Purpose
We pride ourselves on the quality of relationships we have with the organisations and people we do business with, and the difference we make together in creating better experiences for our customers.
Our business is diverse and involves partners, suppliers and stakeholders across the globe. One of our core values is ‘We do the right thing’. This Policy addresses the key principles that must be adhered to in regard to Fraud, Bribery & Corruption, Facilitation Payments, Gifts & Entertainment and Political Donations.
Scope.
This Policy applies to all Directors, Team Members, Vendors, Contractors and Third Parties who work for or with the 3S Group in all countries of operation. This policy sets out the expectations and standards required.
Principles
- We want our relationships with partners (consisting of suppliers, service supplier agencies and consultants) to be a positive point of difference for 3S Group and to be a reflection of our core values.
- Fraud, bribery and corruption are serious criminal offences that can have a significant impact on our brand, reputation and profits.
- We are committed to complying with laws and regulations addressing fraud, bribery and corruption in each country in which we conduct business.
- Individuals must not knowingly commit, be party to, or be otherwise involved in fraud, bribery and corruption.
- We will not do business with any organisation that engages in fraudulent or corrupt activity.
Fraud
- Fraud is dishonest activity that leads to obtaining a personal benefit through deception. It can be by an individual against the company, our customers or other external parties.
- Fraud includes forgery, money laundering, irregular payments or commissions, misuse of company or customer information, theft or misappropriation of cash or stock, company credit card or asset misuse and falsifying accounting records.
- Team members are expected to operate with integrity and comply with policies and procedures addressing the handling of goods, financial accounts, payments and information with respect to record keeping.
Bribery & Corruption
Bribery and corruption are serious offences and can include improper payments, benefits or gifts offered or given with the purpose of influencing a decision or outcome. The bribe or corrupt act may not always be of a large value. It could be a lunch or an invitation to a sporting event.
- Team members should never give or accept bribes to persuade someone to act in 3S Group’s favour, their favour or for the benefit of a third party, including family or friends.
- Team members may engage with governments, regulators, NGOs and industry associations across the world in the ordinary course of business, however they should not offer or accept gifts, or entertainment to or from any government employee or public official.
- Organisations and individuals doing business with 3S Group (including third parties) should never offer a bribe, payment or gift to a 3S Group’s team member or anyone working on behalf of 3S Group.
- If a team member is offered a bribe it is expected that they decline the offer and report the matter to their line manager, HR or through our whistleblower service Speak Up.
Facilitation Payments
- Facilitation payments are low value payments to government officials designed to receive favourable treatment or speed up routine governmental actions.
- Team members must never make payments in cash or payments that are unofficial, improper or irregular directly or indirectly to government or public officials in order to secure a permit or licence or accelerate any other decision from a government agency.
- Team members are permitted to utilise legitimate fast-track processes in order to expedite routine actions.
- Third parties must never make payments on behalf of 3S Group in cash or payments that are unofficial, improper or irregular directly or indirectly to public officials or any government agency.
Political Donations
- A political donation includes gifts or payments made to a political party, candidate, or elected parliamentarians at federal, state or local government.
- 3S Group may engage in the political process, provided it is in a manner that is open, transparent and compliant with all relevant federal, state and local laws.
Gifts and Entertainment
- Our Gifts and Entertainment Policy (G&E Policy) is to not accept or provide gifts and/or donations of any monetary value from a supplier or any other stakeholder. Attendance at supplier paid events and other entertainment is only acceptable if it is modest.
- Team members must not offer or accept any form of gift or entertainment to or from Government officials.
Breach of Policy
- Compliance with this policy is mandatory. Team members dealing with suppliers, third parties, government, public officials and consultants are to emphasise and explain these requirements as a condition of our continued relationship with them.
- Any breach of this policy by a team member will result in disciplinary action, may lead to their termination or criminal prosecution and may have serious consequences for all parties involved.
Notification of Suspected Breach
Please email us if you become aware of any suspected breach of this policy suite.