Combatting fraud, corruption and bribery
During 2019, additional policies and new procedures were developed to reinforce internal control measures for combatting fraud and corruption and implemented in the following areas: Spend Approval Policy, Capital Expenditure and Lease Approval Policy, Global Travel and Expense Policy, and Delegation of Authority (DOA) Policy.
These actions have increased transparency across all relevant business units and have clarified decision-making roles and responsibilities.
Following the launch of our new DOA Policy, a training roadshow was carried out by the legal team with 18 sessions organised at different locations. Specifically targeting employees with decision making responsibilities, an attendance rate of 88.3% was achieved and follow-up actions have been developed.
The Global Travel and Expense Policy has been automated to allow increased ease of approval and monitoring of expenses with the implementation of ‘Mobile Expense’.
We have recognised that across the group, any exposure to corruption would vary depending on the nature and location of the business. One of the key risks identified is the use of third parties and intermediaries (such as commercial agents) in certain geographical areas. Some of these agents have already taken part in our 2018 Antitrust and Corruption training and the reach will be extended during 2020 as part of the drive to increase awareness.