Bribery and Other Forms of Corruption

OUR WAY IN THE MARKETPLACE

Doing Business Honestly

OUR WAY

We do the right thing. We win and retain business on the strength of our value proposition and by building relationships based on transparency and trust.

WHY WE PUT VALUES FIRST

Doing things the right way strengthens our reputation as a trustworthy and reliable business partner. We have no interest in “buying” business, or in dealing with those who encourage or tolerate corrupt practices. Corruption harms communities, distorts the marketplace and makes it harder for everyone to do business. Regardless of local custom or the practices of other companies, we resist corruption in all its forms. We avoid even the appearance of acting improperly, whether dealing with government officials or private enterprise.

WHAT OUR WAY LOOKS LIKE

We vigorously oppose bribery and other forms of corruption by:

Never offering, promising or giving anything of value to a government official, customer or anyone else in order to gain a business advantage
Refusing to accept bribes or kickbacks and notifying the Ethics & Compliance Department if they are offered
Keeping accurate and complete records so that all payments are honestly detailed and company funds are not used for unlawful purposes
Conducting appropriate due diligence on all our third-party providers
Not using an agent or other third party to make improper payments that we would not make ourselves
Diligently following our Third-Party Travel, Gifts and Entertainment Policy and Anti-Corruption Policy
Reporting any concern about a potentially improper payment

IS THAT CORRUPTION?

Corruption can take many forms; we must watch for the warning signs. These include other parties:

Refusing to agree to our Global Supplier Standards
Objecting to anti-corruption contract requirements
Maintaining close ties to government officials
Requesting unusually high commissions, payments in cash, or payments to accounts in someone else’s name
Offering questionable qualifications to perform the required services
Having a reputation for questionable business practices

QUESTION: Our plant is considering changing the civil construction provider we’ve used for several years, looking to reduce costs while still receiving quality service. A team consisting of Sales, Procurement, and Ops evaluated vendor bids, and we recognized that the current vendor was likely to lose the work. However, three days after we recommended going with the new vendor, the buyer distributed a new bid only from the current vendor, whom the buyer clearly prefers. The second bid was slightly lower than the winning bid from the new vendor, and the buyer recommended the work be awarded to the current vendor at the new quote as soon as possible. I am concerned there is something going on here between the buyer and the current vendor. What should I do?

ANSWER: There are warning signs of fraud here. Was this simply good negotiating, or is there another reason the buyer received a revised quote only from the current vendor? Did the buyer give the other vendors equal opportunity to respond a second time? Is the buyer related to this vendor in any way (family or close friend)? Was there pressure from someone else to ensure the current vendor won the bid? If so, why? Fraud and corruption can take many forms, not always involving a direct bribe. In this situation, you should discuss this with the buyer’s manager, or if you don’t feel comfortable doing that, go to another manager, speak with your Ethics & Compliance representative or someone in the Law Department or report the concern to the Integrity Helpline.