Anti-Corruption Management approach
The business ethics of MYTILINEOS Group
are reflected in its steadfast opposition to all
practices which invalidate competition, give
rise to procedures lacking in transparency and
compromise the very essence of entrepre-
neurship. In our view, corruption, bribery and
extortion undermine the moral environment
of businesses and have a broad range of neg-
ative effects that include violations of Hu-
man Rights, impacts on the environment, dis-
tortion of the competition and impediments
to the distribution of wealth and economic
development. In general, they are a major hin-
drance to sustainable development, with a
disproportionate impact on poor communi-
ties, and corrode the very fabric of society.
In our Group, the reference for our efforts to
promote transparency is our corporate val-
ue that refers to the “PRINCIPLE OF IN-
TEGRITY”, which relates to our longstand-
44
During 2013, we took a number of initiatives to improve our performance in this particular area. More specifically:
6.7 ACTIONS TO STRENGTHEN TRANSPARENCY
INITIATIVES
RESULTS
1. In each one of our subsidiaries, we implemented a self-
assessment procedure regarding our performance in
connection with actions to combat Corruption and
Bribery, drawing on the guidelines accompanying the
relevant tool of Transparency International.
2. We developed and are disclosing for the first time our
Management Approach to combating Corruption and
Bribery.
3. We developed a “Code of Conduct for the Suppliers
and Business Partners of MYTILINEOS Group”.
4. We included for the first time the subject of com-
bating Corruption and Bribery in the consultations
with our Stakeholders.
5. Through the procedures applied in the Purchases – Pro-
curement Units of our subsidiaries, we checked the
selection of business partners as well as all types of
transactions.
6. Through the Internal Audit System, we assessed the
relevant risks and verified the compliance of our sub-
sidiaries' operations with our established policies and
procedures, as these are defined in our Code of Pro-
fessional Ethics, in the Internal Regulation of each in-
dividual company, and in the laws and regulatory pro-
visions in force.
7. We upgraded our UNGC COP Differentiation Level
from Active to Advanced.
The methodology of this procedure enabled us to investigate any deficiencies
in terms of prevention policies and procedures as well as in terms of transac-
tions, focusing on sensitive areas which may involve circumstances encourag-
ing Corruption and Bribery. The key results from this procedure determine the
Group’s immediate goals in this particular area.
We developed our Management Approach in order to disclose our position of
zero tolerance for corruption and bribery, wherever these may come from, and
to establish our Management Approach as the basis on which our responsible
entrepreneurship initiatives are founded.
With this initiative, the Group is informing its key Suppliers / Business Partners
of its specific requirements and expects them to develop key policies and pro-
cedures against the risks of Corruption and Bribery. The Group will assess the
compliance of its Suppliers / Business Partners and will take it into considera-
tion in the selection procedure regarding the conclusion of business agreements.
During the presentation of our Social Footprint, we had the opportunity to dis-
cuss combating Corruption as a subject which our strict self-assessment has shown
to be the one with the most significant impact on society for our Group. Read-
ers are reminded that, in establishing our Social Footprint, the fact that from
its establishment to this day no incidents of Corruption have been recorded in
the Group, was not taken into account.
No incidents of Corruption or Bribery were recorded in the Group for 2013 as
a result of these actions.
In doing so, we strengthen our commitment to Principle 10 of the UN Glob-
al Compact and we move towards the gradual application of specific best prac-
tices that will help us implement our policy more effectively.
