ANTI CORRUPTION COMPLIANCE

Anti-corruption compliance is an important part of our operational framework. We are determined to act as a key stakeholder in fighting corruption in all sectors we operate. Corruption not only puts our company and employees at risk of criminal prosecution but it destroys our hard earned reputation. Building on a strong framework with a focus on continuous improvement, is extremely important as we work towards being an exemplary leader in the fight against corruption.

Anti-corruption standards and procedures

SMCS GROUP’s Code of Conduct and Anti-Corruption Policy clearly prohibits bribery and corruption in all our business dealings. We prohibit facilitation payments to government officials in order to progress our operations. The obligations for our employees, partners and contractors are clear and the Company provides training and support to ensure these obligations are understood. Senior management are required to incorporate anti-corruption compliance into business key performance indicators.

Our anti-corruption policy applies to our third party engagements. A risk-based system is used to assess business partners and determine due diligence and other compliance requirements prior to approval. All suppliers must comply with various minimum requirements, including adopting SMCS GROUP’s anti-corruption policy and expectations in relation to anti-corruption compliance.

Anti-corruption risk assessments

SMCS GROUP’s Management are required to conduct regular anti-corruption risk assessments. Risk assessments form a critical part of our operations, ensuring that an adequate set of controls has been adopted to mitigate risks.

Anti-corruption training

All of SMCS GROUP’s employees undertake anti-corruption training both on starting their employment and during regular training programs.

Confidential reporting and investigations

Reporting suspected corruption issues is encouraged at SMCS GROUP. Any retaliation against someone who speaks up and reports an issue is prohibited by our Code of Conduct and faces instant dismissal from their employment at SMCS GROUP. The Group CEO manages investigations into all potential anti-corruption issues.