Anti-Corruption Policy Statement
Take a zero tolerance approach to Bribery & Corruption
Introduction to Anti-Corruption
It is the Board’s clear intent that we conduct all of our business in an honest and ethical manner and it has adopted a zero-tolerance approach to those who are involved in bribery and corruption. The Board is committed to ensure that our Group acts professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and will implement and enforce effective systems to counter bribery.
The legislation that has driven recent changes to our Anti-Corruption policy is the Bribery Act 2010 which will come into force in July 2011. Whilst the Bribery Act is a piece of UK legislation it applies to the Group’s activities in every country where it operates and not just the UK. Clearly we will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
The second most important legislation for the Group to be aware of, given our large presence in the United States of America is the Foreign Corrupt Practice Act (15 U.S.C. §§ 78dd-1, et seq). The FCPA makes it illegal for any person or a corporation established in United States or acting within the United States to influence, bribe or seek an advantage from a foreign official. (Federal and State Laws also prohibit bribery and corruption of any state, local or federal official.)