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Global Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling anti-bribery compliance problems/ corrective actions Training and Education Gifts and Hospitality Socioenvironmental investments Suppliers Joint ventures, consortia, and other associations Selection and compensation of employees and managers Books, records, and financial reporting Internal auditing and monitoring Appendices

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Page 1: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Global Anti-Corruption Compliance Manual

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 2: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

I

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 3: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 4: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Anti-CorruptionPolicy

II

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 5: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 6: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 7: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 8: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 9: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Corporate IntegrityDepartment

III

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 10: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 11: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

oIntroduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

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Page 12: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 13: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Handling anti-bribery compliance problems &corrective actions

IV

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 14: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Under no circumstances must the reporting of any such potential violation or impropriety serve as a basis for retaliation and intimidation against any employee who acted – or made such report – in good faith.

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 15: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 16: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Training andEducation

V

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 17: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 18: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Gifts andHospitality

VI

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 19: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 20: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 21: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 22: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 23: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

o

oIntroduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 24: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 25: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 26: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

oIntroduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 27: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

SocioenvironmentalInvestments

VII

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 28: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 29: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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*subject to applicable labour laws and the terms of negotiated collective bargaining

rights.

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 30: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Suppliers

VIII

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 31: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

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*Service providers, suppliers of materials or equipment, vendors, agents, distributors,

brokers, consultants, representatives, other contractors or suppliers, and other

intermediaries paid to represent Vale. Supplier does not include customers or recipients of

socioenvironmental investments. Separate rules apply for Government Authorities.

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 32: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

o

o

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

*Employees may use a risk classification questionnaire provided by the Corporate Integrity department (e.g., the Initial Risk Assessment Questionnaire) to establish the Supplier's level

of corruption risk, or request the Supplier to complete such questionnaire.

Page 33: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

o

o

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 34: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

o

o

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 35: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Appendices

Page 36: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Joint ventures, consortia, and other associations

IX

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 37: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

o

o

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 38: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Selection and compensation of employees and managers

X

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 39: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 40: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Books, records, and financial reporting

XI

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 41: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

o

o

o

o

o

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 42: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Internal auditing and monitoring

XII

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 43: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 44: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Appendices

XIII

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 45: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 46: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 47: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 48: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

Page 49: Global Anti-Corruption Compliance Manuals Global... · 2020-05-26 · Anti-Corruption Compliance Manual Introduction Anti-Corruption Policy Corporate Integrity Department Handling

Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

o

o

o

o

o

o

o

o

o

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

o

o

o

o

o

o

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

§

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

§

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

§

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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Appendices

Introduction

Anti-Corruption Policy

Corporate Integrity Department

Handling anti-bribery compliance

problems/ corrective actions

Training and Education

Gifts and Hospitality

Socioenvironmental investments

Suppliers

Joint ventures, consortia, and

other associations

Selection and compensation of

employees and managers

Books, records, and financial

reporting

Internal auditing and monitoring

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