Ethics

Commitment

Mott MacDonald is committed to behaving ethically in all that we do and respecting the customs and cultures of the countries in which we operate.

We are committed to business practices that are responsible, fair and promote the highest standards of integrity, and to countering all forms of bribery and corruption.

We comply with applicable legal and regulatory requirements in every jurisdiction in which we work.

Approach

To fulfil our commitment, we:

• only work with those who operate in a way that is consistent with Our Code and our PRIDE values, and who can meet the standards set out in this policy
• ensure decisions are made in the best interests of Mott MacDonald and are not influenced by external interests. We prohibit the giving or receiving of bribes, including facilitation payments, donations to political parties or charities, and gifts or hospitality, that may improperly influence business decisions
• prevent facilitation of tax evasion and fraud by Mott MacDonald employees or those associated with Mott MacDonald
• compete fairly, respecting the laws and ethical practices of the jurisdictions in which we work including Competition Law and procurement rules
• compete vigorously but do not seek to misrepresent our competitors
• evaluate the bribery risk and integrity standards of clients, suppliers, subcontractors and other business partners
• monitor the conduct of third parties – we will withdraw from contracts if unethical business practices are suspected
• respect and abide by national and international trade laws, including economic sanctions, anti-money laundering regulations, anti-boycott provisions and import and export controls
• ensure third-party payment is always appropriate for the work done and is justifiable at market value
• avoid situations that could interfere, or appear to interfere, with, the impartial discharge of the Group’s duties. Where gifts and hospitality are given and received, this is done openly and transparently. We take great care when considering providing gifts or hospitality to ensure we do not breach working regulations
• identify and manage actual, potential and perceived conflicts of interest as soon as they arise
• ensure our communications, marketing and publications are factually correct, ethical and fair
• encourage staff to seek help and advice from line management if they suspect Our Code and PRIDE values are being breached and provide confidential resources to report concerns when potential violations occur. Retaliation against those who Speak Up or assist in investigations will not be tolerated and may result in disciplinary action.
• work to continually improve our anti-bribery systems and practices to meet the needs of our employees, clients and business.

Our business management system meets the requirements of ISO:37001 and is independently certified in appropriate geographical locations around the world.

Responsibility

• The executive chair is responsible for this policy and its implementation.
• Regional general managers are responsible for the effective implementation of this policy in their regions and business units.
• Ethics and compliance officers are responsible for monitoring the effectiveness of this policy and for ensuring that our ethical commitments are reflected in our operational requirements.
• Project managers are responsible and project principals accountable for ensuring ethical practices within their projects.
• All members of our workforce are responsible for behaving ethically, meeting our standards of integrity, and for promoting Our Code and our PRIDE values. Adhering to this policy is a condition of employment and breaches will result in disciplinary action.

James Harris
Group executive chair