Anti-Corruption and Anti-Bribery Statement
HDR conducts business honestly, fairly, ethically, free from corruption, and in compliance with all applicable laws. HDR does not engage in or tolerate bribery or corruption and we require our workforce, customers, and other business partners to comply with applicable anti-bribery and anti-corruption laws. These laws include the Bribery Act 2010 of the United Kingdom (often referred to as the UK Bribery Act), Canada’s Corruption of Foreign Public Officials Act, European Union’s November 2015 Anti-Corruption Law, Germany’s criminal code sections 331 to 338, Australia’s Crime Legislation Amendment, Singapore’s Prevention of Corruption Act and other bribery-related legislation, the People’s Republic of China criminal law and anti-unfair competition laws, Saudi Arabia’s Regulations for Combating Bribery, the Organization for Economic Cooperation and Development anti-bribery convention, and the World Bank Guidelines on Preventing and Combating Fraud and Corruption.
What are corruption and bribery?
Bribery is a form of corruption in which there is an abuse of entrusted power or position for private gain. A bribe is an inducement or reward offered, promised, provided, or received, directly or indirectly, to gain any commercial, contractual, regulatory, or personal advantage. It is a crime to offer, promise, give, request, or accept a bribe and individuals found guilty can be punished by imprisonment and/or a fine.
What are some examples of bribery?
Bribery can take many forms. Some examples could include:
- Offering a bribe, such as by offering a potential client tickets to a major sporting event if they agree to do business with you
- Receiving a bribe, such as by a supplier giving your nephew a job but making it clear that you must use your influence in your organisation to ensure your organisation continues doing business with the supplier
- Bribing a foreign official, such as by having your organisation to pay additional money to a foreign official to speed up an administrative process such as clearing goods through customs
What is unacceptable?
Bribery is unacceptable in all its forms. HDR considers it unacceptable for its workforce, customers, or other business partners to, for example:
- Give, promise to give, or offer, a payment, gift or hospitality with the expectation that a business advantage will be received
- Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure
- Accept payment from a third party that the recipient knows or suspects is offered with the expectation that it will obtain a business advantage for them
- Accept a gift or hospitality from a third party if the recipient knows or suspects that it is offered or provided with an expectation that a business advantage will be provided by the recipient’s organisation in return
- Threaten another worker who has refused to commit a bribery offence or who has raised concerns under HDR policies
- Engage in any activity that might lead to a breach of any applicable HDR policy
We do make charitable donations that are legal and ethical under local laws and practices. However, we do not make contributions to political parties. We will also never make facilitation payments (typically small, unofficial payments made to secure or expedite a routine or necessary action, for example by a government official to speed up customs clearances).
HDR keeps financial records and has implemented appropriate internal safeguards which evidence the business reason for making payments to third parties. HDR also keeps a written record of hospitality and gifts, given or received, in accordance with our internal policies. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers are prepared accurately and completely. We do not keep accounts "off-book" to facilitate or conceal improper payments.
HDR encourages its workforce, customers, and other business partners to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. HDR does not retaliate (or tolerate retaliation) against anyone for refusing to pay or accept a bribe even if such refusal results in a loss of business. HDR encourages openness and will support any employee who raises genuine concerns in good faith even if they turn out to be mistaken.
Any employee failing to comply with HDR’s anti-bribery and anti-corruption policies will face disciplinary action, which could result in punishment up to and including termination. We may terminate our relationship with consultants, contractors, suppliers, customers, and other business partners if they breach our anti-bribery or anti-corruption policies or any related laws.
For further information or to contact us about our anti-bribery and anti-corruption policies or any issues or suspicion of bribery or corruption, please contact us ethics [at] hdrinc.com.