Don’t meet public officials alone

05 Public officials

Since they often control decisions or processes that can affect our business success, we hold ourselves to the highest ethical standards when working with public officials and politically exposed persons.

Three key things

1

Never offer gifts or business entertainment to public officials, or officials involved in public procurement

2

Ensure discussions and agreements involving public officials are fully documented

3

Bring a colleague when meeting public officials

Definitions

A politically exposed person or public official is:

  • An officer, member or employee of a governmental institution or department
  • An officer, member or employee of an agency of a governmental institution
  • Anyone acting in an official capacity for or on behalf of a governmental institution, department, agency or international governmental organization
  • A political party official
  • A candidate to a political or governmental office, or appointee to such an office
  • A government officer or employee at the international, national, state/regional or local level
  • An employee of a state or government-owned business, school, hospital, or other entity

Do the right thing

We aim to protect employees and the company from potential conflicts of interest and corrupt payments. In particular, we:

  • Never offer gifts or business entertainment to public officials, or officials involved in public procurement
  • Provide only customary tea, coffee or simple lunches to public officials during business-related discussions or events
  • Never offer special numbers, free minutes to public officials unless it is part of a legitimate business deal

It’s best to always bring a colleague when meeting public officials or politically exposed persons. This makes difficult situations less likely to arise and, if they do, you have someone to support you and confirm your version of events.

In addition, you should:

  • Always agree meeting agendas in advance
  • Make sure minutes are taken at meetings – share these with the appropriate people afterwards
  • Record gifts with the company gift repository when appropriate
  • Never give gifts to public officials, except for branded items of minimal value (if permitted by local law or the recipient’s code of conduct)

Find out more

For more information, see our Anti-Bribery and Corruption Group Policy.

If you’re unsure what to do, speak with Group Ethics and Compliance or your local Ethics and Compliance Officer.

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