Anti-corruption and Anti-bribery policy

Size: px
Start display at page:

Download "Anti-corruption and Anti-bribery policy"

Transcription

1 Declaration of the strategic position with respect to anticorruption and anti-bribery practices Anti-corruption and Anti-bribery policy January, 2015

2 Table of Contents Justification Purpose Scope Glossary Guiding principles Consistency Commitment to prevention Responsibility Duty to denounce Transparency and Legality Governance and responsibilities Board of Directors Audit committee Ethics committee General Management or Presidency Auditing Vice-presidency Employees Effective date... 9

3 Justification Millicom Group s business philosophy and its growth strategy for various markets around the world require it to have corporate governance and management schemes of the highest international standards in addition to total compliance with the local and international regulatory frameworks. For these reasons, the Groups has adopted, as part of its business principles and practices, policies aimed at structuring its operation within a framework of ethics and transparency that guarantees the continuity and sustainability of the business. In addition, the aim is to safeguard the organization s reputation and to contribute to and have a positive impact on the communities where the Group operates and so others stakeholders. We understand that the way to do business is as important or more important than the business itself and it is for this reason that we place institutional principles and values above the achievement of corporate objectives and reject and sanction organizational achievements that are obtained through the violation of the values or the law.

4 1. Purpose This anti-corruption policy is intended to make a public statement of its commitment to ethical and transparent actions vis-à-vis its stakeholders, and to carry out its business in a socially responsible manner, acting on a philosophy of zero tolerance for actions that violate its organizational principles. 2. Scope This policy is applicable to all employees of the company, in every region where it operates, and to all related parties and stakeholders, i.e., clients, suppliers, shareholders, investors, collaborators, contractors, sub-contractors and, in general, to everyone with whom, directly or indirectly, the company establishes any type o commercial, cooperation or contractual relationship. 3. Glossary Corruption is defined as any act, attempt or deliberate omission to obtain a benefit for oneself or for third parties to the detriment of the organizational principles, regardless of the financial effects on the companies. Bribery consists of offering, promising, giving, accepting or soliciting a consideration, whether economic or not, in order to obtain a commercial, contractual, regulatory or personal advantage. Bribery and corruption are criminal offenses that affect those who participate both actively and passively in the commission of such acts, affecting the reputation of

5 the companies they represent with heavy fines, exclusion from participation in public bids, and inclusion in international restrictive lists that affect the companies internationalization strategy (for example the UN and OFAC lists). Facilitation payments are a form of bribery intended to expedite or facilitate the actions of a public official for a routine government act. These facilitation payments are usually demanded by low level employees in exchange for an exceptional level of service and, in this respect, they can be considered an act of corruption. As a general principle, Tigo Une and its companies do not accept, promote, justify, or cover up this type of operations and declare their firm commitment to performing their business in a transparent manner without resorting to this type of practices. 4. Guiding principles The center of this policy are its guiding principles that consist of the declarations, that in accordance to the principles of the code of ethics, the code of conduct for suppliers, the institutional values, and the good governance practices, express the guidelines to be applied in all companies and regions where there are direct or indirect operations. The application of these principles will not be discretionary for its employees or managers in any of the regions where the Group operate, and it will not be subject to interpretations to give or attempt to give the appearance of legitimacy to acts or situation about which there are clear reasonable doubts with respect to their appropriateness or legality. In case of doubt about their interpretation, the government agencies are to be consulted about the policies described below. The guiding principles are as follows:

6 4.1. Consistency Every employee, regardless of their seniority or hierarchical position in the Organization, is a referent for acting according to the institutional principles and practices, and will set an example through our behavior. No employee may, either directly or indirectly, participate, hide or sponsor act of corruption or bribery for public or private foreign or domestic entities Commitment to prevention This involves a dynamic supervision and follow-up model of the risks of corruption and bribery. To this end, the risk maps of the processes will be constantly evaluated to ensure that the management measures are providing reasonable protection for the companies against corrupt practices. This activity is to be carried out following risk management practices, with an emphasis on preventive measures and mechanisms rather than on detection or correction systems Responsibility Every reported or detected fact that has any kind or relation to corrupt practices of bribery with either private or public entities, will be carefully investigated, documented and analyzed by the competent bodies. Any event that actually turns out to be an act of corruption or bribery will be sanctioned, regardless of the amount, characteristics or hierarchical position of the party or parties responsible, always proportionately to the facts and with the guarantee of a due process. Management s response to this type of situation will involve administrative, commercial, civil and criminal sanctions, if required. These actions will mean not

