Business ethics policy: zero tolerance for bribery, corruption and fraud.

Sterling operates on zero tolerance for bribery, corruption and fraud, across every dealing with clients, suppliers, certification bodies, training institutes, subcontractors, competitors, government officials and the public, in every country where we operate. Adopted in 2020 and maintained since, this policy is the ethical floor beneath every engagement; for a firm that implements ISO 37001 anti-bribery management systems for clients, it is also the homework we did first. It applies to employees, subcontracted consultants, agents and anyone else acting for Sterling or its group companies.

No one acting for Sterling may give, promise, offer, request or accept any payment, gift or hospitality intended to secure or reward a business advantage, or to facilitate or expedite a routine procedure. In particular, it is not acceptable to:

• Give, promise to give or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to facilitate or expedite a routine procedure.
• Request, agree to receive or accept a payment from a third party that is known or suspected to have been offered with the expectation that it will obtain a business advantage from Sterling.
• Take part in any activity that might lead to or suggest that a facilitation payment or kickback has been made or accepted by Sterling.
• Accept a gift or hospitality from a third party if it is known or suspected to have been offered with an expectation that a business advantage will be provided by Sterling in return.
• Threaten or retaliate against an employee who has refused to commit a bribery offence or who has raised a concern under this policy.

Facilitation payments are not made, whatever the local custom, including to speed up visas, permits or customs clearance. Substantiated acts of bribery are notified to the relevant government agency and treated as gross misconduct, as is a failure to report an act an employee knows of or reasonably suspects.

Modest, occasional courtesy is part of business in many of the countries where we work, such as a working meal during an engagement or a small seasonal token. Anything more is declined. No gift or hospitality is given to or accepted from a client, a certification body or a public official while a decision that affects Sterling or its client is pending, and cash or cash equivalents are never acceptable. Anything offered beyond a modest courtesy is reported to Sterling's management.

Everyone acting for Sterling, whether employee, subcontractor, agent or supplier, must act ethically and with integrity at all times. No accounts are kept off the books to facilitate or conceal improper payments, and all expenses and entertainment follow documented procedures. In client work, honesty also means that we never create, backdate or alter a record to make a management system appear more mature than it is.

Sterling's people declare any personal or financial interest that could influence their judgement on an engagement, and are not assigned where it could. Sterling holds no stake in a client's choice of certification body. Where an engagement touches one of Sterling's group companies, such as Effivity, Sterling Academy, Lakshy, Sterling Philippines or Cyber Vantage 360, we disclose the relationship to the client before contract, as the Impartiality and independence statement sets out.

We expect suppliers, subcontracted consultants and partners to meet the same standard as Sterling, and we state it here rather than in a separate code:

• No bribery, corruption, facilitation payments or fraud.
• Safe and fair working conditions, fair pay, and no child, forced or illegal labour.
• Responsible management of environmental and social issues.
• Confidentiality of client and Sterling information, and compliance with applicable data protection law.
• Compliance with applicable law, and prompt disclosure of any conflict of interest.

A breach of these expectations may end the relationship.

Reasonable suspicions of bribery or fraud must be reported. Write to hello@sterling-grc.com with the subject "Ethics"; employees may also raise a concern directly with Sterling's management. Concerns are handled under our Complaints and feedback policy, and no one who reports in good faith is threatened, disadvantaged or retaliated against.