Traveling on Business

CODE PRINCIPLES

When we travel on behalf of Albemarle, we do so safely and responsibly.

  • We take every precaution to ensure our safety, security and well-being during business travel.
  • We comply with applicable immigration laws and obtain visas where required.
  • We are mindful of local culture, customs and laws when we travel.
  • We ensure that we are sufficiently rested after travel to perform work at a host site safely and effectively.
  • We use authorized agents to make travel bookings so that the safety and security of our employees can be monitored.
  • We are cost-conscious in our travel-related decisions, and only incur reasonable travel expenses.

Our Code Principles in Action

  • Follow the Business Travel Policy when planning travel.
  • Follow the Code (Offering or Accepting Gifts & Hospitality) if your business travel plans involve offering gifts and entertainment in excess of $150 to others.
  • Use your corporate travel & expenses credit card to book travel, and pay for other business travel expenses.
  • Cash withdrawals using a corporate travel & expenses credit card are only possible for cards issued in certain countries. Only withdraw cash using such a card in emergencies, and personally reimburse the card issuer for any cash not used to pay for business travel expenses.
  • Only use your personal credit card when your corporate travel & expenses credit card is not accepted.
  • Only use personal cash when credit cards are not accepted, or for paying reasonable tips.
  • Obtain required visas sufficiently in advance of the planned travel.
  • Obtain pre-approval from your GBU president or Head of Function before booking travel to a high- risk location, as advised by International SOS, the Company’s travel security advisor.
  • Immediately contact Global Ethics & Compliance or Legal if, during your trip, a government official requests a bribe, including a facilitation payment.
  • If you feel that your health, safety or security is under threat of imminent harm unless a payment is made to someone, 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.
  • Inform your supervisor if your trip includes a vacation either before or after the business trip, and provide evidence that it will not increase the cost of the business trip.
  • Do not downgrade your class of travel in order to acquire a ticket for a companion at Albemarle’s expense.
  • Consult with Global Trade Compliance Operations before traveling to other countries with:
    •  goods, raw materials or technical equipment in your possession; or
    • a laptop or phone containing controlled technology or proprietary information.
  •  Consult with Global Ethics & Compliance or the Legal Department before taking information, including information on a laptop, out of China or Russia, which might be considered state secrets of that country.
  • Incur reasonable expenses, obtain supporting receipts and submit timely expense claims in accordance with this Code (Managing Your Business Expenses) and the Business Expense Guidelines.

DEFINED TERMS

Bribery

Offering or providing anything of value directly or indirectly with the intent to improperly influence any person in order to gain business or an improper advantage. This includes, for example, improper influence over the:

  • decision whether to accept an application, official form or any other type of paperwork;
  • grant or revocation of a permit, license, quota, visa or any other award which allows the recipient to undertake a specified activity;
  • award of a commercial procurement or sales contract;
  • decision to enforce, or not enforce, a particular law or regulation against a company or individual;
  • decision to enforce, or not enforce, contractual terms such as performance guarantees;
  • decision to require, or not require, a payment to be made or how much is to be paid (e.g. taxes); and
  • sponsoring or approval of a change in existing law.

Bribery also includes the making of facilitation payments.

Controlled Technology

Hardware, software, documentation, technology or other technical data (or any products that include or use any of the foregoing) the export, re-export or release of which to certain jurisdictions or countries is prohibited or requires an export license or other governmental approval, under any Law, including the U.S. Export Administration Act and its associated regulations.

Facilitation Payment

Small payments made to lower-level government officials as a personal benefit to them to secure or speed up a performance of a routine action (e.g. licenses, permits, visas, customs clearance).

Government Official

Defined broadly, and can include:

  • an officer, employee or anyone acting on behalf of any government body including a department or agency at any level (national, regional, or local). Examples include a government minister, regulator, judge, city mayor, police officer, soldier, customs official or chemistry professor at a public university;
  • an employee of public international organizations such as the United Nations and World Bank;
  • an employee of state-owned or controlled enterprises, such as refineries;
  • a political party, party official or candidate for political office; and
  • a person holding an appointment, position or office created by custom or convention, such as, an indigenous community leader or member of a royal family.
State Secret

As a general rule, information is a state secret if its disclosure may harm national security and interests in the area of politics, economy, national defense or foreign relations. Examples could include:

  • material decisions relating to national affairs (e.g. strategic plan);
  • national defense construction and military activities;
  • foreign relations;
  • reserves data;
  • location and condition of mines, oil or gas wells;
  • unofficial maps of regions;
  • commercial secrets relating to state-owned enterprise; and
  • geological surveys.

In many instances the information will be stamped as a state secret but this will not always be the case. For example, state secrets can also be disclosed verbally. The types of information that may be considered a state secret are very broad and potentially encompass all information having a bearing on state security and national interests that is not in the public domain.

Examples of where you might have potential exposure to state secrets may include:

  • information received from a customer that is a state-owned enterprise (SOE);
  •  information gathered through Albemarle direct interactions with relevant government agencies;
  • information gathered by a third party that includes information received from government sources;
  • market surveys involving SOEs; and
  • industry associations and site visits.

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