How we win
Why we put values first
Putting integrity first strengthens our reputation as a trustworthy and reliable business partner. We have no interest in “buying” business, nor dealing with those who encourage or tolerate corrupt practices. Corruption harms communities, distorts the marketplace and makes it harder for everyone to do business. Regardless of local custom or the practices of other companies, we resist corruption in all its forms. We avoid even the appearance of acting improperly, whether dealing with government officials or private enterprise.
What winning looks like
We vigorously oppose bribery and other forms of corruption by:
- Never offering, promising or giving anything of value to a government official or anyone else in order to gain a business advantage
- Refusing to accept bribes or kickbacks and notifying the Compliance Department if they are offered
- Keeping accurate and complete records so that all payments are honestly detailed and Company funds are not used for unlawful purposes
- Conducting appropriate due diligence on all our third-party providers
- Not using an agent or other third party to make improper payments that we would not make ourselves
- Following our Third Party Travel, Gifts and Entertainment Policy and Anti-Corruption Policy diligently
- Reporting any concern about a potentially improper payment
Is that corruption?
Corruption can take many forms and we must watch out for the danger signs. These include other parties:
- Refusing to agree to our Global Supplier Standards
- Objecting to anti-corruption contract requirements
- Maintaining close ties to government officials
- Requesting unusually high commissions, payments in cash, or payments to accounts in someone else’s name
- Offering questionable qualifications to perform the required services
- Having a reputation for questionable business practices
Think first
Q:
My team is bidding on a big urban redevelopment project in a developing market. Even though we don’t need a partner to be successful on the project, the city government’s procurement official is strongly recommending that we meet with a local company to discuss using them as our subcontractor. It appears that the CEO of that company and the government official are related. Should we go ahead with the meeting?
A:
There are warning signs of corruption here. One is the suggestion that we’ll win business in return for using a subcontractor with close ties to the government official, and another is the fact that we don’t need a subcontractor to provide products and services to this customer. Corruption can take many forms and does not always involve a direct bribe to a government official. In this situation, you should inform the procurement official that there is no need for the recommended subcontractor and politely decline the meeting. If you have any concerns at all, speak with Compliance or the Law Department.