Preventing Corruption & Fraud

ICL is committed to preventing bribery, corruption, and fraud in all aspects of its business and operations. For this purpose, it has established two global programs following internationally recognized best practices: The Anti-Bribery and Corruption Program, and the Fraud Risk Management Program. \

ICL’s Anti-Bribery and Corruption (ABC) Program

ICL is committed to zero tolerance for bribery. Our ABC program provides employees with detailed guidance and examples of how to recognize and avoid bribery in common business situations.

In 2022 the ABC risk assessment was updated and enhanced by creating a detailed risk map by entities and location. Higher risk entities and locations will receive enhanced training and monitoring.

Third Party Due Diligence

ICL’s Third Party Due Diligence Policy and Procedure ensures that external business partners that present ABC risk to ICL undergo background checks, agree in writing to comply with ICL’s Code of Conduct 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. All parties reviewed are continuously monitored against global databases of restricted parties, politically exposed persons, and adverse media reports.

The Third-Party Due Diligence review requirement extends to all suppliers who interact with government agencies and officials in the course of providing services to ICL. Additional suppliers are required to sign ICL’s Supplier Code of Conduct, and through the Together for Sustainability (TfS) initiative, ICL’s largest volume suppliers are reviewed for their adherence to ABC legal requirements and best practices. For information on supplier due diligence see “Sustainable Procurement.”

Sales agents, distributors, traders, resellers, and other intermediaries that represent ICL to end-user customers in the marketplace are also subject to the review requirements. All such intermediaries go through a background check and continuous monitoring. Intermediaries selling in higher risk locations and/or with high resale volumes, as well as all external parties receiving sales commissions, are subject to a more extensive review.

Gifts & Entertainment

ICL’s Gift and Entertainment Policy requires all employees to obtain prior approval for gifts and entertainment for higher value items and those which involve government officials. The Gift and 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.

Community Relations & Donations

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 online and face to face training to all new employees in management, finance and accounting, sales, customer service, and procurement. Existing employees receive periodic refresher training.

Additional ABC Controls

Controls have been established to ensure that unapproved parties that are 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:

Restricted party screening as part of the Trade Compliance Program which ensures that all vendors and customers are screened against government issued lists of parties sanctioned for illegal activity, including terrorism, drug trafficking, and bribery
Anti-money laundering controls prevent payments from being made in cash, and require review of all payments made to or received from countries other than the country where the counterparty is located or does business
Conflict of Interest management procedures require employees to disclose any relationships with customers and suppliers, and management level employees are required to certify they have disclosed all such relationships
ICL does not make contributions, financial or otherwise, to politicians or political organizations

Adherence to the ABC policies, procedures and controls is monitored through reviewing expense reports for unapproved gift and entertainment spending, reviewing sales commission payments to ensure that only approved parties have been paid, and other periodic reviews performed in an annual cycle. ICL also pursues unauthorized spending through audits, and incorporates lessons learned from both audits and monitoring of relevant policies, procedures, and programs

ICL's Fraud Risk Management 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 ICL’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 departments in preventing, detecting and investigating fraud.

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 digital communication. Employees throughout ICL are trained on how to identify and report phishing attempts through live and online based training events, as well as targeted phishing drills. Global procedures and controls have been implemented to address the risk of social engineering fraud, including enhanced controls on vendor setup and bank account changes, and a global minimum standard of required information for onboarding new customers.

Implementation of the controls is monitored systematically by spot checking transactions for compliance, following a risk-based monitoring plan.

Procedure for Authorized Signatories on the Company’s Accounts

ICL has an established procedure for signatory rights and authorization. According to company policy, two defined authorized signatories are required to legally bind ICL in any contractual obligation or legal action.

Competition - Being A Fair Partner

We are committed to the principles of fair competition and compliance with all antitrust and competition laws applicable to our operations around the world. Anti-competitive behaviors with competitors or customers and other third parties are prohibited, including price fixing, agreements to limit production, exchanging competitive information and predatory pricing. Our Competition Compliance Program outlines ICL’s strict expectations of all employees, officers, and directors, as well as third parties such as distributors, agents, resellers and contractors.

In 2022, the Compliance Department performed a Global Risk Assessment for Anti-bribery and Corruption, Global Trade and Competition Law.

The Risk Assessment was conducted to identify and determine the level of exposure to certain compliance risks.

With a 100% response rate, the Risk Assessment yielded clear risk profiles for the respective compliance programs per ICL site. The data also yielded valuable insights from a structural perspective.

Sustainability Reporting Disclosures:

Disclosure: 2-15

Disclosure: 103-1

Disclosure: 103-2

Disclosure: 205-2

Disclosure: 415-1