In addition to a comprehensive procurement policy approved by our Board of Directors and which policy includes provisions and procedures pertaining to the tendering process for the procurement of goods and/or services, there is a robust compliance program and culture within our business which has oversight and scrutiny from our Board of Directors.
As part of that robust compliance program, we require full compliance with all the applicable principles and provisions of the U.S. Foreign Corrupt Practices Act of 1977 (FCPA), the UK Bribery Act 2010 and similar relevant legislation by all of our employees, consultants, distributors, customers, contractors, suppliers, counterparties and other stakeholders. In addition, we have in force a written code of conduct and business ethics, and whistleblowing policies to support our strong compliance culture.
Finally, in relation to any procurement of goods and/or services, we contractually require each party to undertake that, at the date of the entering into force of the contract, itself, its directors, officers or employees have not offered, promised, given, authorized, solicited or accepted any undue pecuniary or other advantage of any kind (or implied that they will or might do any such thing at any time in the future) in any way connected with the contract and that it has taken reasonable measures to prevent subcontractors, agents or any other third parties, subject to its control or determining influence, from doing so.