Anti-Bribery and Anti-Corruption


This policy applies to all individual employees of Miray International , including its branches, agents or other persons acting on behalf of Miray International and its consultants, contractors, and any other person providing services to us.



Miray International values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The actions and conduct of the firm’s staff as well as others acting on the firm’s behalf are key to maintaining these standards.

The purpose of this document is to set out the firm’s policy in relation to bribery and corruption. The policy applies strictly to all employees, directors, agents, consultants, contractors and to any other people or bodies associated with the Miray International group of companies, within all regions, areas and functions.


A bribe is a financial or other advantage offered or given:

To anyone to persuade them to or reward them for performing their duties improperly or to any public official with the intention of influencing the official in the performance of his duties



This policy is not meant to prohibit the following practices provided that they are customary, are Proportionate and are properly recorded:

Normal and appropriate hospitality. The use of a recognised fast track process which is publicly available on payment of an appropriate fee; and/or The offer of resources to assist a person or body, to make a decision more efficiently, provided that such is supplied for that purpose only.



We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. Kickbacks are typically payments made in return for a business favour or advantage.



We will keep financial records and have appropriate internal controls in place which will evidence the Business reason for making any payments to third parties. It is vital that the following records are kept:

All expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with our expenses policy and specifically record the reason for expenditure.


Examples of bribery:

Offering a bribe

You offer a potential client tickets to a major sporting event, but only if they agree to do business with us.

This would be an offence as you are making the offer to gain a commercial and contractual advantage. It may also be an offence for the potential client to accept your offer. Providing clients with hospitality is acceptable provided the requirements set out in section are followed.

Receiving a bribe

A supplier offers your nephew a job, but makes it clear that in return they expect you to use your influence to ensure we continue to do business with them.

It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage. You must decline the job offer.

Bribing a government official

You are asked to arrange for an additional payment to be made to a customs official to speed up the administrative process of clearing our property (e.g. personal protective equipment) through customs.

The offence of bribing a government official has been committed as soon as the arrangement is made. This is because it is made to gain a business advantage for us. It is illegal to make a facilitation payment and such payment must not be made even if doing business is made more difficult for Miray International if we refuse. You must never make such an offer.


Gifts and Hospitality

This policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure, such as calendars, diaries, meals, and invitations to arts and sporting events (given and received), to or from third parties.


The practice of giving gifts and hospitality is recognised as an established and important part of doing business. However, it is clear that they can be used as bribes. Giving gifts and hospitality varies between countries and sectors, and what may be normal and acceptable in one may not be in another. To avoid committing a bribery offence, the gift or hospitality must:

  1.   be reasonable and justifiable in all the circumstances; and
  2.   have the intention to improve the image of the commercial organisation, better present its products and services, or establish cordial relations.

The giving or receipt of gifts or hospitality is acceptable if all the following requirements are met:

  1. it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits or for any other corrupt purpose;
  2. it complies with local law;
  3. it is given in the name of Miray International, not in your name;
  4. it does not include cash or a cash equivalent (such as gift certificates or vouchers);
  5. it is appropriate in the circumstances. For example, in some countries it is customary for small gifts to be given at Christmas time;
  6. taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time;
  7. it is given openly, not secretly, and is given in a manner that avoids the appearance of impropriety;
  8. gifts and hospitality must not be offered to, or accepted from, government officials or representatives, or politicians or political parties.

If the gift or hospitality given or received is more than a token gift or modest meal in the ordinary course of business, you must obtain prior written approval from your Line Manager and it must be recorded in the gift and hospitality register.

Examples of token gifts:

  • Corporate calendar, pen, mug or umbrella
  • Modest bottle of wine
  • Bunch of flowers


The gift and hospitality register is a written record setting out full details of the gift or hospitality given or received including the approximate value, the purpose or intention of the gift or hospitality, the name of the recipient and provider of the gift or hospitality and their relationship. A register is maintained locally. Your Line Manager will know how to access your local register.


