| 1. Anti-Bribery Policy
It is our policy to conduct
all of our business in an honest and ethical manner. We take a
zero-tolerance approach to bribery and corruption and are
committed to acting professionally, fairly and with integrity in
all our dealings wherever we operate. We are also committed to
implementing and enforcing effective systems to counter bribery.
2. Who is covered by the policy?
This policy applies to all
individuals working at all levels and grades, including senior
managers, directors, employees (whether permanent or temporary),
consultants, contractors, and any other person providing
services to us.
3. What is a bribe?
A bribe is a financial or other advantage
offered or given:
- to anyone to persuade them to or reward
them for performing their duties improperly or;
- to any public official
with the intention of influencing the official in the
performance of his duties.
4. Gifts and Hospitality
This policy does not prohibit
giving and receiving promotional gifts of low value and normal
and appropriate hospitality. However, in certain circumstances
gifts and hospitality may amount to bribery and all employees
must comply strictly with Domino’s ethics policy in respect of
gifts and hospitality. We will not provide gifts or hospitality
with the intention of persuading anyone to act improperly or to
influence a public official in the performance of his duties.
5. Facilitation payments and kickbacks
We do not make, and will not
accept, facilitation payments or “kickbacks” of any kind.
Facilitation payments are typically small, unofficial payments
made to secure or expedite a routine government action by a
government official. Kickbacks are typically payments made in
return for a business favour or advantage. All employees must
avoid any activity that might lead to, or suggest, that a
facilitation payment or kickback will be made or accepted by us.
6. Donations
We do not make contributions
of any kind to political parties. No charitable donations will
be made for the purpose of gaining any commercial advantage.
7. Record Keeping
We will keep financial records
and have appropriate internal controls in place which will
evidence the business reason for making any payments to third
parties.
8. Raising Concerns
Employees will be encouraged
to raise concerns about any issue or suspicion of malpractice at
the earliest possible stage. No employee will suffer any
detriment as a result of raising genuine concerns about bribery,
even if they turn out to be mistaken.
9. Monitoring
The effectiveness of this
policy will be regularly reviewed by the Management. Internal
control systems and procedures will be subject to audit under
the internal audit process.
|
