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FOSTERING FAIR BUSINESS SUPPLY CHAIN DUE DILIGENCE

MSC is committed to undertaking business fairly, and MSC strives to implement within its agreements with MSC performs due diligence in selecting business
to uphold all applicable anti-bribery and corruption customers and business partners, anti-corruption partners. MSC expects the same level of due diligence
laws when conducting business anywhere in the clauses to impose strict requirements and obligations from its agencies. Due diligence must be carried out
world. MSC strictly prohibits all corruption, as well throughout its supply chain. MSC anti- corruption before engaging with a business partner to identify
as active and passive bribery. MSC employees must clauses impose to MSC counterparties and their share- existing problems and potential risks.
comply with all applicable anti-bribery laws, including holders, subcontractors and affiliates the highest The Compliance department is working in close
the Swiss Penal Code and where applicable the U.S. standards in strict application of anti-corruption laws. collaboration with the Contract Review team to
Foreign Corrupt Practices Act and the UK Bribery Act As such, MSC counterparties must perform anti- implement specific compliance clauses within contracts.
2010. corruption due diligence to ensure compliance with Thanks to strong cross-transversal team efforts, MSC’s
MSC has created a dedicated team of experts in its applicable anti- corruption laws. business partners are required, through specific com-
headquarters, which has successfully implemented Any employee must report on an anonymous basis pliance obligations in contracts to comply with all
the MSC Anti-Bribery policy with the strong support all events that he perceives as being a potentially applicable laws, statutes and regulations, such as the
of the senior leadership. This policy provides a frame- corrupt activity. The management shall take appropriate UK Modern Slavery Act of 2015. MSC also expects its
work for employees worldwide on how to conduct remedial and corrective actions if necessary. business partners not to have been convicted or been
themselves when dealing with external third parties There is a training for employees focusing on subject of an investigation for any offence involving
such as customers, government officials and business anti- corruption, on how to fight corrupt practices a human rights violation. MSC also encourages its
partners. Agencies and employees shall never offer, in their daily activities. A mandatory e-learning business partners to commit to similar principles to
give, solicit, accept or receive, an undue advantage in course raising awareness on anti-corruption will be those set out in the MSC Code of Business Conduct.
return for favourable treatment, influencing a person implemented during the year 2017 for a better and
or decision, or gaining or retaining business. stronger reach globally.
It is of paramount importance that MSC always
conducts its business legally, responsibly and with
integrity. There is a zero-tolerance policy on any form
of corrupt activity and facilitation payments. MSC will
not tolerate wilful ignorance in relation to corrupt
activities. The failure to comply with the policy may
lead to disciplinary action and up to the termination
of employment. The MSC Anti-Bribery policy was
translated in 11 different languages for a better reach
and understanding by employees, globally.
As a general principle, giving or accepting luxurious,
unduly lavish or extravagant goods, as well as cash
or cash equivalents such as gift cards and vouchers,
is forbidden. As a rule, corporate hospitality
expenditures unrelated to business activities are
prohibited, as well as expenditures that are primarily
for personal purposes. Charitable contributions or
sponsorships cannot be used to funnel bribes.

78 BUSINESS ETHICS AND PROTECTION OF HUMAN RIGHTS MSC SUSTAINABILITY REPORT 2016 79