Standard for the Prevention of Bribery & Corruption

Definition

Bribery and corruption includes any activity or transaction involving the offer or acceptance of a financial or other benefit intended to encourage improper or unfair action in the award of business or execution of duties.

The standard covers state-awarded business, business between commercial entities, business awarded to Soletec, and business awarded by Soletec to vendors and subcontractors.

• Payments intended to influence business awards.
• Lavish gifts or entertainment intended to influence a transaction.
• Political or charitable donations intended to unfairly influence business.
• Improper payments to officials to overlook taxation, customs, or other requirements.

Business Principles

The standard is based on ten business principles for preventing bribery and corruption in Soletec business practices.

• Soletec is committed to preventing bribery and corruption in all forms.
• Business awarded to or by Soletec must be fair, legal, and free from bribery or corruption.
• Gifts and entertainment must not unfairly influence, or appear to influence, contract awards.
• Facilitation payments are not condoned except in exceptional circumstances such as threats to personal safety.
• Political contributions using Soletec funds or in Soletec's name are prohibited.
• Charitable, community, and CSR donations must not be connected to bribery or corruption.
• Actual or suspected bribery and corruption will be investigated promptly and in confidence.
• Accurate records must be maintained to demonstrate the effectiveness of the risk management system.

Delegation of Authority and Code of Business Conduct

This standard sets rules for preventing bribery and corruption in third party transactions. Managers with decision-making authority should understand and comply with the relevant delegations of authority and business unit authority limits.

The standard is consistent with the broader principles in the Soletec Code of Business Conduct. Each business unit should ensure employees understand the Code and uphold its principles at all times.

Observing This Standard

If any aspect of the standard is unclear, or if there is uncertainty about how it applies to a specific issue or transaction, the matter should be referred to the director responsible for risk and compliance.

Where there is doubt about whether an activity involves, or may be perceived to involve, bribery or corruption, it should be escalated before proceeding.

Third Party Risk Assessment

Soletec must conduct adequate risk analysis and due diligence on significant third party relationships before contractual commitments are entered into. Failure to demonstrate risk consideration can expose Soletec if bribery or corruption subsequently occurs.

The risk assessment should consider ownership structure, connections to government officials, history of illegal activity, legitimacy of the business, experience and capability, payment arrangements, and commitment to anti-bribery standards.

High risk relationships

High risk third parties may require review by the business unit risk review committee, additional investigation, contractual protections, annual certification, and ongoing monitoring.

Gift Giving, Receiving, and Entertainment

Modest gifts and appropriate entertainment may be part of normal business relations, provided they are transparent and not designed to unfairly influence a business transaction.

Gifts or entertainment must not be lavish, improper, or offered or accepted in circumstances that could create a perception of influence over the award of business.

Facilitation Payments, Contributions, and Donations

Soletec does not condone facilitation payments and is committed to combating facilitation payment culture wherever it is encountered, except under exceptional circumstances such as threats to personal safety.

Political contributions of any kind in the name of Soletec, or using Soletec funds, are prohibited. Charitable, CSR, and local community donations may be supported only where they are not connected to bribery or corruption.

Travel and Expense Reimbursement

Each business unit is responsible for establishing and documenting travel and expense reimbursement policies and procedures. Those controls should be sufficient to identify and prevent bribery and corruption risks and should comply with the corporate travel and expenses policy.

Investigation and Reporting

Investigation and reporting of suspected bribery and corruption, whether involving a Soletec employee or a connected third party, is an essential part of the risk management system.

Employees are responsible for immediately reporting suspected bribery or corruption to a line manager or the director responsible for risk and compliance. Concerns may also be raised by email at info@soletec.com.

Maintaining Records and Monitoring Implementation

Proper records of transactions and risk assessments are essential to the risk management system. Without accurate records, it is not possible to demonstrate an adequate framework of controls.

Business units are responsible for implementing the standard, monitoring compliance, maintaining records of risk assessments and approved exceptions, and conducting reviews or audits of high risk third parties where appropriate.

Appendices and Supporting Tools

The PDF includes supporting appendices for high risk countries, a third party risk assessment questionnaire, high risk factors, and contract wording for high risk third parties such as joint ventures, consortium arrangements, agent consultants, vendors, and subcontractors.

These appendices support consistent documentation, due diligence, contractual protection, and auditability across relevant third party relationships.