LEE Engineering & Construction Company Limited adopts a zero-tolerance approach to bribery and corruption. As a reputable company, LEE Engineering conducts business affairs in a responsible manner that shuns the use of corrupt practices or acts of bribery in order to obtain unfair advantage in our dealings within the markets and the communities we operate.
This policy is in compliance with some notable international regulatory bodies like the FCPA and New UK Anti-Bribery Act, Other Related Acts and all applicable anti-bribery authorities covering both international and local jurisdiction.
LEE Engineering’s Anti-Bribery and Anti-Corruption Policy is an integration of various policies and guidelines as seen in the diagram above.
OUR PHILOSOPHY
The objectives of LEE Engineering ANTI-BRIBERY AND ANTI-CORRUPTION POLICY are as follows:
Ensure that LEE Engineering businesses are conducted in an honest and ethical manner. LEE Engineering is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships at all times wherever it operates.
Ensure that LEE Engineering does business with a zero-tolerance approach to bribery and corruption.
Ensure that LEE Engineering is bound by the laws of Nigeria and all other international and local laws relevant to countering bribery and corruption in the jurisdictions in which it operates.
Ensure that LEE Engineering’s Reputation is adequately maintained and preserved by employing competent and capable personnel Bidding for projects by following due processes.
Occasionally, the company places advert on CNN, Journals, Newspapers and other Local Television and Radio stations to showcase its transparency in business dealings as well as emphasis on its business expertise and techniques.
LEE ENGINEERING’S COMPLIANCE POLICY
LEE Engineering’s Anti-Bribery and Anti-Corruption Policy require that LEE Engineering employees, directors, and business associate in Nigeria and all of its Subsidiaries abide by the following ethical conducts:
Prohibition from all kinds of inducements by offering, promising, giving, requesting, accepting or agreeing to receive bribe of any kind in any form, directly or indirectly.
Prohibition from making facilitation or “grease” payments, even if this represents local practice or custom.
Prohibition from offering, promising or transferring anything of value to a public official in order to influence the public official and obtain or retain business or an illicit advantage for the benefit of LEE Engineering (or to obtain or retain an advantage for any employee, any other entity or person). This includes offers, promises or transfer made to any third party (such as public official’s family members or business associates) in order to influence a public official.
To carry out appropriate due diligence on parties when LEE Engineering proposes to engage them to perform services for or on our behalf, and to include appropriate anti-bribery and anti-corruption clauses in contractual arrangements with such parties.
Prohibition from offering /giving /accepting gifts from third parties unless this is permitted within the limit of Local laws and practices.
Required to adhere to the internal requirements of reporting to the Internal Auditor who is the Compliance Officer, working side by side with the CSO (Chief Security Officer), also known as the Implementation Officer. Any suspicions or attempts of bribery and corruption as well as suspected or actual breaches of LEE Engineering Anti-Bribery and Anti-Corruption Policy must be reported.
To understand appropriate anti-bribery and anti-corruption training and awareness programme at least once every year.
To audit donations and Sponsorships.
LEE ENGINEERING’S REPUTATION
LEE Engineering has built a respectable reputation by dint of its committing to excellence and maintaining high quality standards in all aspect of its job delivery processes. This is also evident in the fact that LEE Engineering has no Bank case, Court case or any Economic Crime case. Engaging in bribery has never been and will not be a precondition for LEE Engineering’s emerging market success. There are practical steps that the company has taken to avoid falling afoul of anticorruption statutes and to lessen the potential competitive disadvantage of abstaining from corrupt practices. To minimize the risk of prosecution, LEE Engineering has adopted rigorous due diligence procedures and established reputations for ethical business dealings. In competing effectively, LEE Engineering has closely monitored competitor’s conduct, drawn on the support of their governments and used both international statutes and local mechanisms to hold other companies to similar standards of behaviour.
LEE Engineering has a strong anti-corruption culture in place, which has set in motion a kind of virtuous cycle. The company has successfully developed a reputation for strictly abstaining from corrupt behaviour which discourages counterparties from even attempting to extract bribes, significantly lowering the risk of any incident. Developing such a reputation requires discipline, the right set of internal practices and support from top management, which are some of LEE Engineering’s attributes. LEE Engineering’s longstanding commitment to operate free of corruption worldwide, has endowed the company with an enviable image of responsibility, and the company’s success shows that bribery is an abominable element for doing business in the world’s most rapidly expanding economy.
TOP CAMPAIGN
LEE Engineering is in strong support of InternationalAnti-Bribery Acts and Local Agencies which include:
Foreign Corrupt Practice Act, FCPA.
New U.K. Anti-Bribery Act.
Economic and Financial Crimes Commission, EFCC.
Independent and Corrupt Practices and Other Related Commission, ICPC.
Code of Conduct Bureau, CCB.
It is a known fact that clear policies/procedures with approval processes and stringent controls, alongside regular internal audits of high-risk areas are all necessary measures. But more importantly, is the strong local leadership with respect to the issue of compliance which has been LEE Engineering’s Watchword since 1991, being a company established during the dictates of the Military regime, swimming through and smoothly into the existing Civilian regime.