Anti-corruption: SABMiller’s approach

High standards of ethical behaviour and transparency underpin all that we do. SABMiller does not tolerate bribery or corruption in any form, and the group has implemented a comprehensive anti-corruption programme. We also place a high value on reporting and communicating in an open and honest way with all our stakeholders, and this webpage provides more information about our anti-corruption programme.

SABMiller has a long-standing commitment to responsible, transparent and ethical business practices. Acting responsibly goes beyond complying with laws and regulations – although that is something we must do. It also encompasses setting ourselves high standards of business ethics, acting with good judgment, and taking a zero tolerance approach to bribery and corruption. Our standards are set out in the SABMiller Code of Business Conduct and Ethics and our Anti-Bribery Policy. Following our policies and procedures is not optional. It is fundamental to our long term future – we want to remain a company of which our shareholders, business partners, customers and staff are proud to be a part.
Alan Clark |Chief Executive

Our starting point in implementing this commitment is SABMiller’s Code of Business Conduct and Ethics. The Code is a summary of our commitment to ethical business conduct and requires group companies to comply with applicable laws and regulations, including anti-corruption laws. It is supplemented by our Anti-Bribery Policy, which sets out our zero tolerance approach to bribery and corruption. Both the Code and the Policy apply throughout the SABMiller Group – to all the entities we control and all directors, officers and employees. Together with our Supplier Anti-Bribery Policy, they also set out the principles we expect suppliers and other third parties who act on our behalf to follow.

The Anti-Bribery Policy is supplemented by a range of supporting policies, procedures and guidance, covering areas such as staff training and communication, vetting and communicating our ethical standards to suppliers on a risk-based approach, procedures in areas such as gifts and entertainment, donations and sponsorships, whistleblowing, monitoring, and related matters.

The Group Audit Committee reviews the adequacy of the group’s anti-corruption framework and the implementation of our policies. More information about the work of the Audit Committee is available on the Board Committees page.

As a participant in the UN Global Compact, we are committed to its Ten Principles, including that “Businesses should work against corruption in all its forms, including extortion and bribery”.

Whistleblowing

One important aspect of our anti-corruption programme is the ability of employees and business partners to raise any concerns about bribery and corruption without fear of retaliation. The group whistleblowing hotlines provide global coverage for employees and others wishing to raise concerns freely, anonymously, and in local languages. No action or retaliation is permitted against any employee making a good faith report about an actual or suspected violation of a SABMiller policy.

Global procurement

We also look to build close and equitable business relationships with our suppliers, and actively select and favour those who share our values and our ethical commitments.

We have formulated the SABMiller Supplier Code of Conduct and Anti-Bribery Policy for Suppliers, which set out our expectations in relation to transparency and business ethics, as well as human rights and labour standards, and the reduction of environmental impact.

Our group companies are required to implement risk-based anti-corruption due diligence processes. In addition, the rigorous supplier accreditation programme managed by SABMiller Procurement assesses prospective suppliers’ alignment with our standards in terms of ethics, business governance, social compliance and human rights, financial stability and, where appropriate, technical compliance. SABMiller Procurement only contracts with suppliers who have been accredited to our global standards.