At ICL we are all responsible for understanding the important legal and ethical issues that affect our business and for acting with integrity at all times. Integrity means complying with both the spirit and the letter of the laws and regulations that govern our industry. ICL’s zero tolerance on corruption and ethical standards are set out in our Code of Conduct, Group Policy Anti-Corruption and other governing documents, which is implemented in all ICL’s subsidiaries directly or indirectly controlled by ICL ASA. All suppliers and parties that have a direct contractual relationship with ICL and offer products or services to ICL must comply with to our Supplier Conduct Principles. These principles set out the minimum standards that we expect to see achieved over time, including on ethics and anti-corruption.

Top-level commitment is vital for establishing a transparent and enterprise-wide culture which works against corruption. ICL’s management is committed to sending clear, unambiguous and regular messages to all staff and business partners that corruption and bribery is unacceptable. The Ethics and Sustainability Committee of ICL ASA’s Board of Directors supports the Board in fulfilling its responsibilities with respect to ethics and anti-corruption.

Our Anti-Corruption Program

ICL’s Anti-Corruption Program is rooted in our Code of Conduct and Group Policy Anti-Corruption. Its design, implementation and enforcement are risk-based and tailored to prevent corruption throughout ICL’s business activities. It applies to all persons working for or on behalf of ICL.

The Anti-Corruption Program includes several elements working together. Ethics and anti-corruption considerations are integrated into ICL’s business activities and decisions across all functions and levels. ICL has an organization with clearly defined roles and responsibility for implementation of the Anti-Corruption Programme, both at Group and Business Unit level. The Group Policy Anti-Corruption and the effectiveness of the Anti-Corruption Program are assessed and revised on a regular basis.

The Anti-Corruption Program works together with ICL’s Ethics & Compliance function. All employees may report any concerns to the Local Ethics & Compliance Manager, or ICL Group compliance functions at ICL’s “Hotline to Compliance”. All reporting shall be treated confidentially.

Our Anti-Corruption Handbook

ICL’s Anti-Corruption Handbook is a practical guide to help all ICL employees to understand and live ICL’s values and formal policy relating to anti-corruption.

Corruption takes many forms. Our Anti-Corruption Handbook shall assist our employees to navigate challenges related to gifts, events and representations, facilitation payments, public authorities and middlemen and business partners. The guidelines shall help each employee to make the right decisions. The Handbook cannot provide answers to every situation and dilemma that our employees may face. Our employees are strongly encouraged to seek advice when in doubt.

Anti-corruption in Supply Chain and Third Party Relations>

Integrity is a vital part of ICL’s business. We recognize that our business partners, whether new investments, partners, agents, consultants, contractors or suppliers, will be associated with ICL. It is crucial to ensure that ICL’s business partners are in compliance with our ethical standards. ICL has implemented mandatory requirements for screening and conducting integrity due diligence assessments of our business partners.

All suppliers and parties that have a direct contractual relationship with ICL and offer products or services to ICL must adhere to our Supplier Conduct Principles. These principles set out the minimum standards that we expect to see achieved over time, including on ethics and anti-corruption. Anti-corruption is part of the regular supplier engagement and forms part of supplier training & awareness activities in various forms in the local markets.

ICL monitor compliance through a systematic, risk-based approach, which may include both announced and unannounced site visits. We encourage our suppliers to implement an efficient anti-corruption program to minimize corruption risk.