7 only notifying the respective authorities about the acts of corruption, but also assistance with the process by those legally responsible parties in the companies Duty to denounce Every employee of the company and related third parties, especially those with which there are commercial or contractual relations, is obligated to report to Management all acts or circumstances that might be considered corruption or bribery. The various institutional channels available at the company, such as the immediate superior, the vice-president or Director of the respective area, the manager of auditing, the audit committee, the ethics committee, the general managers of the companies, and specially the ethical line. Additionally there will be the guarantee that no one will suffer harmful treatment or retaliation or questioning as a result of their refusal to participate in the bribery or corruption, or as a consequence of submitting reports in which he or she, in good faith, expresses suspicions that an actual or potential bribe or other corruption crime has taken place or might take place in the future. Such denunciations may be made known to the company protected by the principles of confidentiality and/or anonymity Transparency and Legality Any act of circumstance that is detected and verified will be reported according to the information protocols established with the various stakeholders, always respecting the official spokespersons of the companies for these matters and guaranteeing transparency, legality and information balance.

8 5. Governance and responsibilities 5.1. Board of Directors The Board of Directors, as the highest body for Corporate Governance and Control, shall define the anti-corruption policy for the company and will keep it upto-date according to the regular reviews resulting from recommendations made by management, Auditing or the Audit committee Audit committee The audit committee will be responsible for supervising the implementation and adoption in the companies of the anti-corruption and anti-bribery practices and principles by means of the evaluations carried out through the company s manager of Auditing Improvement plans resulting from the deviation identified during the evaluations performed by Internal or External Audits will be carefully supervised by this committee to ensure that such measures are effective and help prevent the risk both by reducing the probability of occurrence and the severity of the events Ethics committee The Ethics Committee will be responsible for handling any denunciation of corruption or bribery that are brought to its attention, and will order the appropriate investigations to identify the sources that allowed the risks to take place, and provide feedback to the owners of the processes about those vulnerabilities. The Ethics Committee will provide regular reports of its activities to the Audit Committee through the manager of Auditing or the committee s technical secretary.

9 5.4. General Management or Presidency The company s President or General Manager, as case might be, will be responsible for implementing the policy in the company, encouraging, motivating and facilitation its inclusion in the company s management model. The President or General Manager will implement any cultural transformation programs required for this policy will become, rather than just an internal regulation, a part of the institutional culture and philosophy Auditing Manager This auditing manager will be responsible for carrying out the evaluations about the compliance with the policy and its correct implementation, for identifying any issues that could be preventing compliance, and for proposing any measures or updates that it considers appropriate to the company s Audit Committee that might lead to a stronger policy Employees They will be responsible for uncompromising application of the anti-corruption and anti-bribery policy. They will also act according to the guiding principles of the policy described above, and ensure that each governance body acts according to its responsibilities. 6. Effective date This policy will be effective as of the date it is publishes. Its principles and guidelines must be applied as they have been established, and all employees and related third parties are obliged to comply with them, and any deliberate or intentional failure to comply will be considered as a serious fault.

10 As of this date, the companies on-boarding process for both employees and third parties will include a specific training and communications module on the scope and application of this policy.

Samsung Engineering Co., Ltd.

Samsung Engineering Co., Ltd. Introduction to Our Compliance Program Samsung Engineering Co., Ltd. 500 Samsung GEC, Sangil-dong, Gangdong-gu, Seoul, Korea 134-090 +82-2-2053-3000 www.samsungengineering.com 03 Since its establishment

More information

ANTI-BRIBERY AND CORRUPTION POLICY

ANTI-BRIBERY AND CORRUPTION POLICY ANTI-BRIBERY AND CORRUPTION POLICY OBJECTIVES Woodside is committed to conducting its business and activities with integrity. To achieve this objective: Woodside will not engage in corrupt business practices;

More information

ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of

More information

APEC General Elements of Effective Voluntary Corporate Compliance Programs

APEC General Elements of Effective Voluntary Corporate Compliance Programs 2014/CSOM/041 Agenda Item: 3 APEC General Elements of Effective Voluntary Corporate Compliance Programs Purpose: Consideration Submitted by: United States Concluding Senior Officials Meeting Beijing, China

More information

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...

More information

MATTHEWS INTERNATIONAL CORPORATION

MATTHEWS INTERNATIONAL CORPORATION MATTHEWS INTERNATIONAL CORPORATION U.S. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY INTRODUCTION Principles Underlying the United States Foreign Corrupt Practices Act ( FCPA ). The FCPA s Anti-Bribery

More information

Corporate Anti-Bribery Policy

Corporate Anti-Bribery Policy Corporate Anti-Bribery Policy 1 Anti-Bribery Policy statement Bribery is both a criminal offence and bad business. Not only can individuals be guilty of an offence but a company can be prosecuted if it

More information

LAUREATE ANTI-CORRUPTION POLICY

LAUREATE ANTI-CORRUPTION POLICY LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery

