Anti-Bribery & Anti-Corruption Policy
Our Anti-Bribery and Anti-Corruption Policy is supplemented by a framework of supporting policies, procedures and guidance. These include staff training, vetting and communicating our ethical standards to business partners, procedures in areas such as gifts & entertainment, donations and sponsorships, whistleblowing, monitoring and related matters.
Nobel Upstream also plans to host business partner forums to provide an overview of anti-bribery legislation, including the UK Bribery Act 2010.
UK Bribery Act
The UK Bribery Act 2010 requires UK companies, or any foreign companies doing business in the UK, to ensure that all reasonable steps are taken to prevent acts of bribery. The Act, which applies to our business activities worldwide, is considered more onerous than the US Foreign Corrupt Practices Act (FCPA), which has resulted in many high-profile prosecutions in recent years. You can find an overview of some key features of the UK Bribery Act here.
The Bribery Act criminalises bribery in both the commercial and public sectors. It is not limited to bribery that could be committed by a company's own staff but also covers individuals or companies working on a company's behalf. Successful prosecution under the Bribery Act can lead to unlimited fines for companies and individuals and jail sentences of up to 10 years. The only defence against an act of bribery being committed by a member of staff or an individual or company working on our behalf is to have in place ‘Adequate Procedures' to prevent bribery. The UK Government, as a requirement of the UK Bribery Act, published their Adequate Procedures Guidance on 30 March 2011.
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