Examples of gifts and hospitality:


1. You want to invite an important shipping client to attend a fine dining lunch and football match at Fenerbahce Stadium in Istanbul as part of a public relations exercise designed to cement good relations and enhance the client’s knowledge of our services. Is this acceptable?

Yes. This hospitality seems to be reasonable and justifiable in all the circumstances and the intention is to improve our image, better present our products and services, and improve cordial relations.

2. You want to invite a potential client to watch a sailing regatta a month before the deadline for Miray International to tender for a large management systems contract as you hope this will persuade them to accept your tender. Is this acceptable?

No. This hospitality would constitute bribery as it would be made with the intention of influencing potential clients to obtain business. The timing of this hospitality is important. If there was no tender deadline you may be able to entertain the potential clients without breaching the law. This is because the intention of the hospitality would be to improve our image, better present our products and services, and establish cordial relations with the potential client.

3. A client has offered you a five star, seven-day cruise holiday in the Maldives for you and your partner on one of its ships as a thank you for the last special survey you completed. Can you go?

No. Taking into account the reason for the gift, the value of the holiday is excessive and unreasonable in the circumstances. A more appropriate and justifiable gift may be a bottle of wine or corporate diary or calendar. You should politely decline the gift and explain that you cannot accept such a generous offer.


What Is Not Acceptable?

It is not acceptable for you (or someone on your behalf) to:

  • Accept an offer of a gift of any size from any company which is in negotiation with, or is tendering for a contract with us;
  • Give, promise to give, or offer, any payment, gift, hospitality or advantage with the expectation or hope that a business advantage will be given or received, or to reward a business advantage already given;
  • Give, promise to give, or offer, any payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
  • Accept or solicit any payment or advantage from a third party that you know or suspect is being offered with the expectation that it will obtain a business advantage for them;
  • Accept or solicit a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
  • Threaten, or retaliate against, another employee who has refused to commit a bribery offence or who has raised concerns under this policy; • or engage in any activity that might lead to a breach of this policy


Facilitation Payments and Kickbacks

1- We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. facilitation payments are typically small, unofficial payments (sometimes known as ‘grease, payments) made to secure or expedite a routine government action by a government official. kickbacks are typically payments made to commercial organisations in return for a business favour or advantage, such as a payment made to secure the award of a contract.

2-You must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Routine Government Action

Routine governmental action is an action which is ordinarily and commonly performed by a government official:

• Obtaining permits, licences, or other official documents to qualify a person to work or do business in a country;

• Processing governmental papers, such as visas  and work orders

• Providing police protection, mail pick-up and delivery or scheduling inspections associated with contract performance or inspections related to transit of goods across country;

• Providing phone service, power and water supply, loading and unloading cargo, or protecting Perishable products or commodities from deterioration; or actions of a similar Nature.


Facilitation payments are known to be prevalent in many countries and industry sectors. You may be concerned that the inability to make them may cause difficulties in doing business in some jurisdictions, and that this may result in loss of income or contract. The guidance set out below is intended to help support you in circumstances when you are asked to make facilitation payments.

Guidance on how to avoid making facilitation payments

Corrupt government officials demanding payments to perform routine government actions may often put workers in very difficult positions. There is no easy solution to the problem therefore. However, the following steps may help:

•   Require official receipts for any payments you make.

•  Public officials who refuse to co-operate without facilitation payments should be reported to any superiors they may have and to local enforcement authorities

We remain committed to our policy of not making facilitation payments. The only limited exception to this is in circumstances where you or third parties are left with no alternative but to make payments in order to protect against loss of life, limb or liberty. In the event that you experience such circumstances and make a payment, it is your responsibility to contact your Line Manager and the local enforcement authorities as soon as possible after the event, so that the incident can be properly recorded, reviewed and accounted for.


We do not make contributions to political parties, political party officials or candidates for political office. We only make charitable donations that are legal and ethical under local laws and practices. All charitable donations must be made in accordance with our Donations policy which requires the approval of the Chief Executive Officer. Refer to Corporate Secretariat for further detail.


