Code of Ethics/Business Ethics
G11. Does the Company have a code of ethics or policies setting out its values
and governing the conduct of its employees relating to any of the following
topics?
▪
▪
▪
▪
▪
obeying laws/regulations
giving and receiving gifts
donations to political parties
employee use of Company resources
external employee activities
Yes
▪
▪
▪
▪
▪
giving and receiving bribes
facilitation payments
addresses conflicts of interest
anti-competitive practices
other sector-specific issues
No
If “Yes”, please indicate the web address where the code is disclosed:
If not disclosed,
please supply a copy of the code as evidence. If “No,” please skip to the next section.
G12. What is the extent of coverage of these policies? (tick all that apply)
all employees, businesses, and subsidiaries
board only
home country businesses only
other:
managers only
G13. Does the Company have a senior corporate manager responsible for
implementing the code of ethics or similar policies?
Yes
No
If “Yes,” please give details if the senior person has a dedicated staff or other
supporting resources:
G14. Please indicate the extent of Company management systems to implement
the code ethics or similar policies:
System Element
Details/Documentation
Identification of high risk
issues/operations/areas
Employee training of the
code
Compliance monitoring
“Whistleblowing” procedures
Regular reviews of the
code/policies
Reporting of performance,
including details of breaches
and enforcements
Please use this space for any additional details you wish to provide regarding the
Company’s code of ethics policies and systems:
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