bold spirit - ArcelorMittal South Africa
bold spirit - ArcelorMittal South Africa
bold spirit - ArcelorMittal South Africa
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86<br />
<strong>ArcelorMittal</strong> <strong>South</strong> <strong>Africa</strong><br />
Annual Report 2010<br />
Business ethics<br />
There were no reported instances of contravention of ethical<br />
or anti-corruption guidelines during the year.<br />
Our approach to managing business<br />
ethics and corruption is guided by<br />
the <strong>ArcelorMittal</strong> Group Code of<br />
Business Conduct (see page IV of the<br />
annual report) and Anti-corruption<br />
Guidelines. Both policies form part of<br />
our compliance programme.<br />
The Group anti-corruption guidelines<br />
establish procedures for handling<br />
concerns around possible corrupt<br />
practices and provide guidelines on<br />
how to fight and prevent corruption.<br />
All senior executives as well as staff<br />
in relevant sections of the business<br />
are required to be trained in the<br />
application of these guidelines. To<br />
date 686 employees out of a total<br />
of 983 requiring anti-corruption<br />
training have been trained in our anticorruption<br />
policies and procedures.<br />
Fraud risks relating to corruption are<br />
included in the annual internal audit<br />
plan to be covered during a year as<br />
part on the internal audit work.<br />
<strong>ArcelorMittal</strong>’s anti-corruption<br />
policy provides guidelines with<br />
regard to payment to political parties<br />
or government officials. Political<br />
contributions may be made only in<br />
accordance with applicable laws and<br />
are subject to prior written approval<br />
of the local legal department. No<br />
gifts and gratuities may be offered<br />
to government officials except for<br />
promotional items of little value and<br />
provided they are not offered with a<br />
corrupt intent.<br />
There were no reported instances<br />
of contravention of ethical or anticorruption<br />
guidelines during the year.<br />
There were also no significant cases<br />
of fraud or other misdemeanours<br />
reported.<br />
Anti-competitive behaviour<br />
Anti-competitive behaviour<br />
is monitored according to the<br />
<strong>ArcelorMittal</strong> Group Anti-trust<br />
Guidelines which we have an obligation<br />
to observe. The anti-trust guidelines<br />
explain the basic principles of anti-trust<br />
and competition law. The guidelines<br />
require absolute avoidance of any<br />
conduct which violates underlying<br />
principles of competition laws. All senior<br />
executives as well as staff in relevant<br />
sections of the business are trained in<br />
the application of these guidelines.<br />
Competition Authority<br />
investigations<br />
The group is currently the subject<br />
of a number of investigations by the<br />
Competition Authority expanded on in<br />
the ‘Finance report’ on page 23.