Makro's Anti-Corruption Policy
Makro’s Business Principles are founded in integrity, honesty and respect. One of the key pillars of the Makro Business Principles is anti-corruption. This is given greater focus in the UK by the introduction of the Bribery Act 2010.
The Makro board’s zero tolerance position on corruption is clear: members of our team do not offer or accept bribes. The direct or indirect offer, payment, soliciting or acceptance of bribes in any form (which can include favours, gifts or hospitality) by Makro employees, is unacceptable.
This stance on bribery and corruption reaches out to include business partners, agents, joint venture partners, contractors and suppliers. Makro expects its employees to comply with all relevant laws regarding improper payments to foreign officials.
For the purposes of Makro’s anti-corruption policy there is no distinction between bribes and facilitation payments; such payments are also prohibited. A facilitation payment is an immaterial payment to a public official, which is not required or permitted by law, to enable or speed up a process which it is the official’s job to arrange.
The zero tolerance approach adopted by Makro’s board expects employees to never accept or give a bribe, facilitation payment or other improper payment no matter what the circumstances may be. Employees should bear in mind that this can include gifts, or anything of value that is provided in return for improper performance. This will
apply to dealings with government officials or any private company or individual. It makes no difference that the employee arranges for the payment to be made via a third party.
To assist employees and business partners, Makro has set down its zero tolerance approach in more detail in the following documents (http://mcc.uk.metrogroup-networking.com/intranet/site/mcc-gb/node/217126873/Len/index.html):
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1.
The Metro Anti-Corruption Guidelines
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2.
Makro’s Gifts and Corporate Hospitality Policy
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3.
The Metro/Makro business principles
As part of Makro’s zero tolerance approach to corruption, the board has also taken the following steps:
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1.
implemented a risk assessment to identify risk areas where control measures can be introduced;
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2.
endorsed a thorough face to face training program for all employees in medium to higher risk roles;
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3.
used key communications paths to improve awareness of the policy;
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4.
introduced recording systems for supplier due diligence, corporate hospitality / gifts and dealings with public authorities;
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5.
underpinned the culture with continuing audits to ensure compliance.
