Our equipment is used in, and many of our employees travel to, countries which rank highly on Transparency International’s Corruption Perception Index.

Our company’s policy is to comply with all laws, rules and regulations governing bribery and corruption in all the countries where we operate, including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977. Our ethical behaviour seeks to ensure that no bribes or corrupt payments are made, requested, offered or received by anyone acting on our behalf.

We do not pay facilitation payments and we provide our employees with focused training and guidance to assist them in managing any such requests.

Our Anti-Bribery Policy is incorporated directly into our business processes throughout the organisation. It is applied to our contracts through the inclusion of appropriate clauses. Due diligence is performed on third parties that seek to represent us or who provide products and services to us. We conduct regular reviews and risk assessments of all our ethics policies and processes.

Gifts and hospitality remains the most frequent subject raised by employees about our code, in particular around the interpretation and appropriateness of such during seasonal festivities. Our policy does not permit the offer or acceptance of gifts, nor hospitality that is not within the context of a business meeting.

November 2020