Anti-Bribery Policy Statement

Introduction

In accordance with the Group Ethics Policy the Board of Molins PLC is committed to the Group operating in an honest way and without the use of corrupt practices or acts of bribery to obtain an unfair advantage.  

 

The Group:

 

  • has a clear anti-bribery policy;
  • trains its employees so they can recognise and avoid the use of bribery;
  • encourages its employees to be vigilant and to report any suspicion of bribery by providing appropriate means of communication and ensuring that sensitive information is treated accordingly;
  • investigates instances of alleged bribery thoroughly and will assist the appropriate authorities with their investigations and any subsequent prosecution;
  • and takes firm action against anyone found, after investigation, to be involved in bribery and corruption.

The Group prohibits:

the offering, giving, solicitation or acceptance of any bribe whether in the form of cash or other inducement, to or from any person, firm or company, wherever they are based and whether they are a public official or body or a private individual, firm or company, by any individual employee, agent or other person  or body acting on the Group’s behalf, in order to:

 

  • gain any commercial, contractual or regulatory advantage for the Group in a way that is unethical, or
  • gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual. A full copy of the policy can be downloaded here.

The Group recognises that market practices vary across the territories in which the Group carries on business and what is normal and acceptable in one place may not be in another.  The policy prohibits giving or receiving any inducement which results in personal gain or advantage to the recipient or any person or body associated with them and which is intended to influence the recipient to take action which may not be solely in the interests of the Group or the person or body employing them or whom they represent.

 

The policy is not intended to prohibit the following practices providing they are appropriate and proportionate to the particular market and they are properly recorded:

 

  • normal and appropriate hospitality;
  • the giving of small or ceremonial gifts to mark a festival or special event;
  • the use of a recognised fast-track process which is available to all on the payment of a fee.

If there is any doubt as to whether a potential act is acceptable or not, the matter should be referred to the General Manager for the business, the Group Company Secretary or the Chief Executive for guidance before proceeding.

 

Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all Group employees.  Any concerns can be raised confidentially through the whistleblower hotline maintained by Expolink Europe Limited.  Full details of the hotline are contained in the Group Ethics Policy which is issued to all employees.  Further copies are available from local HR departments, the Group Company Secretary or can be found on the Molins PLC website at www.molins.com/about-us/molins-group-policies.