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Indicator 1.3.1
by Contact on 8 October 2026
Requirement
The UoC shall discourage all forms of corruption and shall encourage ethical behaviour and integrity in their business operations.
How Do I Interpret This Requirement?
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Corruption can:
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Happen anywhere;
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Involve anyone;
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Take many forms. For example:
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extortion
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embezzlement
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bribery
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Examples of corruption are:
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A manager buys supplies from a friend and in return, the friend gives 20% of the profits to the manager. This may go as far as the manager excluding other appropriate suppliers from the system of approved suppliers.
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A piece of infrastructure has an unsafe mechanism and the owner pays the manager cash to not disclose this at the next audit.
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Examples of extortion are:
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Employee A threatens to provide information to the manager which could get Employee B into trouble or fired, unless Employee A is paid a requested amount of money.
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A site owner threatens to hurt the owner of the neighbouring plot of land unless the land-owner agrees to give up some of his land so that the site can build an additional building.
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Examples of embezzlement are:
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A site manager getting cash from the first point of sale in exchange for under-declaring harvest volumes (i.e. the purchaser receiving more product that they are paying for).
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A sourcing manager purchases cheaper non-eligible feed but registers them as eligible and provides documentation falsely declaring it as more costly eligible feed, as financial sourcing performance increases the sourcing manager’s bonus.
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Examples of bribery are:
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A supplier buys a new car for a site manager, in exchange for the site manager giving the sourcing contract to that supplier.
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A site pays cash to customs officials to speed up the passage of their feed through the import and export system.
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A sustainability manager offers auditors excessive accommodation and lunches to reduce the audit effort or to turn a blind eye to non-conformities.
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Evidence of Implementation
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Policies preventing corruption, including extortion, embezzlement and bribery.
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Terms of dismissal should employees engage in these practices.
Auditors Should Confirm
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Management and employees are aware of:
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what these practices involve and how to recognise them.
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the policies in place for preventing corruption, including extortion, embezzlement and bribery.
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Useful Resources
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Transparency International: <https://www.transparency.org/en>
