“Kingspan’s approach to bribery and corruption is very simple. Kingspan maintains a zero tolerance towards bribery and it is prohibited in any form. It is essential that Kingspan conducts business openly, fairly and honestly both on a domestic and international basis.” - Russell Shiels, President Kingspan North America
We will ensure compliance by our associates with anti-corruption law and anti-bribery law as violation could subject Kingspan, its directors and associates to severe penalties and could be very damaging to Kingspan’s business and its reputation.
Our Policy prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement in order to gain any commercial, contractual or regulatory advantage for THE COMPANY in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
It is not in keeping with our Business Principles to offer, promise, or give a bribe and request, agree to receive or accept a bribe. Failure to comply with this policy may, depending on the circumstances, result in disciplinary action, up to and including dismissal, and/or prosecution.
Kingspan’s policy prohibits ‘facilitation’ or ‘grease’ payments as these breach our Business Principles.
Facilitation payments are small payments made to secure or speed up routine actions, usually by public officials. It is also our policy that we work to ensure that associates and directors of THE COMPANY do not make facilitation payments on our behalf.
Kingspan’s Policy prohibits the making of political contributions in any form. Our Business Principles state that as a corporate entity, we will act with absolute political neutrality. We will abstain from any direct or indirect participation that could be interpreted as taking a position in favor of or against legitimate political parties. In particular, we will not make contributions or donations of any type, whether in cash or in kind, in support ofpolitical parties, organizations, factions, movements or public or private entities whose activities are clearly linked with political activity. It is important to ensure that any contributions or sponsorships are not used as pretense for bribery. A review of the charitable contribution and the indeed end use of the funds must take place before making the payment.
Bona fide hospitality and promotion which we provide, or other business expenditure which seeks to improve the image of the business, better present products and services, or establish cordial relations, is recognized as an established and important part of doing business and it is not the intention of this Policy to penalize such behavior. Hospitality and promotion or other similar business expenditure should be reasonable and proportionate. Where hospitality is expected to exceed $3,000 then this must be formally approved by a divisional director prior to commencement.
Where you are in receipt of hospitality (sporting events etc.) you must obtain the approval from your line manager where the value of the hospitality will exceed $2,000. In addition, you should not accept such hospitality more than twice per annum from the same supplier or customer.
It is accepted practice that from time to time, to promote the best interest of the company gifts will be offered to third parties but will not exceed a value of $500 per annum. These gifts will never be viewed as inducements for business.
Associates are allowed to accept gifts where the value does not exceed $150. Any gifts received in excess of this value must be declared to the local management team who will decide whether to decline the gift or accept on behalf of the company. These gifts where accepted, will be retained and donated to charity, raffled off to staff or used in such similar fashion as decided by management.
What if I am not sure?
If anyone is in doubt as to whether a potential act constitutes bribery or an improper inducement, the matter should be referred to local senior management before proceeding.
Associate Responsibility
The prevention, detection and reporting of bribery is the responsibility of all associates throughout the Company. An individual who is concerned about another individual’s non-compliance with this policy should raise the matter in the first instance with their line manager (or any member of the senior management team) or by using the Confidential Help Facility.
Collect call number (this can be used internationally)
0044 1249 661 808 and/or USA toll free phone number: 1-877-533-5310
THE COMPANY, or Kingspan Group, will conduct regular Internal Audits to ensure compliance and the effectiveness of anti-corruption policy and procedure.
THE COMPANY will provide regular training on its corruption policies to its directors, associates, representatives, and business partners. Training will be tailored to meet the requirements identified in the Risk Assessment(s).
Those requiring specific and immediate guidance should contact a senior member of the local Finance Team or a Divisional Director.