Business Ethics

Zero tolerance of corruption and bribery, according to the main axes of the Corporate Social Responsibility Policy, the Code of Business Conduct and the Suppliers & Business Partners Code of Conduct.

By operating in developing countries with high energy needs, which according to the annual Transparency International Corruption Perception Index are countries with a high risk of corruption, MYTILINEOS may be exposed to risks involving facilitation payments or the extension of other benefits to the local partners in order to ensure the continuation of the projects’ smooth operation.

Addressing corruption and bribery is a key element of the MYTILINEOS Code of Business Conduct and its Suppliers and Business Partners Code of Conduct. For MYTILINEOS, the reference point when it comes to addressing corruption and bribery, is the principle of integrity, which relates to its long-standing commitment of zero tolerance of such issues. MYTILINEOS undertakes a number of measures to implement this commitment:

• MYTILINEOS has officially declared its commitment to the 10th Principle of the UN Global Compact, according to which “Businesses should work against corruption in all its forms, including extortion, bribery and facilitation payments”. This principle acts as a catalyst in establishing a culture of ethics across the Company.

• In order to tackle corruption and bribery, MYTILINEOS implements rigorous screening and due diligence practices of third parties before proceeding to an agreement or payment.

• MYTILINEOS avoids any transaction and contact with third parties that have participated in the creation of conditions for the development of incidents of corruption, blackmail or bribery.

• The Company conducts on an annual basis a risk study on potential corruption and bribery in its business activities and prescribes risk minimization measures, within the framework of Enterprise Risk Management.

• Both prevention and detection systems and controls have been established to ensure that suppliers are properly selected, disputed payments are avoided and the payments due are made correctly and are entered in the Company’s accounting books in an accurate and transparent manner.

• In countries with a high risk of corruption, the Company establishes a Grievance Mechanism, protecting complainants from eventual retaliation, while at central level, the grievance mechanism functions through the submission of reports of violations to the Director of Regulatory Compliance.

• The Company carries out unannounced audits on suppliers with the aim to ensure the implementation of Suppliers & Business Partners Code of Conduct.

• The Company ensures systematic training of personnel on the Code of Business Conduct by category of exposure to regulatory risk.

• GRI Standards
• SASB Standards
• UN Global Compact