Conducting our business with integrity

Preventing bribery and corruption

Simply, we do not tolerate any form of bribery or corruption. They can cause harm to Mott MacDonald, cause clients and business partners to lose trust in us and damage the communities in which we work.

Bribery and corruption
We are committed to countering all forms of bribery and corruption. We support initiatives to eliminate them, and work to continually improve our anti-bribery and corruption systems and practices.

We comply with all anti-bribery and corruption laws and will never offer or accept bribes, kickbacks or other improper payments. We prohibit improper payments including to secure permits or approvals, and small payments to speed up a routine government process (often known as ‘facilitation payments’). We conduct due diligence to mitigate the risk that colleagues or those working on our behalf will be exposed to bribery or corruption when working on projects or providing services.

Anyone who suspects bribery or corruption is taking place must report it. All allegations of bribery are investigated. Appropriate follow-up steps are taken, with breaches reported to the police and other relevant authorities when necessary.

Fraud
Any fraudulent and dishonest conduct is unacceptable, within our organisation or in those we do business with. Fraud can take many forms, including false representation, failing to disclose information and abuse of position. It is important we are all vigilant to identify and report fraudulent or dishonest conduct.

Money laundering and tax evasion
We are all responsible for protecting our business against money laundering or tax evasion. Money laundering is the process of hiding illegal funds or making them look as though they are legitimate. It also covers the use of legitimate funds to support crime or terrorism. Criminals may try to hide their identity or the identities of third parties, as well as disguise the origin of the funds they are seeking to launder.

Tax evasion and the failure to prevent its facilitation, however minor, are criminal offences. Wherever they are in the world, nobody who works for us or on our behalf should facilitate a third-party taxpayer to evade tax. Suspected incidences must be reported.

Exchanging gifts and hospitality

Exchanging gifts and hospitality can generate goodwill and be part of building and strengthening business relationships. However, we do not offer or accept gifts or hospitality that could appear to create an improper advantage for Mott MacDonald, or improperly influence us or any third party. Everyone working for or with us must use good judgement and ensure their actions cannot be viewed as inappropriate or constitute a bribe.

Before offering or accepting any gift or hospitality, we consider if it is part of a regular pattern, or if it places an obligation to deliver something in return. Close attention is paid to the timing of any gifts or hospitality, which must never be offered or accepted during a tender process.

Particular care is taken when dealing with government or public officials or making charitable donations to ensure that such transactions do not breach anti-bribery or corruption laws.

Any gift or hospitality offered or received must have a business purpose and be reasonable and proportionate, in terms of value, nature and occasion. Gifts or hospitality must not include cash or a cash equivalent. Care is applied when offering or accepting any gift or hospitality that involves family members.

All gifts and hospitality above set limits must be discussed with line management and included within the Mott MacDonald gifts and hospitality register.

Managing conflicts of interest

To protect the integrity of our decision making we never allow an external interest to influence, or appear to influence, our judgement. We protect our ability to make decisions in the best interests of Mott MacDonald by avoiding all actual, potential and perceived conflicts of interest when possible and managing them when they are unavoidable.

Personal conflicts can occur in many different circumstances, including close relationships inside or outside the workplace, affiliations with competitors or suppliers, outside positions or financial investments, which may influence or appear to influence decision making.

Organisational conflicts can arise when our role on one project has the potential to unfairly benefit Mott MacDonald in another role or project. They may compromise our ability to give impartial assistance or advice, or provide an unfair competitive advantage, compromising our stance on corruption.

Personal and organisational conflicts are identified and resolved swiftly. They are discussed with clients and other stakeholders where appropriate, and management plans agreed.

All actual, potential and perceived conflicts of interest must be entered into our conflict of interest management tool to ensure proper action is taken.

Competing fairly

We support open and transparent markets where businesses can compete fairly. This builds trust and provides the best value and outcomes for our clients, their customers and society.

In our dealings, we respect competition and anti-trust laws as well as the ethical practices of the jurisdictions in which we work, adhering to Our Code where that provides the higher standard. We do not engage in anti-competitive agreements or behaviour, such as dividing or sharing markets, price fixing, limiting production or output, bid-rigging, collusive tendering or other cartel behaviour.

When exchanging information with a third party, we respect confidentiality. We do not exchange commercially sensitive information with competitors. If unilateral disclosures of commercially sensitive information or other anti-competitive behaviour are identified, we will cease the communication and take clear and immediate steps to remove ourselves.

Any anti-competitive practices must be reported. All allegations of anti-competitive behaviour are investigated. We take appropriate follow-up steps and inform relevant authorities when appropriate.

Respecting international trade and export controls

We respect and abide by national and international trade laws, including economic sanctions, anti-boycott provisions and import and export controls.

Many countries impose controls on the movement of items across their borders, including goods, software and technology. Specific licences and approvals are required before listed items can be exported. When our business operations require us to export any item, we identify if it is listed and proactively comply with any relevant legislation.

Economic sanctions may prohibit or restrict our ability to conduct business with governments, entities and individuals in certain countries. Sanctions change frequently, and we review and adjust our project work and business relationships accordingly. We understand who we are doing business with and conduct proper due diligence checks on business partners, clients, suppliers and other third parties. These checks include screening for breaches of sanctions and other trade controls.

Any questions or concerns about international trade should be reported.

Treating our clients, suppliers and partners fairly

The support of our clients, suppliers and partners is essential to the long-term success, resilience and sustainability of our business. Mutual respect and good governance underpin all our business relationships.

We seek to work only with those who share our values and operate in a manner consistent with Our Code – in their dealings with us and within their own supply chains. We conduct due diligence checks on our clients, suppliers and partners. We communicate our expectations, monitor performance and address any issues. This includes withdrawing from contracts if our standards are not being met.

We work innovatively with suppliers and partners to procure goods and services sustainably and ethically and to deliver services to our clients at the optimum value and required quality. We endeavour to treat our supply chain fairly and consistently, and to pay them in line with contractual obligations.

We aim to always provide open and honest feedback on performance, and to be open to feedback on our own performance from others.