Our most effective tools for identifying fraud and misconduct

Our Code of Ethics already establishes a system of values for the company and outlines the level of conduct we expect from each of our employees. It represents an effective tool for preventing irresponsible or illegal conduct by those who work for us and on our behalf. But we want to go even further.

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We implemented a whistleblowing tool, Integrity First. Whistleblowing programs are one of the most effective tools for identifying fraud and misconduct. In fact, employee tip-offs have played such a significant role in uncovering fraud and unethical practice that they have been adopted by many major international corporations.

Our Integrity First Program complies with the latest in best practice and ethical compliance matters whilst further enhancing employee awareness of our policies regarding corruption.


We have established dedicated and secure channels (including telephone lines and a web portal) for individuals who wish to report professional misconduct. These channels are managed by an external independent company (The Network, Inc.) which has a binding mandate to protect the identity of whistleblowers. They also act as an intermediary to relay any required follow-up information, as well as related questions and answers, and information about the resolution of the case.

Alongside these channels, we have formed a Whistleblowing Committee. This functions to accurately evaluate any reports, perform specific investigations into cases where required, and adopt coherent and appropriate measures.

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