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 any company found having taken part in corruption could risk an unlimited fine and face damage to its’ reputation. We therefore take our legal responsibilities very seriously.
In 2014-15 we implemented a group wide anti-corruption policy and this is an area of continuous focus since corruption and bribery remain critical improvement areas in the global business environment as well as in the political establishment.
We have never discovered any lawlessness within our own organization and we are aware of the risks and have identified the most critical areas of risk and informed our organization clearly about the company policy and responsible conduct on anti-corruption.
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
Employees working within or close to these areas are all trained in our anti-corruption policy.