Effective July 2026
Purpose & scope
Privy Consul Anti-Bribery and Anti-Corruption Policies and Procedures set out the policies and procedures for identifying, preventing and avoiding corruption and bribery for Privy Consul and each of its direct and indirect subsidiaries (collectively, Privy Consul).
The policies and procedures apply to all persons involved in Privy Consul's business, including people working on Privy Consul's behalf, managers, shareholders, officers and directors (collectively referred to as employees).
Policy
It is the policy of Privy Consul to conduct all its business in an honest and ethical manner. Privy Consul takes a zero tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever Privy Consul operates.
Privy Consul and its employees (or someone on the employee's behalf) must not engage in any activity that might lead to a breach of its Anti-Bribery and Anti-Corruption Policies and Procedures.
Anti-Bribery committee
An Anti-Bribery Committee has been established which is responsible for implementing the requirements of the policies and procedures, including considering applications and investigating reports, monitoring effectiveness and arranging adequate and regular training.
Payments, gifts & hospitality
Privy Consul does not make, and will not accept, facilitation payments or 'kickbacks' of any kind.
Privy Consul and its employees (or someone on the employee's behalf) must not give, promise to give, or offer, a payment, gift or hospitality (except normal and appropriate gifts or hospitality as set out in the policies and procedures) (i) with the expectation or hope that a business advantage will be received, or (ii) to reward a business advantage already given; or (iii) to a government official, agent or representative to 'facilitate' or expedite a routine procedure.
Privy Consul and its employees (or someone on the employee's behalf) must not accept a payment, gift or hospitality (except normal and appropriate gifts or hospitality as set out in the policies and procedures) from a third party that an employee knows or suspects is offered or provided with an expectation that a business advantage will be provided by Privy Consul in return.
Privy Consul reserves the right to review each situation as it arises and may approve a specific gift or hospitality upon application to the Anti-Bribery Committee in accordance with the policies and procedures.
Political & charitable donations
Privy Consul does not make contributions to political parties. Privy Consul only makes charitable donations that are legal and ethical under local laws and practices. Privy Consul has Corporate Social Responsibility Committees in each office which receive, review and decide upon all donation and sponsorship requests in accordance with its CSR policy, priorities and established practice.
Reporting & whistleblower protection
Employees must adhere to the reporting and disclosure requirements set out in the policies and procedures. Privy Consul and its employees (or someone on the employee's behalf) must not threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under the policies and procedures.