We put integrity and fair play at the heart of all relationships

Investigations by competition authorities may result in significant fines, costs, and compensation claims by our customers and competitors. It can also seriously damage our reputation and commercial relationships. Criminal sanctions for individuals, including imprisonment may also apply.

To protect ofi we will: 

• comply with all applicable competition laws; 
• read and understand ofi’s Competition Law Policy; 
• attend and complete all relevant training, especially where involved in marketing, sales and purchasing, M&A or are in regular contact with our competitors; 
• follow four key rules: 
  • Set our own prices: do not agree or dictate resale prices at which our own customers and distributors can resell products to their end users. 
  • No price fixing: do not enter into arrangements with competitors to fix prices, whether directly or through a third party. 
  • No market rigging: do not ‘carve up’ markets or allocate customers between us and our competitors, nor enter into agreements that have the effect of restricting sales or bid entries to certain customers only. 
  • Protect commercially sensitive information: do not exchange price sensitive, strategic, or confidential information with competitors nor ask our customers or distributors to provide us with price sensitive or confidential information about our competitors. 

Breaches of competition and anti-trust laws can occur inadvertently so when in doubt, consult LEGAL immediately.

Conflicts of interest

Should you ever be faced with a potential conflict of interest at work, you must place ofi’s interest above your own personal interests.

Examples can include:

• hiring (final decision on hiring) friends or relations; 
• offering a contract (final decision on offering) to friends or family;
• procurement of goods and services from a firm you have a financial interest in; 
• sponsoring/awarding services or collaboration driven by personal interests; 
• pursuing a business opportunity that is in competition with ofi’s business interests; 
• using business information for personal use. 

To protect ofi we will:

• at the earliest opportunity, advise our immediate manager, or make a formal declaration, of any personal interest that could inappropriately influence our judgement when we are acting for ofi;
• for further information, read the Conflicts of Interest Policy and consult LEGAL should you need any further guidance.

Anti-bribery and corruption

ofi has a zero-tolerance stance when it comes to bribery, facilitation payments, and any form of corruption. We operate in some countries where it may be common practice to request or pay bribes in order to do business. Paying any bribes, no matter how small, only allows this unethical practice to continue.

Bribery or a bribe includes, directly or indirectly:

• promising; 
• offering; 
• agreeing to pay; 
• authorizing payment of; 
• paying; 
• giving; 
• accepting; 
• requesting; 
• soliciting; 

anything of value to or from a third party intending that a person performs (or is rewarded for performing) their role improperly.

Being bribed is also prohibited. No employee may accept, request, or solicit a bribe.

Facilitation Payments - or ‘grease money’ - are one of the most common forms of corruption. These are small bribes to ensure speedy processes, queue-jumping, inspections approvals and the like. The payment of Facilitation Payments are strictly prohibited in ofi.

To protect ofi we will:

• act professionally, honesty and fairly in all our business dealings and relationships; 
• read and become familiar with the ofi Anti-Bribery and Corruption Policy; 
• report to LEGAL where a third party suggests or offers, a bribe. (This can also be done directly via the ofi Whistleblowing line); 
• implement appropriate Anti-bribery wording in contracts; 
• contact LEGAL with any concerns or questions.

To protect ofi we will not:

• offer or give bribes to any Government Official or other third party; 
• request or receive bribes from any third party; 
• agree to pay a facilitation payment unless we believe our safety, or the safety of others is at stake. Records of all such unavoidable payments must be fully documented.

Gifts and entertainments

Gifts and entertainments can play a positive role in building relationships with stakeholders. However, these should be moderate in value, appropriate, justifiable, and not disguised or given in secret.

Gifts and/or entertainments (G&E) is anything that has commercial or personal value e.g., discounts, loans, sponsorships, favorable terms on any product or service, transportation, use of ofi’s assets, subsidizing of expenses, tickets to a sporting or theatrical event, accommodation, client entertainment, dinner, or drinks.

To protect ofi we will:

• ensure that all G&E provided is not excessive in value, reasonable and does not fall into the prohibited category as defined in the ofi Anti-Bribery and Corruption Policy; 
• wherever possible, avoid providing G&E in excess of the threshold level set out in the ofi Anti-Bribery and Corruption Policy; 
• Where any G&E exceeds the threshold level set out in the ofi Anti-Bribery and Corruption Policy, a full explanation should be provided stating why it was considered necessary and appropriate. 

To protect ofi we will not:

• provide or accept G&E to/from a Government Official without the prior approval of LEGAL;
• receive or provide gifts or entertainment that may give rise to a conflict of interest. 

Tax evasion

We do not evade tax or facilitate the evasion of tax by others, in any jurisdiction.

ofi operates in some jurisdictions.that are higher risk from a tax evasion perspective. We must be alert to suspicious behaviors and situations that may suggest parties are involved in tax evasion or facilitation of tax evasion.

For example: 

• a counterparty intends to make or receive payments from multiple bank accounts, or submits invoices addressed to a different entity, or other unusual payment methods; 
• a counterparty has made a false statement relating to tax or income or has not been transparent with a tax authority in some way; 
• a counterparty requests payment in cash or fails to provide invoices or contractual documentation relating to dealings with ofi; 
• a counterparty seeks to include an intermediary in its dealings with ofi, particularly where the justification for using the intermediary, and their identity, is unclear; 
• a counterparty seeks to make payment in currencies different to the invoice currency.

To protect ofi we will: 

• ensure all third parties that we deal with are aware of ofi’s zero tolerance approach to tax evasion and facilitation of tax evasion before entering into a relationship with them; 
• include anti-tax evasion wording in contracts entered into with third parties; 
• read and understand the ofi Non-Facilitation of Tax Evasion Policy.

Engaging government, officials and Non-Government Organizations (‘NGOs’)

ofi routinely works with government, officials and NGOs on matters that concern our business. We expect employees to act with the highest level of integrity and in a fair and professional manner, following laws around the world which regulate interaction with Government Officials.

To protect ofi we will:

• deal honestly with governments, officials and NGOs and are open, transparent and accurate about the purpose of the interaction; 
• disclose our identity and relationship with ofi, the purpose of the representation and ofi’s position or standpoint; 
• be open and transparent about the nature of the organization, its position and connection with ofi when acting as a formal representative on behalf of a trade association or industry alliance; 
• only approach public authorities with a clear mandate from the industry organization; 
• read and understand the ofi Government Interaction Policy.

 Political donations

ofi is strictly against making any political contributions, monetary or otherwise, to political candidates, political parties and political associations (or similar).

To protect ofi we will:

• ensure any contributions towards, and support for, political parties are clearly personal and do not affect our personal performance or objectivity at work; 
• read and understand the ofi Government Interaction Policy. 

To protect ofi we will not:

• directly or indirectly offer, pay or promise any donations or anything else of value to public authorities or government officials for the purpose of obtaining any business advantage for ofi.

Responsible marketing and communications

ofi is committed to responsible marketing and external communications. Our approach aligns with our high standard of business ethics and our ambitious mission to drive transformation in the agriculture and food sectors, in an ethical, responsible and sustainable way.

To protect ofi we will:

• only make claims of nutritional and health benefits when a sound scientific basis exists, and in compliance with all applicable regulations in countries where we operate; 
• create communications that show positive, diverse and unbiased portrayals, which are not discriminatory or offensive to any group or person based on social, racial, ethnic, religious, gender, age or physical traits. 

To protect ofi we will not: 

• provide communications that contain false or misleading information or terminology; 
• aim marketing communications directly at children under the age of 12 years. 

To view the Policies referred to in this section contact the ofi Legal, Compliance and Co Sec function.