This Anti-Bribery & Corruption Policy sets out METRA’s zero-tolerance approach to any form of bribery, corruption, facilitation payments or improper advantage in connection with its business activities.
Prohibition of Bribery and Corruption
METRA prohibits the offering, giving, requesting or receiving of bribes, kickbacks or any thing of value intended to improperly influence a decision or secure an undue advantage.
The prohibition applies to dealings with public officials, private sector counterparties, clients, vendors and any other third parties.
Facilitation payments, whether small or customary in certain jurisdictions, are not permitted.
Gifts, Hospitality and Expenses
Reasonable, proportionate and transparent gifts or hospitality may be allowed where they are consistent with local laws and METRA’s internal thresholds and approval processes.
All gifts, hospitality or expenses offered or received must be for legitimate business purposes and must not create an expectation of favourable treatment.
Employees must declare and seek approval for gifts and hospitality in accordance with METRA’s internal procedures.
Third Parties and Due Diligence
METRA exercises appropriate due diligence on third parties, including intermediaries, introducers and vendors, proportionate to the bribery and corruption risk they pose.
Contractual arrangements with third parties should contain appropriate anti-bribery and corruption clauses and audit or information rights where relevant.
Training, Reporting and Consequences
Employees receive training on anti-bribery and corruption requirements and must promptly report suspected breaches through internal reporting channels or the whistleblowing mechanism.
Breaches of this Policy may result in disciplinary action, up to and including termination of employment or engagement, and may need to be reported to regulators or law enforcement.
