Anti-Corruption and Anti-Bribery
We earn business based on the quality of our products and services.
OUR COMMITMENT
We know that bribery and corruption not only harm CoorsTek and our customers, but also the communities where we do business. When business decisions are influenced through improper payments, rather than through transparent and fair proposals, resources are not efficiently allocated and low quality products and services at artificially high prices enter the market.
This is why we strictly prohibit any form of bribe, kickback, illegal payment, extortion or other corrupt arrangement with customers, suppliers, government officials, and other third parties.
OUR EXPECTATIONS
GOVERNMENT OFFICIALS
You must never offer or pay a bribe to a government official.
BRIBE
A “bribe” is anything of value given for the purpose of influencing a discretionary decision, such as encouraging a decision to obtain or retain a government contract, influencing the outcome of a government audit or inspection, or impacting tax or other legislation. A bribe does not need to be a cash payment – it can also include gifts, entertainment, donations, offers of employment, and anything else of value, regardless of the amount, given with the purpose of influencing a decision.
GOVERNMENT OFFICIAL
A “government official” is a person who works for or is an agent for a government, a government owned entity, or a government controlled entity, such as:
- Government and regulatory agency employees
- Candidates for political office, political parties or officials of political parties
- Elected or local officials
- Members of law enforcement, including military and local police
- Representatives or employees of public international organizations (e.g. United Nations) or charities (e.g. UNICEF)
- Relatives of any of the above
You must also never allow an external party, such as a sales representative, to offer or pay a bribe to a government official on our behalf. CoorsTek and its employees may be held responsible for bribes paid by external parties working for us, and so particular care must be taken not to engage any external party that is suspected of attempting to bribe a government official.
You should also never make a facilitation payment to a government officials. A “facilitation payment” is a small payment to an individual government official to secure or speed up a routine, non-discretionary government action, such as obtaining ordinary licenses or customs clearances.
If you find yourself in a situation where your or another person’s immediate personal safety is in danger and a facilitation payment can assure your safety, then you should make this payment, but it must be reported immediately to the CoorsTek Legal Department.
What If?
Q: An employee at one of our government customers asked if I can help his daughter get a position at CoorsTek. Should I help her?
A: You can provide this government employee information about the positions available at CoorsTek and how to apply for them as all other candidates do. Doing anything more than that could give the appearance of giving a bribe to the government employee.
COMMERCIAL BRIBERY AND KICKBACKS
Some countries, such as the U.K., also prohibit bribes to or from anyone, not just government officials. To ensure compliance with these commercial bribery laws, as well, you should:
- Never solicit or accept a bribe or kickback from any customer, supplier, or anyone who does or is seeking to do business with CoorsTek
- Never offer or give a bribe or kickback to any customer, supplier, or anyone who does or is seeking to do business with CoorsTek
- Always refer to Gifts & Entertainment under the Conflicts of Interest section of our Global Standards when interacting with any commercial partners of CoorsTek
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