Employees must avoid conflicts of interest between their private financial activities and their part in the conduct of company business. Shell companies insist on honesty, integrity and fairness in all aspects of their business and expect the same in their relationships with all those with whom they do business. So you may be wondering why we need a primer on how to deal with bribery and corruption. We need to ensure not only that our policies are effectively and consistently applied, but also that they are understood by our current and potential business partners. Unfortunately, attempts to bribe and corrupt have to be confronted and dealt with in the normal course of business.
Difficulties usually arise in the 'grey' areas.
As with any other complex subject, there are inevitably difficult questions of definition, interpretation and analysis. This is not a manual, containing the definitive answers. Unfortunately, because of the nature of the problem, that is not possible. It is a primer that describes some of the many forms of bribery and corruption and, I hope, raises awareness of the very real threats that exist and an understanding of the difficulties involved. The controls and procedures the Group has in place are described and recommendations for good practice are given.