<strong>Code</strong> <strong>of</strong> <strong>Business</strong> <strong>Conduct</strong>3.3. Sponsorships and charitable donationsLAIO will support local community groups and charities throughsponsorships and donations which are legal, ethical and which further theinterests <strong>of</strong> LAIO.Our commitmentLAIO will support local charities and community groups through sponsorships anddonations provided they comply with local laws and meet the ethical standards <strong>of</strong>LAIO.LAIO will not sponsor or provide donations to, or in respect <strong>of</strong>, the following:• Individuals, other than through organised events or specific scholarships andbursaries• Initiatives or organisations not aligned with this <strong>Code</strong>• Projects or events not relevant to our geographical areas <strong>of</strong> operationYour responsibilityYou must:• Only consider potential sponsorships and charitable donations that support localcommunities, which comply with local laws and the ethical standards <strong>of</strong> LAIO• Obtain approval for all sponsorships and charitable donations in accordance withthe <strong>Leighton</strong> Rules• Comply with the <strong>Leighton</strong> Rules in relation to Sponsorship and CharitableDonationsReferences<strong>Leighton</strong> GGS – Corporate Community Investment GuidelineLAIO Community Relations PolicyLAIO Sponsorship Guidelines<strong>Leighton</strong> <strong>Asia</strong>, India and Offshore Revision 430 November 2014 Page 22 <strong>of</strong> 46
<strong>Code</strong> <strong>of</strong> <strong>Business</strong> <strong>Conduct</strong>4.0 Ethical <strong>Business</strong> Practices4.1. Bribery and CorruptionLAIO prohibits bribery and corruption in all forms, whether directly orthrough a third party.Our commitmentLAIO does not permit, or condone, any form <strong>of</strong> bribery or corruption. “Bribery”involves: The <strong>of</strong>fering, giving, granting, promise or acceptance <strong>of</strong> any payment, gift,promise, benefit, favour or anything <strong>of</strong> value, whether directly or through a thirdparty, which is:• To or from any person or entity (whether a government <strong>of</strong>ficial, a privatebusiness person or an associate <strong>of</strong> any <strong>of</strong> them)• For the purpose <strong>of</strong> improperly securing a private or business benefit oradvantage, or for the improper performance <strong>of</strong> a function or activity“Corruption” involves the abuse <strong>of</strong> a position <strong>of</strong> employment, authority or trust togain an advantage in breach <strong>of</strong> duty.Such behaviours are illegal in most countries. A breach <strong>of</strong> anti-bribery or corruptionlaws is a serious <strong>of</strong>fence, which can result in significant fines to the <strong>Leighton</strong> Group,LAIO and LAIO Employees and/or imprisonment. Even the perception <strong>of</strong> bribery, orcorruption, can have a serious impact on the reputation <strong>of</strong> the <strong>Leighton</strong> Group, LAIOand LAIO Employees.LAIO also prohibits making “facilitation payments”, even where permitted under locallaws. Facilitation payments are typically payments involving small sums to anindividual within government, or other public authority, or within a private entity toobtain routine services that are not related to obtaining an undue advantage.Your responsibilityYou must never:• Engage in any form <strong>of</strong> bribery or corruption• Make a facilitation payment• Authorise, undertake or participate in schemes to give any improper benefit, kickbackor secret commission to anyone• Offer, promise or give a cash or cash equivalent payment <strong>of</strong> any kind to agovernment <strong>of</strong>ficial or to any other person for the purpose <strong>of</strong> obtaining improperadvantage• Use any third party to do something that LAIO is prohibited from doing itself• Give anything <strong>of</strong> value to any third party when there is any suspicion that thethird party, will engage in bribery, corruption or other prohibited conduct inrelation to LAIO<strong>Leighton</strong> <strong>Asia</strong>, India and Offshore Revision 430 November 2014 Page 23 <strong>of</strong> 46