34 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT Corruption involves the abuse of a position of employment, authority or trust to gain an advantage in breach of duty. Such behaviours are illegal in most countries. A breach of anti-bribery or corruption laws is a serious offence, which can result in significant fines or imprisonment for you and/or the Group. Even the perception of bribery, or corruption, can have a serious impact on our reputation. A facilitation payment is the offering or providing anything of value to a foreign official for the purposes of securing an unfair business advantage. 4. OUR BUSINESS the purpose of improperly securing a private or business benefit or advantage, or the improper performance of a function or activity. WHEREVER WE OPERATE, WE DO SO IN ACCORDANCE WITH THE HIGHEST ETHICAL STANDARDS AND WITHIN THE LETTER AND SPIRIT OF THE LAW. WE DO NOT TOLERATE ANY FORM OF CORRUPTION, BRIBERY OR FACILITATION PAYMENT. THIS IS HOW WE PROTECT OUR REPUTATION. Bribery is the offering, giving, granting, promise or acceptance of any payment, gift, promise, benefit, favour or anything of value, whether directly or through a third party, which is to, or from any person or entity for: REFERENCES: • Anti-Corruption Operating Standard
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