Ethics, Bribery and Corruption Policy

By adopting and displaying this ethics policy, the shareholders, management, and all employees of Paterson & Cooke commit to conducting our business in an ethical manner. We will do this by performing our work in a way that complies with the highest possible standards relating to fraud, corruption and bribery.

Any employee who breaches this policy (or the spirit of this policy) will face disciplinary action, which could result in dismissal for gross misconduct. Where a breach of this policy amounts to an offence under the applicable local law or regulations, the employee concerned may face criminal prosecution.

This policy applies to all persons working for us, or on our behalf in any capacity, whether full-time, part-time, or as sub-contractors.

A bribe is a financial or other inducement for an action which is illegal, unethical, a breach of trust or improper in any way. Bribes may take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage that is intended to influence a decision. Corruption means any form of abuse of power for business and/or personal gain.

Specifically, we will not:

  • Give or offer any payment, gift, hospitality or other benefit in the expectation or hope that a business advantage will be received in return, or to reward any business received
  • Accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for that party or anyone else
  • Give or offer any payment to a government official in any country to facilitate or speed up a routine or necessary procedure
  • Engage in any other activity that might amount to bribery, corruption, a conflict of interest or otherwise lead to a breach of this policy

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

To facilitate the principles embodied by this policy, Paterson & Cooke will maintain continual awareness of ethical standards through visible engagement with employees.
In turn, each Employee is required to contribute by acting in accordance with the requirements and in the spirit of this policy.