1 – Your Responsibilities.

1.1  You must ensure that you read, understand and comply with this policy. If you have doubts or concerns contact your Line Manager or Chief Executive Officer, Corporate Secretariat.

1.2  The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

1.3  You must notify your Line Manager, and Chief Executive Officer, the as soon as possible if you believe or suspect that a breach of or conflict with this policy has occurred, or may occur in the future. An example is if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in the Schedule section at the end of this policy.

1.4  Any employee who breaches this policy will face disciplinary action, which could result in dismissal. We reserve our right to terminate our contractual relationship with you if you breach this policy.

2 – Record-keeping

2.1  For all hospitality or gifts accepted or given, other than token gestures and modest meals, you must obtain the prior written approval of your Line Manager and record the hospitality or gift in the gift and hospitality register in accordance with section. If you are in any doubt whether an item should be recorded, you should record it anyway.

2.2  You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

2.3  All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts will be kept “off-book” to facilitate or conceal improper payments.

2.4  You must follow the procedures in the Miray International Management System regarding anti-bribery and corruption due diligence on suppliers, potential joint venture parties and clients.

How to raise a concern

You are encouraged to raise concerns about any bribery issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your Line Manager in the first instance.


What to do if you are a victim of bribery and corruption

It is your responsibility to tell your Line Manager as soon as possible if you are offered a bribe by a third party, you are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of corruption or other unlawful activity. You must refuse to accept or make the payment from or to a third party, explain our policy against accepting or making such payment, and make clear that the refusal is final and nonnegotiable because of our anti-bribery and corruption policy. If you encounter any difficulty making this refusal, you should seek assistance from your Line Manager.



Those who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrong-doing, are sometimes worried about possible repercussions. We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.


Detrimental treatment includes dismissal, discrimination, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform your Line Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using your local Grievance Procedure.


Training and communication

Training on this policy forms part of the induction process for all new employees. All existing employees are required to undertake the relevant training on how to implement and adhere to this policy.

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business contacts at the outset of our business relationship with them and as appropriate thereafter.

Who is responsible for the policy?

  1. The Chief Executive Officer has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
  2. Line Managers at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and undertake training on how to implement and adhere to it.
  3. Line Manager ,Chief Executive Officer and Corporate Secretariat has responsibility for this policy, and for monitoring its use and effectiveness (and dealing with any queries on its interpretation). Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy, and attend regular training on how to implement and adhere to it.
  4. You are responsible for the success of this policy and should ensure you use it to disclose any suspected danger or wrong- Doing.

This policy does not form part of any employee’s contract of employment and it may be amended at any time

Schedule: Potential Risk Scenarios: “red flags”

The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these red flags while working for us, you have responsibility to report them promptly to your Line Manager, Chief Executive Officer as set out in How to Raise a Concern.

  • you suspect or become aware that a third party engages in, or has been accused of engaging in, improper business practices;
  • you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;
  • a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
  • a third party requests payment in cash and/or refuses to sign a formal contract, or to provide an invoice or receipt for a payment made;
  • a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
  • a third party requests an unexpected additional fee or commission to “facilitate” a service;
  • a third party demands lavish entertainment, hospitality or gifts before commencing or continuing contractual negotiations or provision of services;
  • a third party requests that a payment be made to “overlook” potential legal violations;
  • a third party requests that you provide employment or some other advantage to a friend or relative;
  • you receive an invoice from a third party that appears to be nonstandard or customised;
  • a third party insists on the use of side letters (i.e. agreed terms in a letter or other document outside the written contract between the parties) or refuses to put the agreed terms in a written contract
  • you notice that we have been invoiced for a commission or fee payment that appears large given the services stated to have been provided
  • a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;
  • you are offered an unusually generous gift or offered lavish hospitality by a third party; or
  • you become aware that a colleague, other employee or contractor working on our behalf request a payment from a third party (such as a client) to expedite an activity (such as an inspection or paperwork) or to “overlook” potential legal or regulatory violations.
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