More information

APEC Anti-corruption Code of Conduct for Business

APEC Anti-corruption Code of Conduct for Business APEC Anti-corruption Code of Conduct for Business Business Integrity and Transparency Principles for the Private Sector 1. Prohibition Of Bribery The enterprise shall prohibit bribery in any form. Bribery

More information

ANTI-BRIBERY POLICY. Introduction

ANTI-BRIBERY POLICY. Introduction ANTI-BRIBERY POLICY Introduction The trust that Royal Mail enjoys from its customers is one of its key assets. We all need to work to make sure that we do everything we can to protect that asset that has

More information

BBC. Anti-Bribery Policy. June 2011

BBC. Anti-Bribery Policy. June 2011 BBC Anti-Bribery Policy June 2011 CONTENTS CLAUSE 1. Anti-Bribery Policy statement... 1 2. Who is covered by the policy?... 2 3. What is bribery?... 2 4. Gifts and hospitality... 3 5. Gifts and hospitality

More information

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,

More information

Complying with the U.S. Foreign Corrupt Practices Act

Complying with the U.S. Foreign Corrupt Practices Act Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption

More information

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011 SEMGROUP CORPORATION Anti-Corruption Compliance Policy August, 2011 SCOPE This is a global policy (the Policy ) applicable to the worldwide operations of SemGroup Corporation ("SemGroup") and all of its

More information

Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy Newcrest strictly prohibits bribery and other unlawful or improper payments made to any individual or entity, as outlined in this Anti-Bribery & Corruption Policy. Newcrest's Anti- Bribery & Corruption

More information

EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY. (As Adopted July 2011)

EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY. (As Adopted July 2011) EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY (As Adopted July 2011) Introduction This UK Anti-Bribery and Corruption Policy ( Policy ) is

More information

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,

More information

Consumers International Anti-Corruption and Bribery Policy

Consumers International Anti-Corruption and Bribery Policy Consumers International Anti-Corruption and Bribery Policy Date of policy: October 2015 Policy approved by: Council Person responsible for policy: The Treasurer s Committee has overall responsibility.

More information

1. Understanding and application of Moelven's Code of Conduct

1. Understanding and application of Moelven's Code of Conduct Code of Conduct 1. Understanding and application of Moelven's Code of Conduct Purpose Moelven must act in a sustainable, ethical and socially responsible manner. Our Code of Conduct provides the basic

More information

Bribery Policy. Policy description:

Bribery Policy. Policy description: Bribery Policy Policy description: This purpose of this document is to set out the College policy in relation to Bribery. The policy also outlines the College s approach to gifts received by the College

More information

DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)

DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011) DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply

More information

CODE OF CONDUCT Ethical rules and guidelines

CODE OF CONDUCT Ethical rules and guidelines CODE OF CONDUCT Ethical rules and guidelines CONTENT Introduction... 3 Our customers... 5 Employees... 7 The world around us... 9 Communication & dialog... 11 Security, theft & loss... 13 Environment...

More information

ICC Guidelines on Whistleblowing

ICC Guidelines on Whistleblowing ICC Guidelines on Whistleblowing Prepared by the ICC Commission on Anti-Corruption A. Introduction 1. No abatement of corruption and economic fraud Fraud remains one of the most problematic issues for

More information

LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy

LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy 1. Introduction. Applicability. This Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy (this Policy

More information

Administrative Policy No. AD 2.26 Title:

Administrative Policy No. AD 2.26 Title: I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates

More information

Global Anti Bribery and Corruption Policy

Global Anti Bribery and Corruption Policy GRC 004 Global Anti Bribery and Corruption Policy Page 1 of 7 Contents 1. Purpose... 3 2. Scope... 3 3. Policy... 3 4. Bribery... 3 5. Gifts and Hospitality... 4 6. What is not acceptable?... 4 7. Facilitation

More information

PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS

PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS Philippine Long Distance Telephone Company ( PLDT or the Company ) is dedicated to doing business in accordance with the highest

More information

15 December 2015. Crime Prevention and Anti-Fraud Policy

15 December 2015. Crime Prevention and Anti-Fraud Policy 15 December 2015 Crime Prevention and Anti-Fraud Policy Content 1. Purpose 3 2. Scope 3 3. Action Principles 3 4. Control, Evaluation, and Revision 4 Look after the Environment. Print in black and white,

More information

CARDINAL RESOURCES LLC INTRODUCTION

CARDINAL RESOURCES LLC INTRODUCTION CARDINAL RESOURCES LLC ANTI- BRIBERY AND ANTI- CORRUPTION POLICY INTRODUCTION The purpose of this Anti- bribery and Anti- corruption Policy (the "Policy") is to ensure compliance by the Red Bird Group

More information

Corporate Code of Conduct

Corporate Code of Conduct Corporate Code of Conduct Statement of Policy. It is the policy of Casa Mining Limited (the "Company") that all of its officers, directors, employees, contractors, consultants and agents representing the

