GUIDELINES FOR CORPORATE INTERFACE WITH PUBLIC AUTHORITIES

Companies are increasingly playing an active role in the development of society, including development of laws, rules and policy documents. Often business is expected and even asked to do so. Providing expertise for more informed decision making, in a collaborative environment with governments, authorities and other relevant bodies is therefore an important responsibility. Corporate approach to transparent interaction with authorities and organisations must be based on what is good not only for the company but for consumers and society at large.

Any action undertaken in the context of advocacy activities should  comply with Corporate Business Principles, Code of Conduct and other relevant internal rules.

General Principles

• When interacting with politicians, public officials and other relevant bodies, employees should at all times act with integrity and honesty and in a fair and professional manner.
• Employees should always be open and transparent about the purpose of the contact and communication.
• In situations not governed by specific laws or business practices, employees should use good judgement and common sense, seek advice and direction of their managers.
• When contacting authorities and organisations within the framework of a trade association or talking directly to companies, applicable external and internal anti-trust or competitions rules should be fully complied with.
• Any advocacy activity that is undertaken on behalf of the company, including key messages and positions, should require prior managerial approval.
• Employees should , when making a representation to a politician, a public official or other relevant body disclose their identity and relationship with the company, the identity of the organization, on whose behalf the representation is made including the purpose of the representation and the position or standpoint. The same is true if a third party is acting on behalf of the Company.
• Employees should use best efforts to ensure factual accuracy of the information provided. The information must be clear about what are facts vs. opinion. Employees should never knowingly mislead anyone and should use proper care to avoid doing so inadvertently.
• Employees should respect and honour third parties intellectual property and corporate  confidential information, and not divulge such information to third parties. Under exceptional circumstances and for very special purposes, confidential information may be disclosed in full agreement with the Department Head/Supervisor.
• Within the framework of a trade association, company should act as an independent company. Should the company not agree with the opinion of a trade organisation or any of its member companies, employees should  be transparent about potential conflicting or competing interests, in agreement with the Department Head/ Supervisor. Company should use  best efforts to prevent its opinions and statements being misused to support viewpoints with which it disagrees.
• Employees should never, directly or indirectly or through intermediaries, offer or promise any personal or improper financial or other advantage to an official of a government, a government controlled entity or other relevant institutions for the purpose of obtaining information or influencing decision making. Moreover, employees should  refrain from any activity or behaviour that could give rise to the appearance or suspicion of such conduct or the attempt thereof. On the contrary, employees should foster an open dialogue and convince by using factual accurate information, compelling evidence and robust arguments.
• If employing former public officials, necessary measures should be taken to fully understand and comply with the rules and regulations laid down by the government, the relevant institution and with established best-practices in particular with regards to confidentiality and potential conflict of interest.