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«MARCH 2015 TABLE OF CONTENTS UNDERSTANDING BRIBERY ISSUES GLOSSARY OF TERMS INTRODUCTION What is corruption? 3 Why do we care? 4 Legislative ...»

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Precautionary measures must be taken whenever working with third parties, especially politically exposed persons. For more information, consult our policy Working with Third Parties.

FACILITATION PAYMENTS

Facilitation payments are small payments to officials with a view to speeding up routine governmental transactions to which the payer is already entitled.

Unlike bribery, facilitation payments do not result in the receipt of an undue or unwarranted benefit; rather, they simply speed up or facilitate the transaction, which is why they are sometimes known as “speed money” or “grease payments.” Examples include payments to speed up customs clearances and extra fees to officials to secure electricity connections.

The Corporation prohibits facilitation payments. They are illegal in almost every country. They undermine good governance, and a willingness to make them often leads to demands for larger, more significant payments.

Furthermore, laws like the UK Bribery Act do not distinguish between facilitation payments and other forms of bribery.

Unfortunately, demands for facilitation payments are relatively common in some of the jurisdictions in which we operate. If you think you may encounter a demand for facilitation payments, please consult the section entitled What to do when confronted with corruption? below for further guidance, and consult your senior manager or the Risk and Ethics team.

HOW CAN YOU AVOID CORRUPTION?

Avoiding corruption is not meant to be an impossible task. In general, corruption can be avoided by appropriately following the Company’s Code of Conduct and our policies on Working with Third Parties and Gifts, Entertainment and Hospitality. Individual liability can be avoided by adopting your own zero-tolerance policy toward bribery, kickbacks and facilitation

payments. Simply stated, you can do so by:

 Never offering, paying, requesting or receiving bribes or kickbacks, even if you have been requested to do so by your senior manager or anyone else.

 Never getting involved in any fraudulent or dishonest activity.

 Never authorizing any corrupt activities or behaviours, nor turning a blind eye to potentially corrupt behaviour by your subordinates or third parties acting on the Company’s behalf.

 Never engaging in activities that could facilitate corruption, including drafting illegal agreements, drafting fraudulent claims, falsifying evidence, and giving false evidence in legal proceedings.

 Never concealing any corrupt or potentially corrupt activity.

WHICH RED FLAGS TO LOOK OUT FOR?

In addition to the measures above, recognizing scenarios where corruption is likely to occur can help you avoid and prevent precarious situations in the first place. Good judgment and intuition must play a critical role. In general, suspicious or odd activity or behaviour during a competitive bid or commercial transaction should always be treated seriously, especially if it involves government officials and intermediaries.

You should also be aware of certain warning signs, including:

 Officials or business partners with a general reputation for questionable behaviour;

 Competitive bids that require the use of designated intermediaries;

 Officials or business partners who request charitable or political donations during a competitive bid;

 Officials or business partners who request isolated meetings, especially after a request to include additional parties has been made;

 Odd requests relating to communications (private meetings, conversations, etc.) or payment mechanisms (off-shore payments, cash, etc.);

 Suspicious last-minute changes to selection criteria for competitive bids, which tilt the bid overtly in our favour (for example by excluding all other competitors);

 Officials or business partners who suggest they can provide favours or help on unrelated matters;

 Business partners who request unusually high commissions or fees.

This list is by no means exhaustive, nor does the existence of one or more of these factors mean that you should refrain from engaging in the transaction.

Rather, if you recognize these or any other suspicious behaviour at the outset of any transaction, document your concern and consult your senior manager and/or the Risk and Ethics team. They can help determine if further investigation and precautionary measures are necessary.

WHAT TO DO WHEN CONFRONTED WITH CORRUPTION?

Our management will take every precaution to avoid situations that expose the Corporation and its employees to corruption and we will always support employees acting in good faith to abide by corporate policies. Our Code of Conduct and our policies on Gifts, Entertainment and Hospitality and Working with Third Parties offer important guidance to prevent circumstances which can give rise to corruption. The Risk and Ethics team is also readily available to offer guidance and advice whenever necessary.

However, despite every precaution taken, you may still be confronted with challenging situations. If you are ever requested to pay a bribe or engage in a

kickback scheme, consider taking the following actions:

 Politely refuse. Always treat officials with courtesy and never lose your temper. If you treat them well, they are more likely to reciprocate  If the person requesting a bribe continues, inform them of the Corporation's zero-tolerance policy and the international and local laws on anti-corruption to which we are subject  Request that any bribery demands be made in writing  Make a detailed record of the event and include witnesses if possible  Immediately report the incident to the Risk and Ethics team If you suspect that a colleague or one of our business partners is involved in potentially corrupt behaviour, immediately make a record of the circumstances and report these to the Risk and Ethics team so we can formulate a response.

The Corporation also recognizes that corruption-related demands in any form – whether bribes, kickbacks, facilitation payments or otherwise – are often backed by a form of extortion, in some cases including the threat of violence or personal harm. An extreme example would be a demand for payment to secure an emergency admission into hospital, leaving no time to consult a local line manager.

In such circumstances, the Corporation accepts that staff will need to use their best judgement in accordance with the Corporation's principles.

Whatever happens, staff must report any incident where they feel forced to bribe or make a facilitation payment as soon as possible, and any payments made must be properly recorded. Remember that the Corporation's management will support well-founded and rational decisions by employees facing such situations.

Likewise, if you ever feel that reporting a bribe, kickback or facilitation payment by a colleague, superior or any other party requires anonymous reporting, you may report the questionable activity by phone or via the internet. The information will be processed by an independent party (the Vice President of Internal Audit), who will be required to advise the chairman of the Audit Committee. This situation is covered by relevant internal procedures, including the whistleblowing service procedure, which is available on the Corporation’s web and intranet sites. The reporting party need not identify him/herself and, as such, may remain anonymous.

WHERE TO TURN FOR HELP

If in doubt about any aspect of this policy and guidance, you should contact the Risk and Ethics team.

REPORTING VIOLATIONS

CONFIDENTIAL BUSINESS CONDUCT HOTLINE

Employees can use the Corporation’s whistleblowing service provided by an independent service provider. Information on how to use this service, including free phone numbers, is available in the Code of Conduct, published on the Corporation’s web and intranet sites. The Corporation also provides information on the whistleblowing service in dedicated pages on its web and intranet sites.

CONFIDENTIAL E-MAIL

wsp@expolink.co.uk



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