It is Crown’s policy to conduct business with a zero-tolerance approach to bribery and corruption. Crown is committed to acting professionally, fairly and with integrity and in compliance with local laws. We continue to improve, implement and enforce systems to counter bribery and corruption in our business dealings and relationships.
As with any global business, this comes with challenges when doing business in almost every country of the world. In 2015, Crown focused on further assuring full compliance in every country, including those with less developed legislation on anti-bribery and corruption (ABC). This requirement will cover every service segment, even those most at risk. To facilitate 100% compliance, all service providers are to be vetted, trained and will sign our Service Partner Agreement (which will includes a provision that we can audit their accounts at any time). This will enable us to more easily conduct periodic audits, especially in high-risk locations.
These enhancements are targeted to be fully implemented by early 2016. Service partners undergo training on anti-bribery and corruption through our "Doing Business without Bribery" program. In 2015, 23% of service partners completed the course and in 2016, we are targeting completion by 50% of partners. We are specifically targeting service partners in areas with low levels of existing corporate governance.
Every year, our own people receive training on our Anti-Bribery and Corruption Policy; this also helps our people learn how to identify and avoid supporting improper practices of others.
Employees also review and acknowledge our documented global Code of Conduct. This details expectations of every employee when it comes to business integrity. Acknowledged by employees annually through Crown’s performance management system, these include rules on appropriate practices related to:
- Conflicts of interest
- Securities and antitrust laws
- Agreements with competitors, customers or licensees
- Relationships with public officials
- Bribery, kickback and fraud
- Sanctions and trade embargoes
Also available to all our employees is an ethics and compliance hotline to anonymously report any suspicious activities. These programs are driven by Crown’s Chief Risk Officer and Group Compliance Officer, roles which work independently and impartially to uphold our objective to work against corruption in all forms.