The Companys Code of Business Conduct and Anti-Bribery Policy provide guidance on how to conduct business in a fair, ethical and legal manner.
Our anti-corruption compliance program encompasses numerous reporting, monitoring and certification controls, as well as a critical education component comprising both web-based and in-person training.
We conduct periodic anti-bribery assessments and audits of our business to raise overall awareness, detect potential misconduct and monitor compliance with anti-corruption laws and policy. Annually, we review practices at high risk operational units for compliance with our Anti-Bribery Policy. We periodically engage independent third parties to perform assurance procedures to ensure our anti-bribery compliance program elements are functioning properly and to identify best practices that we can implement broadly. We continue to leverage opportunities to share learnings and successful practices across our system.
Additionally, we have a global program to screen vendors and potential vendors deemed to be high risk and to obtain their agreement to abide by the Company’s Anti-Bribery Policy. We refreshed our training in 2012 and continue to direct resources to training and support in order to assist local management in avoiding corruption. In Myanmar, for example, it is not uncommon for the traffic police and other government employees to request facilitating payments (small payments to low-level officials to speed routine interactions or approvals) from commercial drivers. The company whose operation we acquired was not immune to this practice. We determined that on a certain date following our acquisition, with training preceding, we would end this practice of facilitating payments altogether. We reviewed local processes and implemented necessary mitigation practices, including training programs, the development of local-language cards that drivers can provide to authorities that state our policy prohibiting such payments, and reviews to ensure that our vehicles are appropriately maintained, roadworthy and licensed.
We have assessed all our business units for risks related to corruption and concentrate our auditing on the highest-risk locations. The Transparency International Corruption Perceptions Index is one of several factors we consider in targeting our auditing efforts. From January 2007 through June 2008, we conducted anti-bribery audits in locations spanning our Company operations across nearly 100 countries.
As a signatory to the United Nations Global Compact, we are actively engaged with other companies and nongovernmental organizations in the fight against corruption. In December 2007, we became a signatory to the World Economic Forum Partnering Against Corruption Initiative (PACI), making The
The PACI's mission is to develop multi-industry principles and practices that will result in a competitive, level playing field, based on integrity, fairness and ethical conduct. The PACI requires CEO commitment to zero tolerance for bribery and a commitment to implement a practical and effective anti-corruption program within their company.
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