We take a zero tolerance approach to all forms of corruption, bribery, conflicts of interest, theft, extortion, embezzlement, fraud and misuse of company assets.
To De Beers, business integrity means ensuring that we compete fairly, legally and without improper influence, and in line with international best practice in all our operations. Our whistleblowing service, Speak Up, is a confidential reporting service for employees, business partners and other stakeholders to raise concerns about potentially unethical, unlawful or unsafe conduct or practices involving the company.
Our Business Integrity Policy sets out our standards and provides guidance in respect of 11 areas that give rise to an increased risk of bribery for our business, including the offer and receipt of gifts and entertainment, political and charitable donations (we do not participate in party politics or make political donations), interactions with government and public officials, the use of intermediaries and social investment. This approach is embodied in our value of Building Trust, which establishes that ‘we will always listen first, then act with openness, honesty and integrity so that our relationships flourish’.
The majority of De Beers’ business units have annual Business Integrity Policy plans, which were first implemented in 2015 and have been updated in 2016.
At the end of 2016, implementation of the Business Integrity Policy in our business units was audited internally through a combination of nine full audits and 12 self-assessments.
Business Integrity Policy training follows a four-year cycle, starting with workshop training followed by online refresher training two years later, and is supported by regular global and local communications to support awareness and understanding.
Since launch in 2013, 2,592 people have participated in the workshop training, which is tailored to deliver a good understanding of what corruption is in the modern world and why corruption risk is relevant to De Beers. It provides a focus on the corruption risks that employees may face in their daily activities. The online refresher training began in 2015 and continued in 2016.
We have a zero tolerance stance on any non-compliance with competition and anti-trust laws. Our approach is guided by the De Beers Anti-Trust Compliance Manual and Policy. We run an annual competition law compliance programme, which includes a requirement for relevant employees to undertake either standard or refresher online training. In 2016, 1,534 (2015: 1,452) people took part in the programme, and the average completion rate was 99.9 per cent (2015: 99.8 per cent).
De Beers is subject to legal commitments to the European Commission not to buy rough diamonds from ALROSA, directly or indirectly. Also, as part of a Settlement Agreement that De Beers entered into in March 2006 to settle all outstanding class actions against it in the US, we entered into an injunction that will remain in effect until June 2017.
No fines or non-monetary sanctions were imposed on De Beers in 2016 in relation to non-compliance with anti-corruption legislation and regulations, with competition or anti-trust laws or for breach of the ALROSA commitments or the US injunction.
De Beers entities were named as defendants in four class actions in Canada. A settlement on a Canada-wide basis was entered into in 2016 and is subject to court approval.