INTRODUCTION
Most countries have laws that prohibit corruption and bribery. Increasingly
these laws will extend to payments to foreign entities or individuals
outside these countries’ own borders. Enforcement of anti-corruption and
bribery laws has stepped up significantly in the last decade, particularly
on the part of the US authorities and also in the UK with the introduction
of the Bribery Act. Penalties can be severe with fines running into millions
of dollars and fines and imprisonment for individuals. In addition illegal
arrangements (including contracts) are unenforceable.

Finally, the taint of bribery and corruption could do incalculable damage
to Alulines reputation.In recognition of the above Aluline has a clear
anti-bribery policy; encouraging employees to report any suspicion
of bribery; and will investigate rigorously any instances of alleged bribery.


ANTI BRIBERTY POLICY
Alulines employees must not directly or indirectly offer, promise, pay or give
a bribe to any person or authorise such a bribe, or accept a bribe.
This prohibition includes the use of contracts or consulting agreements to
channel payments to public officials, political parties, or political figures
including their relatives or business associates. The policy applies whether
or not payment is made to a public official. Breach of this policy will result
in disciplinary action up to and including summary dismissal.

INTERMEDIARIES OR THIRD PARTIES
Improper payments may not be made through third parties. Employees must
be diligent in appointing and monitoring contractors, agents and joint venture
partners. Specific rules apply within Aluline relating to the acceptable terms
of contracts with foreign agents and the regular monitoring of those agents.

PUBLIC/PRIVATE SECTOR
The division between the public sector and the private sector has become
blurred through privatisation, state owned enterprise, public finance initiatives,
joint ventures and government outsourcing. Bribery of government officials is
illegal. Bribery of those working in the private sector is also often illegal under
local laws and is always contrary to Alulines own business standards and
prohibited by this policy.

COMPLIANCE
Compliance with this Policy will be treated in the same manner as other
Aluline-wide policies. All Management will be required to sign a disclosure
statement each year acknowledging their receipt of a copy of this Policy; their
dissemination of the Policy to their direct reports; and their disclosure of any
known violations of the Policy.


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Our Anti-Corruption Policy