Government and regulatory decision-making directly affect our legal and social license to operate in every country in which Albemarle conducts business. We will proactively engage with governments on issues of concern to Albemarle, its businesses or its stakeholders (employees, investors, communities) to inform their decisions.
- We are courteous, truthful, cooperative and constructive when engaging with government officials.
- We apply or compete for government permits, licenses and business with humility, integrity, transparency and free of any conflict of interest.
- We prohibit all forms of bribery of government officials or activity which could give the impression of bribery, whether by our employees, contractors or third parties acting on our behalf. This includes the making of facilitation payments.
- We do not offer or provide anything of value directly or indirectly with the intent to improperly influence any government official in order to gain business or an improper advantage.
- We ensure that information we provide to government officials is accurate, timely and in accordance with applicable laws.
- We cooperate with any government request or investigation and answer questions honestly.
- We do not obstruct legitimate government investigations by intentionally withholding, concealing or destroying relevant documents.
- We do not retaliate or discriminate against anyone who reports wrongdoing or lawfully cooperates with a government inquiry or investigation.
Our Code Principles in Action
- Be aware that the definition of government official is broad, including employees of state-owned entities and community representatives.
- Consult with Government Affairs and any relevant country manager in advance of:
- Prepare a summary of any sensitive or non-routine meeting with government officials and provide a copy to Government Affairs.
- Consult with Government Affairs, Legal and the relevant country manager before making any non-routine submission or application to a government department or regulatory agency on behalf of the Company.
- Consult the Guidance Note on Engaging with Government Officials if you are unsure if your meeting or submission is sensitive or non-routine.
- Immediately notify the Legal Department if you are contacted by the police, military or a regulatory agency, or if any such authority makes an unscheduled visit to an Albemarle site.
- Follow this Code (Offering or Accepting Gifts & Hospitality) if you are considering offering anything of value, including gifts or hospitality, to a government official, or receiving the same from a government official.
- Follow the Code (Hiring New Employees) and Anti-Corruption Policy and obtain pre-approval before offering, promising or giving employment, a temporary contract or an internship to:
- Consult with Global Ethics & Compliance if your spouse, partner or a relative becomes a government official in a position of influence or authority over Albemarle’s business, and notify your supervisor in accordance with this Code (Disclosing a Potential Conflict of Interest).
- Obtain pre-approval accordance with the Political Contributions Policy and this Code (Making Political Contributions on Behalf of Albemarle) before making such contributions on behalf of the Company.
- ·Obtain pre-approval in accordance with the Global Procurement Policy and Compliance Sensitive Vendor Procedure before:
- Immediately contact Global Ethics & Compliance or the Legal Department if a government official requests a bribe or facilitation payment. If you feel your health, safety or security is under threat of imminent harm, this is considered an extortion payment and not bribery. If such a payment is required in order to avoid harm, make the payment, request an official receipt if possible to do so safely under the circumstances and immediately contact Global Ethics & Compliance or the Legal Department as soon as it is safe to do so.