Whitford Group Anti-Bribery and Corruption Statement

Whitford Worldwide Company and the entities that form the Whitford Group (Whitford) are committed to high standards of ethical behavior and have zero tolerance towards bribery and corruption. Whitford requires compliance with all anti-bribery and corruption laws in all markets and jurisdictions in which it operates. These laws include the UK Bribery Act, the US Foreign Corrupt Practices Act and the HK Prevention of Bribery Ordinance, as well as other similar laws and regulations in the countries where we operate.

Whitford’s Anti-Bribery and Corruption (AB&C) compliance program

Whitford’s Anti-Bribery and Corruption (AB&C) compliance program and policies are overseen by Whitford’s Board. Policies incorporate the results of regular risk assessments and emphasize that books and records must be fair, accurate and kept in reasonable detail. Whitford requires all employees, including the Board of Directors and Associated Persons, to comply with the principles in these policies in the performance of their services for or on behalf of Whitford.

Whitford’s Global AB&C Programme includes the following statement of principles:

  • It is unethical, illegal, contrary to Whitford principles and good corporate governance to bribe or corrupt others, including to:
  • Offer, provide, or agree to give anything of value to induce recipients to act improperly, whether directly or indirectly (e.g. to a close family member or other closely connected people); or
  • Offer or provide a facilitation payment. Exceptions may be permitted in limited circumstances where an employee’s health, safety and/or liberty is at risk;
  • Influence or attempt to influence Public Officials in order to obtain or retain business or an advantage in business.

Based on the principles above, the AB&C Program imposes the following requirements:

  • Associated Persons: All Whitford entities and individuals are required by policy to ensure that appropriate due diligence and controls are applied, according to policy, to any Associated Persons they engage, to ensure that they comply with the letter and spirit of applicable anti-bribery legislation and regulation;
  • Gifts, entertainment and charitable giving: All Whitford entities and individuals are required by policy to avoid offering, accepting or permitting any gift, entertainment, charitable giving, sponsorship or other advantages to be offered or accepted without the appropriate controls being applied;
  • Recruitment: All recruitment must be merit-based, fair, and in keeping with the stringent hiring standards applied for all employees. Hiring, for paid or unpaid, temporary or permanent roles, must not be used to influence third parties or to obtain or retain business or an advantage in business.
  • As part of the prevention, identification and remediation of AB&C issues, mandatory training is conducted throughout Whitford with the content tailored to the roles of the participants. Whitford carries out regular, risk-based assessments, monitoring and testing of its AB&C program.
  • Whitford also maintains clear whistleblowing policies and processes to ensure that individuals can confidentially, with no fear of retribution, report concerns to be investigated and remediated appropriately.