During 2014 we have developed and implemented our anti-corruption policy.
It is Spectre’s policy to conduct all our business in an honest and ethical manner. We have a zero-tolerance approach to bribery and corruption and we remain bound to the UK Bribery Act and the national legislations of the countries in which we operate.
Bribery and corruption are punishable for individuals and if Spectre is found to have taken part in corruption we could face an unlimited fine and face damage to our reputation. We therefore take our legal responsibilities very seriously.
To address the risks we have taken the following steps:
- Formulated and implemented an anti-corruption and bribery policy
- Conducted a risk assessment
- Trained all managers and relevant staff in our anti-corruption policy
We have identified that certain activities create particular risks for our company:
- Import/export of goods including contact to customs authorities
- Supplier contacts
- Price negotiations
- Quality audits
- Social audits
- Financial audits
- Payments of invoices
- Payments and contacts with tax authorities
- Salary payments (only bank transfer)
Employees working within or close to these areas are all trained in our anti-corruption policy.