Corporate Social Responsibility Report 2018

GRI 205: Anti-corruption

205-1 Operations assessed for risks related to corruption Our business activities are subject to a number of laws that prohibit various forms of corruption, including local laws that prohibit both commercial and governmental bribery and anti-bribery laws that have a global reach, such as the FCPA and the UK Bribery Act. Additionally, our business activities are subject to various economic and trade sanctions programs and import and export control laws, including (without limitation) the economic sanctions rules and regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), which prohibit or restrict transactions or dealings with specified countries and territories, their governments, and-in certain circumstances, their nationals, as well as with individuals and entities that are targeted by list-based sanctions programs. We maintain written policies and procedures and implement anticorruption and anti-money laundering compliance programs, as well as programs designed to enable us to comply with applicable economic and trade sanctions programs and import and export control laws (“Compliance Programs”). Through our Enterprise Risk Management Program, we maintain a systematic, disciplined approach to evaluating and improving the effectiveness of governance, internal controls and risk management processes throughout our global operations. We carry out annual Global Enterprise Risk Assessments which include corruption risk. In 2018, key risks included the need to reinforce ongoing vigilance in complying with the U.S. Foreign Corrupt Practices Act (the “FCPA”), the UK Bribery Act and other anti-bribery, anti-money laundering and corruption laws.

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