Anti-Corruption Policy
1. About This Policy
It is GlobalTailingsReview.org‘s policy to conduct all of our work 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.
2. Who Must Comply With This Policy?
This policy applies to all persons working for Us or on Our behalf in any capacity, including employees at all levels, external consultants, third-party representatives and business partners.
3. What is Bribery?
Bribery means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
Bribery includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery are strictly prohibited. Specifically, you must not:
- give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
- accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
- give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
- threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
4. Gifts and Hospitality
This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships or promoting global tailings best practice.
A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret.
6. How to Raise a Concern
If offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify Duncan Robertson (duncan.robertson@icmm.com) as soon as possible.