The business ethics of MYTILINEOS Group are reflected in its steadfast opposition to all practices which invalidate competition, give rise to procedures lacking in transparency and compromise the very essence of entrepreneurship. In our view, corruption, bribery and extortion undermine the moral environment of businesses and have a broad range of negative effects that include violations of Human Rights, impacts on the environment, distortion of the competition and impediments to the distribution of wealth and economic development. They represent a major hindrance to sustainable Development, have a disproportionate impact on poor communities and corrode the very fabric of society.
In MYTILINEOS Group, the reference for our efforts to promote transparency is our corporate value that refers to the “PRINCIPLE OF INTEGRITY”, which relates to our longstanding commitment to ZERO TOLERANCE for corruption and bribery and is implemented by avoiding all transactions and contacts with any party which may be guilty or suspect of encouraging conditions giving rise to corruption, extortion or bribery. Furthermore, our publicly declared commitment to Principle 10 of the UN Global Compact, according to which “We work against corruption in all its forms, including extortion and bribery”, is a catalyst for the development of our subsidiaries’ corporate culture regarding the promotion of transparency. To this end, our aim as a Group is to evaluate and improve our procedures for managing the risk of corruption and to verify that the operations of our subsidiaries, as well as those of our major suppliers and business partners, comply with our established policies and procedures, as these are defined in the Professional Ethics Code, in the Internal Rules of Operation of the individual Group companies and in the Suppliers’ & Business Partners’ Code of Conduct, always ensuring our full alignment with the laws and regulatory provisions in force.
Our policy on addressing corruption is organised in three key stages:
The first stage involves the analysis of the prevailing conditions and the identification of potential risks or threats which may encourage the occurrence of non-ethical incidents in our corporate environment. These are implemented through annual self-evaluations and internal preventive audits with a view to introducing measures to combat corruption at the level of the Group’s subsidiaries, in parallel with a relevant internal audit programme at the Group level. This analysis is an important and necessary management practice which helps assess the likelihood of occurrence of instances of corruption or bribery in several sensitive areas, such as charity contributions, sponsorships, facilitation payments, gifts and hospitality, with a view to formulating relevant policies but also to establishing the procedures – where these are not in place – which are required to deal with such instances.
Thesecondstagerefers to ensuring that all transactions carried out on behalf of the Group by our shareholders, employees, subsidiaries and major business partners and suppliers are characterised by a high level of integrity and by high moral standards. Through established procedures, applying primarily in our Purchases and Procurement Units for the selection of suppliers and other business partners, we check the conditions under which every single transaction is carried out, in order to identify and eliminate those which may give rise to incidents of corruption.
The third stage refers to our operation as a “Responsible Corporate Citizen”, reflected in a number of voluntary initiatives such as: adherence to market rules; participation in international standards to strengthen transparency; establishing transparency as an important item on the agenda of the ongoing dialogue with our key Stakeholder groups; the provision of education and training on anti-corruption policies and procedures to our employees of all levels; and in general our dedication to ethical business practices and proper corporate governance.
Our goal is to eliminate completely our exposure to corruption, as we firmly believe that strengthening transparency in all transactions connected with the Group’s business activities is crucial key to its sustainability.