Don’t do bribes

04 Improper payments

We act with the highest standards of transparency and integrity wherever we operate. By doing so we can ensure our actions and decisions are always in the best interests of customers, our business and society.

Three key things

1

Nobody should gain personally from our business decisions

2

Take due care when engaging with third parties and never make facilitation payments

3

Always keep accurate and transparent financial records

Definitions

Corruption is the abuse of entrusted power for private gain.

Bribery is the offering, providing, authorizing, requesting or receiving of a financial or other advantage intended to influence a transaction or decision, or encourage misuse of a person's position.

Financing of corruption is a payment made to a third party – such as an agent, partner, vendor or consultant – who uses it (or part of it) for a corrupt activity.

Facilitation payments are payments offered or made to a public official to secure or speed up a routine and necessary government or official action.

Do the right thing

We always keep accurate and transparent financial records, as this helps ensure all our payments are made for the right reasons.

We recognize that, in rare and exceptional situations, an employee may be forced to break these rules under threat of violence or personal harm.

We never:

  • Offer or accept anything of value that could be intended to influence or reward a business decision
  • Offer, provide, authorize, request, accept or receive bribes, either directly or indirectly, including through any third party
  • Offer or accept facilitation payments
  • Offer financial support that could encourage or lead to corruption
  • Never offer, provide, authorize, request, accept or take a bribe
  • Never make personal gain or profit from a business transaction
  • Take due care when engaging with third parties, such as partners, suppliers, consultants, subcontractors, lobbyists, agents and agencies
  • Take immediate action and report your concerns if you're aware of potential corruption or bribery

Facilitation payments:

  • Stand your ground – if you're asked to make a facilitation payment, contact the responsible manager to help resolve the situation
  • Make sure your documents are in order when approaching public officials in a region where facilitation payments are customary – this gives less opportunity to ask for additional payments
  • Refusing to make facilitation payments may make it more difficult to get the service you need – plan ahead for this and speak to your manager if you have any concern

In practice

I'm responsible for our network rollout in a market with high regulatory complexity. The rollout has already been delayed and I am getting impatient – it's damaging the company and we're now in danger of missing our targets. I've now been offered the option to make a donation to an orphanage, which could speed up the process.

Explain to the official that you're not responsible for donations. You can also point out that the company keeps donations separate from business activities.

Find out more

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

You can raise concerns or report potential misconduct through our secure web portal – Speak-Up Line. If you're unsure what to do, speak with Group Ethics and Compliance or your local Ethics and Compliance Officer.

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