We are an innovator, creating and distributing cars and parts to drivers all over the world. We recognize that one unlawful or improper act, even if unintentional, can harm our reputation and our future, so we insist on conducting business ethically and in compliance with the law everywhere we operate.
Our Company succeeds based on the merit of our products — never because of illegal bribery or corruption. Follow our policies and the law wherever you do business. Understand that the consequences for engaging in these activities can be severe, so avoid even the appearance of anything improper.
Know how to recognize a bribe. Typically, a bribe is defined as a financial or other advantage given or received for the purpose of improperly influencing a business decision. Many anti-bribery laws prohibit offering, receiving or giving bribes.
Be familiar with the law. Anti-bribery laws vary from country to country, so know the laws that apply where you work. If the laws where you work conflict with our policies, follow the more restrictive requirement. Be sure to follow our policies and report suspected illegal or unethical activity. If you ever need help — speak up.
Do business with the government ethically. Often stricter rules apply when working with the government. Never make a payment to a government official to facilitate or speed up a routine action, such as processing paperwork or issuing visas. Payments like these are called “facilitation payments” and are prohibited under our policies.
Take care when working with third parties. Be fair and ethical when negotiating with any third party, competitor or government official. Avoid any action that might appear to be inappropriate.
Never give anything that could be perceived as being offered to obtain an improper advantage. Remember, even if it’s allowed by local law, it could still be considered an unethical payment under our policies.
A BRIBE COULD BE:
BRAKING POINT
Know that we can be held liable for the acts of third parties, so never allow a third party to engage in illegal or unethical activities on our behalf.
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One of our suppliers offered to hire my son, who just graduated from college, if I made sure that her company was offered a contract. Since it’s not in cash, it’s not a bribe, right?
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We recognize that especially strict rules apply when doing business with the government. As with all other business partners, do your best to be a responsible partner and always be fair and honest in your interactions with government representatives.
Interact with integrity.
Cooperate with investigations.
BRAKING POINT
The rules that apply when interacting with the government are often stricter than those that apply when working with our regular business partners. Know your obligations and always avoid even the appearance of anything improper.
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I wanted to provide a complimentary dinner to all of the attendees of a Company event. A colleague told me that it could be a problem for some of the attendees who work for the government. Is she right?
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The exchange of gifts, entertainment and hospitality is a practice that is often meant to show goodwill and build business relationships. However, an offer that is expensive or offered too frequently or at a time when a business decision is being made can suggest something improper. That is why our policies are specific about what is permitted and what is not. We want to make sure that anything given or received does not affect our objectivity in making decisions on behalf of Mazda.
Check our policies. They describe in detail what is permitted but in general, gifts you offer or accept may only be token items valued at less than €50, such as calendars, pads of paper, pencils and logoed tie clips. Cash or cash equivalents (including gift cards, gift certificates, loans or shares of stock) are never acceptable.
Stop and consider before you offer or accept a gift or an invitation: Is it being offered during a competitive bidding or contract renewal process? Is it being offered in an effort to obtain business or gain an unfair advantage? If so, the offer violates our policies, and you must refuse it.
Meals, entertainment or hospitality offers must be reasonable in value, and our policies provide details about what is permitted. In all cases, there should be a legitimate business purpose, and both parties (the person making the offer and the person accepting the offer) must be present. The location should be one that’s conducive to discussing business and never something that could bring embarrassment or dishonour to Mazda.
Paying for flights or overnight stays or offers to use someone’s holiday home or jet or luxury vehicle? These types of offers are a clear violation of our policies and strictly prohibited.
Seek guidance. If you are not sure if an offer complies with our policies, check with your manager and the European Audit and Control office in advance. We politely refuse any gift or invitation that is inconsistent with our policies. If you encounter a situation where you cannot gracefully decline a gift, accept it, but immediately (no later than the next working day) report it to Mazda, in accordance with our policies, so that a determination can be made about its disposition.
BRAKING POINT
Gifts, entertainment and hospitality must always comply with the policies of both the giver and receiver and never be solicited.
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A dealer offered to take me to dinner and a play at a local theatre after our meeting. I’m not sure of the value of this offer — can I accept the dealer’s invitation?
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The decisions we make on behalf of our Company should always be objective and impartial. When you are involved in a personal activity that affects your ability to make objective decisions, it creates a conflict of interest. Even the appearance of a conflict can harm our Company and its reputation. You have a responsibility to avoid conflicts of interest and never use your position for personal gain.
Though it is not possible to list every situation that could present a conflict, there are a few instances where they typically occur:
Outside employment — Working a second job, self-employment, a consulting engagement or other opportunity that takes away the time, energy or commitment you bring to your position.
Personal relationships — Supervising a family member or a close friend or helping such a person in a business relationship with our Company or entering such a business relationship.
Financial interests — Investing in one of our customers, vendors, competitors or a company that wants to do business with us or lending or borrowing money from business partners or competitors.
Board memberships — Serving on the board of an organisation that shares the same interests as our Company, such as a competitor, partner or professional organisation.
Business ventures — Taking an opportunity you learned about through your position with our Company for personal gain or starting a business that competes with our Company.
Not sure if something is a conflict? Ask yourself:
Disclose conflicts. If you become aware of a potential conflict of interest, disclose it according to Mazda’s policy immediately and seek guidance to determine the appropriate course of action. Participate in the regular conflicts of interest surveys.
BRAKING POINT
It’s not always easy to spot a conflict. Generally, you should avoid situations where your personal interests compete with the interests of our Company. Follow our policies and seek help if you’re ever unsure.
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I operate my own business. I only work on it during weekends at home, using my personal computer. Is that okay?
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Mazda embraces fair competition, which encourages companies to offer consumers innovative goods and services at the most favourable terms. To be effective, competition requires companies to act independently of each other. Competition laws (also known as antitrust laws) prohibit anti-competitive contacts and interactions between companies which may distort competition. Violations of competition laws are prosecuted as serious crimes in many countries, so it’s important to know what is allowed and comply with the respective laws.
Never engage in activities that may disrupt fair competition. Be aware that antitrust law violations may occur:
BRAKING POINT
Even casual conversations or email exchanges could be seen as anti-competitive, so be mindful about what you discuss with others, especially competitors. If you’re ever unsure about communications or interactions with others, seek help from inhouse or external legal counsel.
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I received an invitation to a meeting where one of our competitors may also be attending. There is no agenda for the meeting and it is possible that among other things the competitor may share some of its pricing strategy. I know that I should not disclose any of our pricing strategy. Should I attend?
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We are proud to serve customers and clients all over the world. As a global Company, we are obligated to abide by applicable trade compliance and export control laws. Be familiar with and follow the laws that apply to your work to avoid unethical or illegal trade practices.
Comply with trade regulations. It’s important that you know and follow all applicable trade compliance and export control laws in your work. Our ability to import and export our products is a privilege, not a right, and a violation of these laws can significantly affect our operations.
When engaging in international transactions, always:
Select ethical trading partners. Research and verify the integrity of third parties and report any suspected violations of trade compliance laws.
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I’m working with a dealer who plans to export our cars to a neighbouring country in the Middle East. Can I ignore this?
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