An Introduction to the BG India Ethical Values

1
Ethical Conduct Policy

Maintain high standards of ethical conduct

Do not tolerate bribery or corruption in any form or
by those who work on behalf of BG Group

Adhere to the Ethical Conduct Standards.
2
Anti-Bribery and Corruption Laws
Major legislation:
UK Bribery Act 2010 (UKBA)
USA Foreign Corrupt Practices Act 1977 (FCPA)
Local Legislation
Prevention of Corruption Act, 1988 (India)
Local anti-bribery and corruption laws and local regulations are also
important!
Providing GIFTS to Public servants must give consideration to
business transactions in progress. Public servant accepting GIFTS
is not allowed (India)
For example gifts and hospitality for Public Officials in Kazakhstan
is not allowed (this includes people in KMG)
In China, senior members of the Chinese Communist Party are
bound by regulations that place heavy restriction on gifts and
hospitality

3
UK Bribery Act 2010
Offences
Offering a bribe
Accepting a bribe
Bribing a foreign public official
Failing to prevent bribery (corporate offence)
Consenting to, or conniving in, bribery (senior officers)

Penalties
Individuals: unlimited fine and up to 10 years
imprisonment
Companies: unlimited fine

4
Failing to Prevent Bribery
5

Liability for BG Group where anyone pays a bribe on BG
Groups behalf anywhere in the world
BG can be liable without knowledge of the offending bribe
Only one defence:
BG has to demonstrate that it has
adequate procedures to
prevent bribery
CONTRACTOR COMPLIANCE

6
Recap of Contractors contractual obligations
Compliance with BG Business Principles and applicable anti-corruption laws

No use agents or intermediaries

No commissions from vendors or contractors

Declaration of any connections with Public Officials

Certificate of compliance

Notification and provision of relevant information to foster compliance

Parties to co-operate and work together to promote and ensure
compliance
Speak Up (Duty to report) Policy
Report promptly any situation where you have
reason to suspect there has been a breach of
the Business Principles, BG Group Policies or
any law or regulations

Provide us much information as possible to
ensure a proper investigation can be carried
out and respond to requests for further
information as the investigation progresses
7
8
ZERO TOLERANCE
Zero tolerance to unethical behaviours