This policy is established for Walter Graham. The Board regularly reviews its effectiveness and relevance and updates it in response to new legislation or regulatory requirements. All employees and associated persons are responsible for ensuring its success by disclosing any suspected dangers or wrongdoings.
This policy is drafted in compliance with relevant international anti-corruption laws, including The PRC Criminal Law (revised in 2020), The PRC Anti Unfair Competition Law (revised in 2019), and The Interim Rules of the State Administration for Industry and Commerce on Prohibition of Commercial Bribery. Under these laws, bribery and corruption are punishable by severe penalties, including imprisonment for individuals of up to 10 years and substantial fines for companies. Walter Graham takes these legal responsibilities very seriously.
Walter Graham values its reputation and is committed to maintaining the highest level of ethical standards. The actions and conduct of our staff and others acting on our behalf are critical to upholding these standards. We adopt a zero-tolerance stance to bribery and corruption and commit to acting professionally and with integrity in all business matters and all relationships.
We have carried out a risk assessment of the bribery and corruption risks to Walter Graham and used this information to create this policy, which is reviewed and updated where necessary a minimum of once a year.
This policy applies to all employees, directors, agents, consultants, contractors, third parties, people, or organizations connected with Walter Graham across all regions, areas, and functions.
In this policy, third-party refers to any individual or organization we interact with during our work, including clients, customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, politicians, and political parties. Third parties will only be engaged with a clear business rationale and an appropriate contract. Payments to third parties will be authorized, recorded, and subject to effective payment controls. High-risk referral or supplier arrangements will undergo enhanced due diligence. Supplier and outsourcing contracts will reflect our zero tolerance of bribery and corruption.
While gifts and hospitality are common in business, they must not be given or received with the intention of influencing business decisions. Acceptable gifts, entertainment, and hospitality must comply with our internal Gifts & Entertainment Policy.
It is not acceptable to:
Walter Graham forbids facilitation payments and kickbacks of any kind. Employees must avoid activities suggesting that such payments will be made or accepted.
We do not donate or contribute to political parties. Charitable donations must be legal, ethical, and comply with local laws, and are managed through our Charities policy, which outlines the processes for advertising, sponsorship, and corporate hospitality at charity events.
All employees must prevent, detect, and report bribery and corruption, and any employee violating this policy will face disciplinary action, including dismissal for gross misconduct. Walter Graham reserves the right to terminate contracts with other workers if they contravene this policy.
We maintain financial records and internal controls to evidence the business reason for third-party payments and record hospitality or gifts accepted or offered.
Employees who decline to accept or offer a bribe or those who report concerns are protected from negative treatment. Negative treatment includes dismissal, disciplinary action, threats, or other critical treatment related to raising concerns.
Training on this policy is part of the induction process for all new employees, and existing staff receive regular training. Walter Graham's zero-tolerance approach is communicated to all suppliers, contractors, and associated partners at the outset of our relationship and as appropriate after that.
A risk assessment of the financial crime risks to Walter Graham takes place annually, and regular monitoring ensures the policy's effectiveness and compliance.
