not openly.
  3. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and is proportionate. The intention behind the gift should always be considered.


  1. In many jurisdictions, making Facilitation Payments is illegal. We do not make, and will not accept, Facilitation Payments or Kickbacks of any kind anywhere in the world.
  2. Where the facilitation payment is being extorted or you are being coerced to pay it and your safety or liberty is under threat or you feel you have no alternative but to pay for personal or family peace of mind, then pay the Facilitation Payment and report this to your line manager as soon as possible.


  1. It is not acceptable for you (or someone on your behalf) to:
    • (a)give,promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
    • (b)give, promise to give, or offer, a payment, gift or hospitality to a PublicOfficial or Third Party to ‘facilitate’ or expedite a routine procedure;
    • (c)accept payment from a Third Party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
    • (d)accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
    • (e)threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
    • (f)engage in any activity that might lead to a breach of this policy or perceived breach of this policy.
  2. It is your responsibility to ensure that allaccounts, invoices, memoranda and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off-book’.
  3. You must declare and keep a written record of all Gifts, Invitations & Hospitality according to Company practice accepted or offered, which will be subject to managerial review.
  4. You must ensure all expense claims relating to Gifts, Invitations & Hospitality or expensesincurred to Third Parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.
  5. The prevention, detection and reporting of any form of Bribery & Corruption are the responsibility of all Employees. You must notify the head of legalas soon as possible if you are offered a bribe, 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.
  6. All Employees have the responsibility to read, understand and comply with this policy. You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.
  7. Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
  8. This policy should be read in conjunction with the Company’s Gifts, Invitations & Hospitality policy, Conflicts of Interest policy and Code of Ethics.
  9. Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their line manager or other available reporting mechanisms.



  1. Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future will beprotected from detrimental treatment/retaliation. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.


  1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
  2. Head of legalhas primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.This training shall also be given to Intermediaries


  1. The Company will establish and put in place appropriate performance measures and reporting systems to monitor performance against metrics and compliance with the relevant policies, procedures and controls.
  2. Head of legal will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.
  3. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective. The head of legal will report to the CEO at least annually on the application of this policy.



The following is a list of possible red flags that may arise during the course of your work for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these red flags while working for us, you must report them promptly to the head of legal.

Release 1.0 – 19th August 2019