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KEY RESULTS OF THE SELF-ASSESSMENT CARRIED OUT BY THE MYTILINEOS GROUP
SUBSIDIARIES REGARDING THE DEVELOPMENT OF TRANSPARENCY
AREAS INVESTIGATED
POLICIES
PROCEDURES
POLITICAL CONTRIBUTIONS
CHARITABLE CONTRIBUTIONS
SPONSORSHIPS
FACILITATION PAYMENTS
GIFTS AND HOSPITALITY EXPENSES
GENERAL DIRECTIONS
1. Formulation of specific policies, such as a policy on the protection of employees in the
event of complaints being made about incidents or cases of corruption or bribery.
2. Revision of the Group’s Professional Ethics Code.
3. Provision of training in the Code of Conduct for Suppliers and Business Partners to the
Group subsidiaries.
1. Full inclusion of the subject of combating Corruption and Bribery in the consultations
with our Stakeholders.
2. Development of a special-purpose handbook with guidelines on the prevention / avoid-
ance of corruption and bribery.
3. Provision to the Group's top management executives of training in the importance of the
laws against corruption and bribery.
4. Design of training for employees, senior executives and supervisors, in connection with
the company's positions against corruption and bribery and with the procedures for the
imposition of sanctions in cases of violation of its policy.
5. Design of a communication procedure through which employees and third parties may
be provided with relevant information and advice and/or lodge complaints about incidents
involving corruption and bribery without fear of retaliation.
6. Design of a procedure allowing the termination of business agreements where the con-
tractors, suppliers or subcontractors were involved or are suspected of being involved in
incidents of corruption or bribery which are contrary to the principles of the Group.
7. Design of a verification procedure for the Group’s key suppliers and business partners, in
order to ensure their adherence to policies and procedures that combat corruption and
bribery.
MYTILINEOS Group has nothing to do with financial and in-kind contributions to political
parties, politicians and related institutions.
1. Formulation of a written policy to cover ”Charitable Contributions”.
2. Development of a procedure for the review and approval of “Charitable Contributions”,
based on specific criteria which will also cover Corruption and Bribery.
3. Revision of auditing procedures in order to ensure that “Charitable Contributions” are
not used as a means to encourage incidents of corruption and bribery.
1. Formulation of a written policy to cover ”Sponsorships”.
2. Revision of auditing procedures in order to ensure that “Sponsorships” are not used as
a means to encourage incidents of corruption and bribery.
MYTILINEOS Group has nothing to do with “Facilitation Payments”. Nevertheless, the for-
mulation and promotion of a written policy prohibiting “Facilitation Payments” to all Group
subsidiaries is considered necessary.
1. Definition of the terms “Gifts” and “Hospitality Expenses” for the Group.
2. Formulation of a formal policy prohibiting the use of “Gifts” and “Hospitality Expens-
es” which might influence or be assumed to influence the outcome of business agreements
and are not reasonable expenses made in good faith.
3. Establishment of communication channels for dissemination to the Group’s employees
of the guidelines on handling cases involving giving or receiving “Gifts” and “Hospital-
ity Expenses”.
