Anti-Corruption Policy

MTE conducts its business honestly, fairly, and professionally in accordance with the best interest of its clients.

Our policy against bribery and corruption is clear:

Bribery is not tolerated in any form under any circumstances.

Scope: This policy applies to all MTE directors, employees, third parties, subcontractors, suppliers, clients and others — who are also expected to comply with these general principles. Any person in scope of the Policy is referred to as “employee” in this document.

Purpose: This Policy sets-out the minimum standards applicable by all MTE employees. It provides guidance on how to ensure that MTE conducts its business honestly, fairly, and professionally in accordance with the best interest of its clients.

MTE management commitment: The MTE management body takes collective responsibility for setting a culture within MTE in which corruption is not tolerated, and for the effective design and implementation of the MTE anti-corruption program. The MTE management body has also taken reasonable steps to ensure that all MTE personnel, including members of the MTE management body,are aware of the Policy in respect of corruption and that it works along-side other policies which, in sum, contribute to strengthen the anti-corruption framework of MTE.

Prohibited conduct: Prohibited activities include offering, promising, giving (or authorising the offering or acceptance) of a benefit, cash payment or valuable item, either directly or indirectly (for example through a business partner or some other person), to a public official and in general to anyone, in view of:

  • influencing an administrative or business decision or
  • getting this person to perform his or her duties disloyally or inappropriately, or
  • obtaining an undue advantage.

Pursuant to MTE’s values and Code of Conduct, MTE employees are also prohibited from soliciting or accepting an undue advantage in order to induce them to perform or refrain from performing any act within their responsibilities. Facilitation payments, i.e. payments made to a public official to facilitate, expedite or secure the execution of an administrative decision, are prohibited regardless of the amount involved.

Bribery and corruption risks

MTE has adopted a risk-based approach when managing the risk of bribery and corruption which is informed by the following principles:

  • Cash payments
  • Employment
  • Gifts and invitations to events
  • Accommodation, travel and related expenses
  • Conferences and events
  • Charitable donations & corporate social responsibility
  • Political donations
  • Sales & lobbying
  • Outsourcing

MTE’s anti-corruption framework

Bribery and corruption can have a devastating effect as they could result in significant financial loss and other long-term business repercussions such as reputational damage. MTE has implemented effective controls to prevent, mitigate and adequately manage bribery and corruption risks. The anti-corruption system implemented at MTE is notably based on:

  • Specific governance system for the fight against corruption
  • Mapping of corruption risks
  • Training and awareness-raising programs on regular basis
  • Due diligence on all potential clients, partners, and service providers to assess the risk of corruption
  • Code of conduct that outlines ethical and transparent behavior, including the prohibition of bribery and other corrupt practices
  • Monitoring of all transactions and business relationships to identify and address any potential corrupt practices
  • Enforcement mechanisms: sanctions and disciplinary measures in place in case of of anti-corruption policy violation
  • Strengthening and protecting mechanisms for whistleblowers

MTE has set up a whistleblowing procedure that enables employees to escalate behaviors or situations that are contrary to MTE’s anti-corruption measures. A whistleblowing tool is made available to collect this information here. MTE is committed to the highest standards of protection for any person that would report any bribery or corruption, or suspected bribery or corruption in good faith.