Our anti-corruption policies are intended to help our employees who find themselves having to deal with difficult situations where ethical choices must be made.

Any company with 115,000 employees operating in 130 different countries will occasionally encounter unsavoury situations, including bribe demands. But how should an employee actually handle a situation where a business opportunity is coupled with undue external pressure?

Our legal department has established a set of policies, compliance tools and training programmes to answer this question. Known as the Group Anti-Corruption Compliance Programme, these initiatives include:

• A Group anti-corruption policy and set of comprehensive guidelines
• In-person and online training sessions
• Use of due-diligence materials in selecting certain categories of business partners, e.g. agents, JV partners and large-scale
suppliers
• Use of risk-based standard compliance contract clauses
• Ongoing internal monitoring as implementation proceeds, including gathering feedback on necessary improvement.

The programme incorporates elements from other companies' programmes, standards proposed by various NGOs and enforcement agencies, as well as significant practical input from our stakeholders.