Anti-Bribery and Anti-Corruption Policy

The Anti-Bribery and Anti-Corruption Policy is a document that outlines the company's strict prohibition of any form of bribery or corruption, whether direct or indirect. The policy applies to all employees, officers, and directors of the company and its subsidiaries. The document begins with a general purpose section, which defines bribery as an inducement or reward offered to gain any advantage and corruption as the abuse of a position of employment or authority. The purpose of the policy is to ensure compliance with applicable laws, to guide employees and anyone acting on behalf of the company in adhering to the policy, and to establish the responsibilities of all individuals in upholding the company's position on bribery and corruption. The scope of the policy covers all staff members, both permanent and temporary.

 

The policy then outlines the principles of anti-bribery and corruption, stating that it is prohibited for staff members to engage in or permit a bribery offense, accept payments or gifts with the expectation of a business advantage, or engage in any activity that might lead to a breach of the policy. The document also provides guidelines for giving and accepting gifts and entertainment, emphasizing that they should be occasional, reasonable, transparent, and not in violation of the policy.

 

The responsibilities of staff members are clearly defined, including the completion of mandatory anti-bribery and corruption training, reporting any known or suspected bribery or corruption, ensuring the inclusion of anti-bribery and corruption legal clauses in contracts, engaging with third parties who have established policies on ethical business practices, maintaining accurate records of gifts and hospitality, and submitting expenses claims in accordance with the company's policy.

 

The document explains the procedure for handling corruption cases, which involves the establishment of an anti-corruption committee responsible for accepting and investigating reports, conducting trainings, and ensuring policy implementation and compliance. It also states that any violation of the policy may result in disciplinary action, including dismissal or termination of employment. The policy can be revised or modified by the company at any time, and the legal department is the authority for interpreting its content.

 

For further information or guidance, individuals are advised to contact the legal department representative.

How to use this document?

1. Complete mandatory anti-bribery and corruption training as required by the company.

2. Report any known or suspected bribery or corruption to the provided email address.

3. Ensure that the company's standard anti-bribery and corruption legal clauses are incorporated into any contracts entered with counter parties.

4. Engage with third parties who have established policies on ethical business practices.

5. Maintain accurate records of all documentation related to the giving or receiving of gifts and hospitality.

6. Submit expenses claims for gifts, hospitality, entertainment, or expenses incurred by or to third parties in accordance with the company's expenses policy.

7. Familiarize yourself with the procedure for handling corruption cases, including reporting to the anti-corruption committee.

8. Cooperate with any investigations conducted by the committee.

9. Attend anti-corruption related trainings provided by the committee.

10. Adhere to the policy and avoid any activities that may lead to a breach.

11. Contact the legal department representative for any questions or further guidance.

12. Stay updated on any revisions or modifications to the policy, as determined by the company's discretion.