Anti-bribery and anti-corruption policy
Doing the right thing
01. Policy statement 01
02. Who is covered by the policy? 02
03. What is bribery? 03
04. Gifts and hospitality 05
05. What is not acceptable? 07
06. Facilitation payments and kickbacks 07
07. Donations 08
08. Your responsibilities 09
09. Record-keeping 09
10. How to raise a concern 10
11. What to do if you are a victim of bribery or corruption 11
12. Protection 11
13. Training and communication 11
14. Who is responsible for the policy? 12
15. Monitoring and review 12
Schedule: Potential risk scenarios: “red flags” 13