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Corruption, bribery and extortion un-
dermine the moral environment of
businesses and have a broad range of
negative effects, as they can result in
violations of Human Rights, in adverse
impacts on the environment, in dis-
tortion of competition, and in im-
pediments to the distribution of
wealth and economic development. In
general, they are a major hindrance to
sustainable development, with a dis-
proportionate impact on poor com-
munities, and corrode the very fabric
of society.
In MYTILINEOS Group, the references
for our efforts to promote trans-
parency are the following two: Our
corporate value which refers to the
Principle of Integrity in all transactions
and which is implemented by avoiding
all transactions and contacts with
any third party which may be guilty or
suspect of encouraging conditions
giving rise to corruption, extortion or
bribery; and Principle 10 of the UN
Global Compact, according to which
“We work against corruption in all its
forms, including extortion and
bribery.”
Additionally, as the formal develop-
ment of an internal control mechanism
for prevention and detection of inci-
dents of corruption or bribery has not
yet been completed, we are taking
steps at the Group level to evaluate
and improve our risk management pro-
cedures and to verify the compliance
of our subsidiaries' operations with our
established policies and procedures, as
these are defined in our Code of Pro-
fessional Ethics, in the Internal Rules
of Operation of each individual com-
pany, and in the laws and regulatory
provisions in force. Furthermore, we
take care to ensure that the collabo-
rations and transactions of all share-
holders and employees, in all Group
companies, are characterised by a
high level of integrity and by high
moral standards. Through the proce-
dures for the selection of suppliers and
other associates which our Purchases
and Procurement Units have in place,
we check the conditions under which
every single transaction is carried out,
in order to identify and eliminate
those which may give rise to incidents
of corruption, extortion or bribery.
During 2012, we applied all neces-
saryinternal procedures to ensure
compliance with the aforementioned
principle. With regard to the above, no
reports were made of conditions
which may give rise to incidents of cor-
ruption in the Group companies, nor
have such conditions been identified
in them. Nevertheless, our plans for the
immediate future include the imple-
mentation of concerted preventive
actions, including the provision of
specific training to our employees of
all levels and the formal audit of our
business units for the existence of con-
ditions which may give rise to incidents
of corruption, bribery or extortion.
9.4 Actions to strengthen Transparency & combat bribery
