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CIMIC Group Limited Annual Report 2016 |
Sustainability Report
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Prevention of bribery and corruption relies on the following key factors:
•
promotion of, and adherence to, an ethical culture of integrity and accountability;
•
management accountability;
•
effective employee recruitment procedures;
•
on-going training and awareness and enforcement;
•
carrying out periodic risk assessments; and
•
strong internal control systems which includes a robust whistleblower regime.
We have an Anti-Bribery and Corruption Policy supported by the Group Code of Conduct - Management, Monitoring and Reporting Policy
which:
•
identifies roles, responsibilities and obligations of leadership and employee groups;
•
prescribes training requirements of various roles in the Group; and
•
details related processes, including:
obligations of employees and managers in reporting a concern about a suspected breach of the Code;
confirming protection available to whistleblowers;
outlining investigation processes for an alleged breach of the Code – ensuring it is confidential, objective, independent and fair;
and
setting out key contacts and details.
Subcontractors and other third parties the Group works with can make a significant contribution to our success. The Group will only do
business with third parties for legitimate purposes, in accordance with the Code, relevant laws and where that business relationship will
benefit the Group. Third parties are entities and individuals outside of CIMIC Group and may include clients, joint venture partners,
subcontractors, consultants and suppliers, agents or intermediaries (as defined by our Dealing with Third Parties Policy).
The Group will not do business with a third party that does not share a similar approach to the Group in relation to ethical matters, or
where engaging with the third party will harm the reputation of the Group. We aim to have effective business relationships with
subcontractors and other third parties, and to encourage them to adopt similar business principles, practices and procedures to those of
the Group. Group employees must ensure that any third party understands the Group’s expectations and the Code.
When the Group has a controlling position in a joint venture or similar arrangement, the Code (or another code containing equivalent
standards of behaviour) must be adopted for the joint venture or other arrangement. In other circumstances, the Group will remain
bound by the Code and will seek to have partners adopt the Code.
Before entering into a commercial relationship with a third party on behalf of the Group, appropriate due diligence must be conducted in
accordance with the Dealing with Third Parties Procedure and all contracts must be approved in accordance with the Group Delegations
of Authority.
Each contract with a third party must be in writing and all contracts must:
•
reflect the entire agreement between the Group and the third party;
•
describe in a transparent manner and with an appropriate amount of detail the services and/or goods to be provided; and
•
contain terms that provide a clear link between, and are commensurate with, the provision of goods or services and the payment of a
fee or charge.
‘High Risk’
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third parties may only be engaged where:
•
they have completed and executed a Third Party Anti-Bribery and Corruption Declaration, where it has been established that the
business relationship is a legitimate one, and that the third party will comply with the Code or, if it has a code of similar scope and
content to the Code, its own code; and
•
integrity checks on the third party have been completed (e.g. internet searches on the company and key individuals) and are
acceptable to the approving manager.
Other third parties may only be engaged where they have completed a Third Party Anti-Bribery and Corruption Declaration.
Where either the Third Party Anti-Bribery and Corruption Declaration or the integrity checks are not to the satisfaction of the approving
manager, further enquires must be made. These could include:
•
enquiries of the third party about the specific concerns; and
•
detailed due diligence by an approved specialist due diligence provider (e.g. Thomson Reuters or Control Risks).
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The Dealing With Third Parties Procedure has a detailed definition for ‘High Risk’ which includes but is not limited to: if it is a potential/new joint venture
partner; it is an agent and/or intermediary (which includes legal, tax, immigration, financial, security and industrial relations advisers, lobbyists, customs
and shipping agents); it is nominated or recommended by a public official or other representative of a government or state-owned enterprise; it is an
individual (rather than a company or partnership), other than permanent or contract employees; the engagement relates directly to a project for a
government or state-owned enterprise in any country which has a ranking of 80 or higher in the most recent Corruption Perceptions Index (as published
from time to time by Transparency International) such as Mongolia, India, the Philippines, Sri Lanka, Thailand, China, Indonesia, Vietnam, Laos, Papua New
Guinea, Cambodia and Myanmar; or ‘Low Risk’ due diligence enquiries identifies potential issues.
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