Anti-bribery and Anti-corruption Commitment

ZeroGeo Energy has zero tolerance to bribery and corruption.

We are committed to:

  • Acting fairly, transparently, and with integrity in all of our business activities and relationships.

  • Implementing and enforcing effective systems to counter bribery and corruption.

  • Aligning our strategy and business practices to support the UN Sustainable Development Goals, in particular Goal 16 Peace, Justice and Strong Institutions.

We require all of our directors, officers, employees, contractors and partners to observe high standards of business conduct and ethics, as well as full compliance with all applicable government laws, rules and regulations, including the Foreign Corrupt Practices Act of 1977 and the UK Bribery Act of 2010.

We comply with Anti-bribery and Anti-corruption laws by observing the following principles:

1. Do not offer or accept bribes or facilitation payments

It is illegal and unethical to offer or accept improper payments in order to gain or retain business, or facilitate approvals or business transactions. We do not condone any improper payments.

2. Reasonable and proportionate gifts and hospitality

Hospitality and gifts to build relationships is an established and important part of doing business, however these must be reasonable and proportionate or they could be considered bribery.

3. Zero tolerance of fraud

Fraud represents a fundamental breach of our ethical standards and is not tolerated in any form. We are committed to the prevention, detection and investigation of fraud. All forms of fraudulent conduct or dishonest behaviour are prohibited and we will report any serious matters to the relevant authorities.

4. Ethical political contributions, charitable donations and sponsorships

We do not make any political contributions to political candidates, parties, committees or their representatives. We are committed to supporting the local communities and businesses in which we operate and will only make charitable donations or sponsor programmes that are legal and ethical under local laws and practices.

5. Engaging in fair and ethical competition

We engage with our competitors and business partners in a fair and ethical way. We do not engage in any activity that is anti-competitive and we only acquire information about our competitors by legal and ethical means.

6. Respecting trade restrictions

We respect and observe the trade controls of all countries in which we operate; including economic sanctions, and import and export laws. This helps ensure that we do not do business with any countries, people or businesses that have trade sanctions or controls imposed against them.

7. Working with responsible business partners

We strive to ensure our business partners share our commitment to eliminate bribery and corruption. We conduct risk-based due diligence to assess risks related to ownership structure, anti-bribery and corruption, sanctions and trade restrictions, and human rights and labour conditions.

8. Responsible tax management

We are committed to acting with honesty and integrity in respect of tax laws and regulations, and to paying our taxes in the countries where we work. We require all business partners acting on our behalf to not engage in the facilitation of tax evasion and we maintain procedures to safeguard against risk of tax evasion.

9. Prompt reporting of inappropriate, illegal or corrupt behaviour

We have established a Whistleblowing procedure to encourage our people to speak up if they are concerned about any inappropriate, illegal or corrupt behaviour in relation to our activities, as well as any actions that are, or could be, harmful to our business.

We are currently developing a detailed Antibribery and Anti-corruption Policy and Code of Conduct to provide further clarification and guidance to our people and partners, and to guard and promote our reputation for integrity and responsibility. All policies will be regularly reviewed and updated to ensure they remain effective and are aligned with best practice standards.