The purpose of this Policy is to ensure compliance by Wärtsilä Corporation and its subsidiaries worldwide (jointly "Wärtsilä”) with the anti-corruption laws of all the countries in which the Company does or intends to do business.
No Wärtsilä employee or company is allowed, either directly or indirectly, to promise, offer, pay, solicit or accept bribes or kickbacks of any kind.
Bribe means
Bribes can include money, gifts, hospitality, expenses, reciprocal favours, political or charitable contributions, or any direct or indirect benefit or consideration.
Corruption means the abuse of power or position for money or other personal gain. Corruption benefits a few individuals but does a lot of damage to the public good.
Facilitation Payments mean payments that are requested by Government Officials to speed up or perform a routine government action such as:
Government Officials mean officials of any government department or agency; officials of any public international organisation; political party leaders and officials; candidates for public office; executives and employees of government-owned or government-run companies; anyone acting on behalf of any of these officials; an individual holding a legislative, administrative or judicial position.
Wärtsilä and all its employees are responsible for complying with this Policy and anti corruption laws as well as the ethical and business standards outlined in the Wärtsilä Code of Conduct.
Each Wärtsilä Business must comply with this Anti-Corruption Policy, which replaces all earlier Policies on the same subject matter. The head of each Wärtsilä Business is responsible for arranging the compliance of this Policy in their respective Business and in their respective organizations.
All managers are expected to monitor continued compliance with the anti-corruption policy and local laws to ensure compliance with the highest moral, ethical, and professional standards.
Wärtsilä expects that its business partners are committed to anti-corruption compliance and maintain the highest level of anti-corruption practices.
This policy applies equally to the private as well as the public sector.
It is forbidden to pay or receive a Bribe whether paid or received directly or indirectly. There is no need for the Bribe to be successful to be viewed as corrupt; the offering of it is enough to amount to a criminal offence.
At Wärtsilä, Bribes and Corruption are forbidden anywhere in the world regardless of local custom.
Particular care must be taken to be transparent in all dealings with Government officials (at whatever level) to ensure that there is no actual or perceived conflict of interest or undue influence. Interactions with Government officials may be high risk for corruption and perception of corruption. Employees must ensure that all contacts with Government officials are known to the Business Line Managers.
As a matter of Wärtsilä Policy, it is forbidden to make a Facilitation Payment even though in some countries Facilitation Payments may be legal.
Generally, giving of gifts is discouraged at Wärtsilä.
However, corporate hospitality, including meals and entertainment, and appropriate business gifts may, at times, build goodwill in business relationships.
When providing or receiving hospitality or giving or receiving gifts one should consider whether it is appropriate, reasonable and justified under the circumstances. If corporate hospitality or gifts can be seen as Bribes, it will be unlawful and harm Wärtsilä’s reputation. It can also lead to criminal prosecution for those individuals involved as well
as Wärtsilä. You must not offer or receive gifts and hospitality that could improperly influence, or be perceived to improperly influence, obtaining business or other commercial advantage.
Generally, Wärtsilä employees may offer and provide or accept corporate hospitality or gifts provided the following principles are followed:
A good test for acceptable gifts and hospitality is to consider whether the employees offering or accepting hospitality or gifts would be comfortable to discuss the case with the company or corporate management or in the public and this would not cause any embarrassment to Wärtsilä.
Additional caution is expected if gifts and hospitality are offered or given to Government Officials. An increased risk that any provision of gifts, hospitality and business entertainment to a Government Official could be construed as a Bribe.
Giving or accepting a gift in cash, regardless of the value, is prohibited.
The Wärtsilä companies cannot make political contributions to political parties, party officials and candidates unless Group Vice President, Corporate Relations and Legal has approved such contribution in advance in writing. Political contributions must always be made in accordance with applicable laws. If a political contribution is allowed to be made, our policy is to take appropriate steps to publicly disclose the contribution unless secrecy or confidentiality is required. The Director, Compliance shall be informed and keep record of the political contributions made.
Charitable donations must not be made to improperly influence the recipient or in exchange for any business or other commercial advantage. Moreover, charitable donations and sponsoring cannot be used to circumvent the prohibition for Corruption or Bribes.
Particular attention to anti-corruption compliance must be paid when using third parties
in business transactions.
To avoid being held liable for corrupt third-party payments, Wärtsilä and any person acting on its behalf must exercise due diligence at all times and take all necessary precautions to ensure that business relationships are formed only with reputable and qualified partners, agents, and representatives.
It is the company policy to require potential brokers, agents, or other sales intermediaries to go through a prequalification process and if prequalified, to sign a written agreement which includes a prohibition of illicit payments, like those related to bribery, money laundering and extortion. Please see the Wärtsilä Agent Policy, Broker Policy and Distributor Policy for further instructions.
A conflict of interest can occur when an employee’s situation or circumstance, either personal or business related, impacts their ability to apply judgment and act in the best interest of Wärtsilä. The perception of competing interests, impaired judgment or undue influence can also be a conflict of interest.
Employees must not act in respect of any transaction, contract, decision making process or similar where it is possible that a conflict of interest may arise before the conflict has been disclosed and clearance obtained in accordance with the Wärtsilä Conflicts of Interest Guide.
Wärtsilä views corruption and bribery very seriously and therefore encourages its employees to voice their concerns as to potential violations of this Policy.
Wärtsilä will investigate reported matters regarding corruption and bribery. A breach of this Policy may result in an employee facing disciplinary action, including termination of employment. Where a case is referred to law enforcement authorities, Wärtsilä will co-operate fully with the investigation.
Directions for reporting violations of this Policy and their investigation, please see
Wärtsilä’s Compliance Reporting Policy.
Wärtsilä provides anti-corruption training, as appropriate.
Revised on September 1st, 2025.