AB & C POLICY

COMPANY ANTI-BRIBERY AND CORRUPTION POLICY

PURPOSE AND SCOPE

This Policy applies to the Company, its Directors, Employees and Third Parties acting for or on behalf of the Company. The Policy covers any activity or behaviour undertaken during the course of, or in connection with employment or acting on behalf of the Company, regardless of the geographical location in which that activity or behaviour occurs.

POLICY STATEMENT

The Company, its Directors, Employees and Third Parties, must be aware of and understand the Company’s AB & C obligations and requirements in order to address and protect the Company and its people from Bribery and Corruption risks.

POLICY REQUIREMENTS

The Company has a zero tolerance towards Bribery, Corruption and Facilitation Payments.

Directors, Employees and Third Parties acting for or on behalf of the Company are prohibited from:-

  • engaging in any kind of bribe, facilitation payment or corrupt behaviour regardless of whether or not a benefit is given to or received by another person and regardless of the value of the benefit.
  • carrying out any dishonest accounting or concealment of complete and accurate financial activity.

WHILSTEBLOWING

The Company fosters a culture of speaking up to encourage reporting of any suspicion of a Bribery or Corruption incident, or other concerns relating to A,B & C without fear of reprisal.

TRANSPARENCY AND RECORD KEEPING

The Company maintains transparency and mitigates Bribery and Corruption risks through procedures relating to:

  • gifts and entertainment
  • conflicts of interests
  • corporate expenses
  • employee due diligence
  • donations and sponsorships
  • third parties

The Company maintains appropriate records of financial and non-financial controls and ensures that they are accurate and protected against improper use or loss of integrity.

AWARENESS

The Company ensures that Directors, Employees and Third Parties are aware of the Company's zero tolerance towards Bribery and Corruption and promotes a culture of compliance with AB & C obligations.