We make good decisions and maintain the trust of our investors if the Albemarle financial information provided to them is accurate and complete. Albemarle maintains internal controls to ensure that our books and records fully and objectively reflect our business and financial transactions and their underlying business purpose in a materially accurate manner.
- We only execute transactions in accordance with this Code, applicable policies and laws. It is our personal responsibility to know those requirements.
- We only approve transactions within the scope of our delegated authority.
- We validate transactions and the source, destination and transmission of funds through appropriate supporting documentation.
- We do not intentionally create false, incomplete or misleading entries in our books or records.
- We do not use Albemarle funds or assets in violation of our Code or applicable law.
- We do not establish or maintain undisclosed or unrecorded Company funds or assets.
- We record all intercompany transactions at arm’s length, and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
- We are honest, transparent and timely in our engagement with auditors and tax authorities.
- We immediately report concerns with the accuracy of our books and records, the integrity of our internal controls or any suspected fraud.
- We collect and understand documentation about prospective business partners to ensure that they are involved in legitimate business activities and that their funds come from legitimate sources.
Our Code Principles in Action
- Ensure all expenses are correctly assigned to the correct General Ledger account.
- Employees outside of Treasury who undertake treasury/banking-related activity must be approved, in writing, by either the Treasurer or Chief Financial Officer.
- All foreign exchange transactions must be undertaken in accordance with the Financial Price Risk Management Policy.
- Provide Treasury with appropriate documentary evidence, and contact details for the payee, to support the transmission of funds.
- Familiarize yourself with the Guidance Notes on the Effective Monitoring of Third- Party Sales Representatives and Customers and the Effective Monitoring of Vendors. Check for red flags such as:
- overly complicated deal structures;
- requests from a business partner for cash payments;
- payments from payors that appear unrelated to the payee;
- unusual fund transfers to or from countries unrelated to the transaction;
- transactions that have been structured to evade recording or reporting requirements; or
- other suspicious payment terms.
- Retain documents relating to Albemarle’s business in accordance with the Document Retention Policy.
- Submit expenses in accordance with this Code (Managing your Business Expenses).
- Follow the Code (Engaging with Government Officials) when dealing with tax, customs and other government agencies.
- Obtain approval in accordance with this Code (Selecting and Managing Vendors), the Anti-Corruption Policy, the Global Procurement Policy and Compliance Sensitive Vendors Procedure before using a vendor who will engage with tax authorities or other government agencies on our behalf.
- Immediately contact Group Tax if an audit is initiated, or you are otherwise contacted, by any tax authority.
- Immediately report any suspected wrongdoing or irregularities related to financial accounting, reporting or business activities in accordance with this Code (Speaking Up – Raising Code of Conduct Concerns) and the Investigations Policy.