Bribery Act Compliance

As a major global company we recognise the threat that bribery poses to economic progress and development around the world.
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We are fully supportive of countries implementing effective legal frameworks to combat bribery, helping to ensure that people are clear about their responsibilities to conduct business in an open and honest manner.

Failure to comply with the Bribery Act has serious consequences for all UK companies, of course. But as a long‑time champion of transparency and business ethics, G4S has warmly welcomed the new legislation. The Act will not only help G4S to strengthen its reputation as an ethical organisation but also make a major contribution to reducing the impact of bribery and corruption around the world.

Given the size and scale of our world‑wide operations there are considerable practical implications of ensuring that there are adequate procedures in place at every level of the organisation to prevent bribery and to comply with the requirements of the Bribery Act which became effective from 1 July 2011.

In 2011, we embarked on an extensive programme to analyse every business for risks related to corruption – reviewing our policies and procedures and introducing new policies where we felt they needed to be strengthened to comply with the “adequate procedures” required by the Act. As a result, we took a number of actions:
Policy Review: We reviewed a number of our policies and updated them, providing practical guidance for managers on specific points relating to the Act
Awareness: We embarked on a global awareness campaign to ensure all managers and employees understand the implications of the Act and our expectations in relation to their behaviour
Training: We created training materials and methodology – in 25 languages – specifically on business ethics and anti‑corruption, for implementation across the group – targeting around 20,000 people. We have also amended our employee induction programme to include the same business ethics and anti‑corruption training materials
Reporting: We launched a 24 hour global, multi‑language and toll free, hotline service to ensure that all employees have a simple means of reporting any non‑compliance with group policies or inappropriate behaviour

Compliance
In order to ensure our compliance with the Act we have implemented two new measures within our compliance and audit processes:
A specific questionnaire for management to complete at a country level to demonstrate their compliance with the group policies and procedures and also assess risk areas
The results are reviewed by regional and group management and action will be taken to make sure that any weaknesses or unacceptable risks are dealt with
A programme of audits to validate the anti‑bribery controls in our businesses focusing particularly on countries where there is a perceived high corruption risk (using the Transparency International corruption perception index and other factors).

For more information on our whistleblowing initiative, Speak out,  please read here.

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