Code of Conduct

Anti Corruption

We have zero tolerance for corruption.

We are committed to conducting our business in a law abiding and responsible manner.
Corruption is the abuse of entrusted power for private gain.
Bribery is illegal and exposes reputational and legal risk to ATOM and those involved.
Bribery may take many forms including facilitation payments, kick-back schemes, and an undue advantage of any value which could be financial or non-financial.
We never offer or accept a facilitation payment or unfair advantage.
We never engage in bribery, and never request someone else to do so.
Corruption in our supply chain may create significant risk for ATOM even if we are not directly involved and we apply anti-corruption measures to our business partners.
Gifts and hospitality may be considered as bribery or providing an improper advantage in certain situations.
Even charitable donations or sponsorships can be seen as bribes if undertaken to secure a commercial advantage.
Public Officials are often subject to strict anti-corruption rules and so should be treated with extra caution when interacting with them.
We assess the risks we may encounter and seek appropriate training and guidance to effectively manage them.
We promptly report bribery and corruption breaches to Integrity Hotline.

Code of Conduct Sections