Anti-bribery and ethical conduct

Nooryva does not pay bribes, and does not accept them. This page says what that means in practice in a trade where the question comes up at borders, ports and inspection points, and what we do when it does.

What is prohibited

Nobody acting for us, whether an employee, an agent, a broker or a subcontractor, may offer, promise, give, request or accept any advantage intended to improperly influence a decision. That applies whether the other party is a public official or a private business, and whether the advantage is money, a gift, hospitality, a job for a relative, or a favour.

Facilitation payments

Small unofficial payments to speed up a routine step are called many things, and in much of international trade they are treated as ordinary. We do not make them.

We are specific about this because vagueness here is how it happens. When a payment is demanded to release, clear or inspect a consignment that should be released, cleared or inspected anyway, our people are instructed to:

• refuse, politely and without argument;
• ask for the demand and its legal basis in writing, and ask for an official receipt;
• escalate to the company rather than settle it themselves at the counter;
• record what happened, whatever the outcome.

We expect this to cost us time, and sometimes money, and we accept that cost. No employee will ever be criticised or penalised for a delay caused by refusing to pay. That promise is the only thing that makes the policy real.

The one exception is a payment made under genuine duress, where someone’s safety is at risk. Safety comes first. Such a payment must be reported immediately afterwards and recorded accurately, and we will disclose it where we are required to.

Gifts and hospitality

Modest, occasional and open hospitality in the ordinary course of business is acceptable. Anything is not acceptable if it is cash or a cash equivalent, if it is offered around the time of a tender or a decision, if it would embarrass either party were it published, or if it is given privately rather than openly. If in doubt, decline it or declare it.

Agents, brokers and intermediaries

Most bribery risk in trade sits with third parties acting in someone’s name. We check who we appoint, we pay them a fee that matches the work they actually do, we require them to keep to this policy, and we do not pay success fees that have no explicable basis. A demand for payment into an unrelated jurisdiction or an unnamed account ends the arrangement.

Records

Every payment we make is recorded accurately in our books, for its true purpose. We keep no off-book accounts and no undisclosed funds.

Conflicts of interest

Anybody acting for us who has a personal interest in a supplier, a customer or a shipment must declare it and step out of the decision. An undeclared interest is the problem; a declared one usually is not.

Raising a concern

If you believe somebody acting for us has offered, paid, requested or accepted a bribe, write to . You may do so anonymously if you prefer, though it is easier for us to investigate if we can ask you questions.

Nobody who raises a concern in good faith will suffer for it. That holds whether the concern turns out to be right or wrong, and whether you work for us, for a counterparty, or for neither. Retaliation against somebody who reported in good faith is itself a dismissible matter.

Where this connects

How we handle controls, sanctions and declarations is in our trade compliance and sanctions policy. How we source, and what we expect of suppliers, is in our responsible sourcing policy.

Which language applies

This policy is published in every language this site is published in. If the versions disagree, the English version applies.