Think. Comply. Prevent. Doing the right thing ensures the
integrity of the Company and helps strengthen our reputation.
Avoiding corrupt practices positions us for a sustainable future.

Every Choice Matters

Video: Working together to prevent corruption

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Our Commitment To Compliance

We all have an obligation to maintain our values and legal standards in our business relationships everywhere we operate. Together we will continue this commitment as One Celanese. How we do business matters.



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HELPLINE

If you need to discuss an issue, the best place to start is often with your Supervisor. They know your situation; they can direct you to resources, help you with procedures, and lend immediate support. But you can also reach out to our Celanese Leaders, HR Partner, or Chief Compliance Officer.

The Ethics Helpline is always available to you to raise your compliance concerns confidentially or anonymously. It’s necessary to report certain compliance issues (bribes, price fixing, and failures of financial integrity) to the Chief Compliance Officer or the Ethics Helpline because they can result in serious consequences.

Read the Celanese Non-Retaliation Policy

Celanese will not permit retaliation for providing information regarding any conduct which you reasonably believe constitutes a violation of our Business Conduct Policy, any applicable law, or for participating in an investigation.


The Ethics Helpline

All Ethics Helpline calls are confidential and, if you like, you can raise concerns anonymously.

1.866.384.4223
(866-ethic ce)

INTERNATIONAL NUMBERS* (toll free)

Country AT&T Direct ®
Belgium 0-800-100-10 Brazil 0800 890 0288 China, PRC 108-11 France 0805-701-288 Germany 0-800-2255-288 Hungary 06 800-01111 India 000-117 Italy 800-172-444 Japan 00 539-111 Mexico 01-800-288-2872 Netherlands 0800-022-9111 Russia 363-2400 Singapore 800-0111-111 Spain 900-99-00-11 Sweden 020 799 111 U.K. 0800-89-0011

*1. AT&T Direct® for your country
2. Wait for tone
3. Then 866-384-4223

More AT&T Direct® numbers can be found here.

RED FLAGS

RED FLAGS

A red flag does not disqualify a Third-Party Intermediary (TPI) but does require additional review and, in some cases, mitigation to reduce potential risk. Here are some scenarios to consider.

  • Does TPI have reputation for a lack of integrity and ethical conduct?
  • Was TPI expressly recommended by foreign official?
  • Does TPI have close family connection or professional affiliation with foreign government or officials?
  • Does TPI refuse or hesitate to sign an agreement in which they represent and warrant that they will not violate anti-corruption laws?
  • Does TPI provide incomplete or inaccurate information in required disclosures or insufficient references?
  • Does TPI typically do this type of work, have the organizational resource or staff to undertake work required or propose significant use of sub-contractors?
  • Does TPI reside outside the country in which services are to be provided or is a shell company incorporated in an offshore location?
  • Does TPI request payment be made to an offshore bank account?
  • Does TPI make large or frequent political contributions?
  • Does TPI request excessive commissions in relation to services provided and/or typical industry and region payment ranges?
  • Does TPI request unreasonably large discounts?

THIRD-PARTY EVALUATOR

DOES YOUR THIRD PARTY QUALIFY AS AN INTERMEDIARY?

The following steps are required during the due-diligence process of determining potential Third-Party Intermediary status.

Answer these questions

If third party is a

  • Sales Agent
  • Distributor
  • Lobbyist
  • Customs Broker
  • Freight Forwarder
  • Reseller
  • Consultant
  • Supplier

What is the estimated value of Celanese product the reseller buys annually?

  • <$1,000,000
  • $1,000,000 or more

Please select the country where the third party will do business for Celanese?

Please select the country where the third party will do business for Celanese?

What is the estimated annual contractual value with the supplier?

  • <$20,000,000
  • $20,000,000 or more

What is the Corruption Perception Index (CPI) Score for the country where the third party will do business for Celanese? Identify a country’s CPI Score by going to Transparency International http://www.transparency.org/country, then select a country and find the CPI Score.

What is the Corruption Perception Index (CPI) for that country?

  • greater than 50
  • less than or equal to 50

What is the Corruption Perception Index (CPI) for that country?

  • greater than 50
  • less than or equal to 50

Is the third party a government official (includes a State-Owned Entity “SOE” – an entity in which the government directly or indirectly holds an equity interest)?

  • Yes
  • No

What is the estimated annual revenue?

  • <$5,000,000
  • $5,000,000 or more

Does third party interact with the Government (includes conducting business with Government-owned Entities/ State-owned Entities “SOEs” or obtaining permits, licenses, other documentation or certifications from a government agency on Celanese’s behalf)?

  • Yes
  • No

Is the third party a government official (includes a State-owned Entity “SOE” – an entity in which the government directly or indirectly holds an equity interest)?

  • Yes
  • No

Third party is an Intermediary subject to Anti-Corruption Policy due diligence and certification requirements and must be under contract; therefore, begin due-diligence process.

No due diligence required; instead follow vendor/customer process.