We have zero tolerance for any form of bribery or corruption, whether by our employees or business partners.
At ST, all business decisions are made transparently and based on merit. This is how we stay true to our values, assert our trustworthiness and support our long-term success.
If you are ever exposed to anything that could be considered bribery or corruption, please immediately report it to the Ethics, Compliance & Privacy department or the Ethics Hotline.
What does it mean?
Corruption can take many forms, from the minor use of influence to institutionalized bribery.
The forms of corruption that first come to mind are facilitation payments or influence peddling (i.e. using personal relationships) to expedite certain government services (permits, licenses, customs clearance) or administrative processes. It can also be more subtle and difficult to identify.
Corruption may be active or passive, direct or indirect.
- Active corruption → offering, promising, or paying a bribe to someone.
- Passive corruption → soliciting or accepting a bribe from someone.
- Direct corruption → personally engaging in a bribe.
- Indirect corruption → intermediaries, agents, or business partners concealing involvement or facilitating the act.
In all cases, it is illegal and a criminal offence.
Although corruption can occur in all countries, sectors, and professions, certain individuals and activities are more exposed to risk and require increased vigilance. That is the case with “public or government officials”, who are subject to specific rules and restrictions. This category includes:
- Officers, employees of governments, governmental agencies, or international organizations;
- Persons acting on behalf of any governmental agency or public international organization;
- Officers or employees of state-owned or state-controlled companies;
- Members or employees of political parties, and candidates for public office;
- Members of royal or ruling families.
However, ST does not distinguish between public officials and private persons regarding bribery and corruption. What you must keep in mind is this: any form of bribery or corruption is strictly prohibited, regardless of the recipient’s status.
Business partners (that includes direct and indirect suppliers, customers, and other stakeholders), play a crucial role in our operations. That’s why we aim to ensure they align with our standards of integrity, quality, and ethical business practices and select them with care. It also means that we expect our business partners to report any concerns they may have.
How we do the right thing?
Our Do’s
- We uphold applicable anti-bribery and anti-corruption standards, laws and regulations wherever we operate.
- We assess bribery and corruption related risks and mitigate them through monitoring, controls, audits. We regularly review and adapt our anti-bribery and anti-corruption program to ensure that it remains effective.
- We regularly provide training and awareness to recognize and prevent bribery and corruption.
- We choose our business partners and third parties with care, to ensure they respect our values, share our standards and apply the appropriate measures.
Our Don’ts
- We strictly prohibit all facilitation payments, regardless of local customs or practices.
- We never accept or offer money, services, favors, or gifts to gain a business advantage from anyone.
- We have zero tolerance for any form of bribery or corruption, whether by our employees or business partners.
Avoiding corruption
in practice
Because real life is rarely as clear-cut as theory, here are the answers to a few questions you might have.
An employee insists on urgently selecting a specific service provider, without following the required bidding process and established procedures. I suspect they might be receiving a benefit in exchange for awarding the job to the specific supplier. What should I consider in this situation?
Selecting a service provider in exchange for a benefit is accepting a bribe. We must recognize and avoid all situations that could be perceived as offering, giving, or receiving any form of advantage in exchange for an undue benefit. You should report using the existing reporting channels.
Is it acceptable to ask a government official, with whom I have a personal relationship, to expedite a permit approval, even if no money changes hands?
No, this is called influence peddling and violates ST’s Code of Conduct. Using personal relationships to gain preferential treatment undermines fairness and transparency.
All interactions with public officials must be conducted transparently and impartially, in accordance with applicable laws and Company policies.