CSL operates in a diverse and complex marketplace where bribery and corruption are risks that could expose the company and employees to possible prosecution, fines and imprisonment. CSL has a number of commercial arrangements with governments and related agencies across various geographies, presenting both challenges and opportunities to the organisation.
CSL’s Audit and Risk Management Committee monitors the company’s risks relating to corruption through risk reports from CSL business units and via the internal audit function. We assess our overall risk relating to corruption to be low, but remain diligent in enforcing relevant polices, mandatory training and the ongoing assessment of risk in this area.
CSL’s Code of Responsible Business Practice (our Code) provides a high-level policy statement on preventing bribery and corruption. A stand-alone Anti-Bribery and Anti-Corruption Policy provides specific guidelines on CSL’s expectations and requirements for employees, such as the prohibition of facilitation payments and how to raise concerns.
In addition, CSL’s Anti-Bribery and Anti-Corruption Policy, along with our Code, ensures CSL and our employees are acting with integrity at all times. New starters receive anti-bribery and anti-corruption training upon commencement with CSL and undergo additional focused training and updates as appropriate via online or face-to-face channels depending on job function and the classification of risk identified for the region.
We have other related global policies – Provision of Gifts, Entertainment and Hospitality, and Interactions with Healthcare Professionals and Healthcare Organisations – which provide further guidance to employees on acceptable limits for expenses incurred in connection with company business, and establish a formal approval process by senior management for certain expenses over a prescribed amount (or such lower amount as may be set in a particular country by local management), and also provide guidance on appropriate dealings with healthcare professionals and healthcare organisations.
- Overseen by CSL's Global Compliance Committee, we implement globally a comprehensive suite of mandatory legal compliance training, including anti-bribery and corruption;
- All new third-party intermediaries are subject to a due diligence process and an annual compliance certification;
- Anti-bribery training is also provided to certain third-party intermediaries based on an overall assessment of several risk-related factors, including the risk rating for the country in which the third-party intermediary is operating;
- All our operations are required to conduct on a biannual basis a specific assessment of bribery and corruption risk within their businesses. This is achieved by means of a standardised questionnaire that is completed and the responses are then reviewed by the GCC;
- All CSL Group operations are required to provide a sign-off in their management representation statements as part of the half-year and full-year accounts process to confirm that there have been no instances of bribery or corruption within their business; and
Employees and managers are required to declare any potential conflicts of interest as they become aware, with local leadership teams providing direction on how such conflicts should be treated. We consider our overall risk relating to corruption to be low and are committed to ensuring full compliance in how we conduct our operations across all regions where we operate and are seeking to enter.