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The ABC Program was approved by ICL’s Board of Directors in 2014 and thereafter in 2020. The Anti-Bribery and Corruption Policy and Handbook establish the Company’s commitment to zero tolerance of bribery and provide employees with detailed guidance and examples of how to recognize and avoid bribery in common business situations.
An initial high-level risk assessment identified the following areas of risk, which are the major focuses of the Program:
ICL’s Third Party Due Diligence Policy and Procedure ensures that all external business partners who interact with government agencies and officials, in the course of providing services to ICL, undergo background checks, agree in writing to comply with ICL’s Code of Ethics and ABC Policy, and provide information about their ownership, management, business registration, and business practices. Additional background checks and investigations are undertaken when warranted based on the level of risk. This Policy and Procedure also extend to sales agents, distributors, traders and other intermediaries that represent ICL to its end user customers in the marketplace.
ICL’s Gift and Entertainment Policy requires all employees to obtain prior approval for gifts and entertainment for higher value items and for those which involve government officials. The Gift & Entertainment Policy applies to all ICL employees wherever they are located. It applies both to giving and receiving gifts and entertainment. Reminders of this Policy are routinely sent to employees prior to the major holiday periods in their region or location.
ICL’s Procedure of Community Relations and Donations requires a background check on all partner organizations and other recipients of monetary or in-kind donations, regardless of value. Higher value donations require a more intensive application and review process.
These procedures are communicated through face to face and online training to all new employees in management, sales, customer service, finance and accounting, and procurement. Existing employees receive periodic refresher training.
Controls have been established to ensure that unapproved parties subject to the requirements of the Third-Party Due Diligence Policy are not set up as vendors or customers in our information systems and do not receive payments. Other compliance program controls reinforce these requirements, including:
Adherence to the ABC policies, procedures and controls is monitored through means such as reviewing expense reports for unapproved gift and entertainment spending, as well as reviewing sales commission payments to ensure that only approved parties have been paid. The Company also detects unauthorized spending through audits, and incorporates lessons learned from both audits and monitoring into the design of the program.
The Fraud Risk Management Program ensures that ICL takes a systematic approach to identifying and mitigating fraud risk throughout the organization, in alignment with the COSO Fraud Risk Management Guide (2016). Resources are proactively targeted to the threats and issues posing the highest risk.
The Fraud Risk Management Policy and Program Framework establishes the company’s zero tolerance approach to fraud, defined as any intentional act or omission designed to deceive others, resulting in the company suffering a loss and/or the perpetrator achieving a gain. It also defines the roles and responsibilities of management, Compliance, Legal, Global Security, Human Resources, Internal Audit, and IT Security in preventing, detecting and investigating fraud. The Program is overseen by a cross functional Fraud Risk Management Steering Committee and managed by a global Program Manager.
Based on a comprehensive risk assessment conducted at one of the company’s major production sites, the Fraud Prevention Manual for Operations was developed in 2016 and control enhancements were implemented at all ICL operating locations throughout the world. An additional risk assessment for global functions led to further control enhancements in Israel. ICL continues to engage in targeted fraud risk assessments of locations and business areas considered to be at relatively high risk.
A major focus of this Program is the detection and prevention of social engineering fraud by way of phishing attacks using email and other forms of electronic communication. Employees throughout the company are trained on how to identify and report phishing attempts through live and digital based training events, as well as the use of targeted phishing drills.
Implementation of the controls is monitored systematically by spot checking transactions for compliance, following a risk-based monitoring plan.
ICL has an established procedure for signatory rights and authorization. According to company policy, two defined, authorized signatories are required to legally bind the company in any contractual obligation or legal action.