More information

Foreign Corrupt Practices Act Summary and Policy

Foreign Corrupt Practices Act Summary and Policy I. Introduction/Overview Foreign Corrupt Practices Act Summary and Policy It is the policy of Cantel Medical Corp. and its subsidiaries (the Company ) to comply with all applicable laws, rules and regulations,

More information

FLUOR HUMAN RESOURCES POLICY POLICY/PROCEDURE

FLUOR HUMAN RESOURCES POLICY POLICY/PROCEDURE Page 1 of 5 HR-720 Supersedes: 09-21-06 I. POLICY A. Fluor s employees, officers, directors, and any agents, subsidiaries, joint ventures, consortiums, consultants, brokers, or other individuals, intermediaries,

More information

Intercontinental Exchange, Inc. Global Anti-Bribery Policy

Intercontinental Exchange, Inc. Global Anti-Bribery Policy Intercontinental Exchange, Inc. Global Anti-Bribery Policy 20140923 1. Policy Intercontinental Exchange, Inc. (ICE), and all subsidiaries and entities controlled by it (collectively, the Company ), is

More information

ERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011

ERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 ERIN ENERGY CORPORATION ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 Statement of Policy It is the policy of Erin Energy Corporation, (the Company ) to conduct its worldwide operations ethically

More information

Anti-Corruption and FCPA Compliance Policy

Anti-Corruption and FCPA Compliance Policy Anti-Corruption and FCPA Compliance Policy Purpose and Scope Vicor Corporation ( Vicor or the Company ) must comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA") and all

More information

Park-Ohio Holdings Corp. Foreign Corrupt Practices Act Policy

Park-Ohio Holdings Corp. Foreign Corrupt Practices Act Policy Park-Ohio Holdings Corp. Foreign Corrupt Practices Act Policy I. Policy Park-Ohio Holdings Corp. ( Park Holdings or the Company ) is committed to conducting all operations and activities, including those

More information

BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL

BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL Transparency International is the global civil society organisation leading the fight against

More information

Message from the Chief Executive

Message from the Chief Executive Anti-Bribery Policy Message from the Chief Executive At Marks & Spencer we are committed to doing the right thing, the right way. Our Code of Ethics and Behaviours outlines the standards and behaviours

More information

AS Merko Ehitus CODE OF BUSINESS ETHICS

AS Merko Ehitus CODE OF BUSINESS ETHICS AS Merko Ehitus CODE OF BUSINESS ETHICS AS Merko Ehitus 1 Introduction The purpose of the Code of Business Ethics, which is described in this document, is to provide guidance to employees, directors and

More information

CC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010

CC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010 CC255 Altus FCPA Policy Last revised: 12 October 2010 C O R P O R A T E Foreign Corrupt Practices Act Policy Purpose The purpose of this Policy is to ensure compliance by Altus and its directors, officers,

More information

Standards of. Conduct. Important Phone Number for Reporting Violations

Standards of. Conduct. Important Phone Number for Reporting Violations Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,

More information

Anti-corruption Policy

Anti-corruption Policy Anti-corruption Policy 1. PURPOSE This policy purpose aims at the guidelines for performance and conduct of Employees, Managers and Third Parties before national and international government agencies in

More information

Foreign Corrupt Practices Act Compliance

Foreign Corrupt Practices Act Compliance Document ID: LGL-D010 Rev 0 February 11, 2010 Page 1 of 6 Applies to: Aerojet Document Owners: Vice President, General Counsel and Executive Director, Contracts, Ethics & Compliance Purpose Background

More information

Our vision. A company where the best people want to work.

Our vision. A company where the best people want to work. Code of Conduct Our vision A company where the best people want to work. The world leader in chemical distribution, providing unparalleled connectivity between customers and suppliers. 2 Univar s guiding

More information

MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY

MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY THIS POLICY HAS BEEN APPROVED BY THE BOARD OF DIRECTORS OF MUELLER INDUSTRIES, INC. ON FEBRUARY 11, 2010 AND IS APPLICABLE TO ALL DIRECTORS, OFFICERS, EMPLOYEES,

More information

EADS-NA Code of Ethics

EADS-NA Code of Ethics Page: 1 of 7 EADS-NA Code of Ethics Introduction The Company demands high ethical standards of conduct from its directors, employees, and agents and will conduct its business with honesty, integrity, and

More information

Worldwide Anti-Corruption Policy

Worldwide Anti-Corruption Policy Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton

More information

Corporate Code of Ethics

Corporate Code of Ethics FERROVIAL CORPORATE CODE OF ETHICS Corporate Code of Ethics Our complete commitment to the ethics and integrity of our workforce highlights us as a serious company committed to its stakeholders interests.

More information

DRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions

DRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions DRAFT Change History: Anti-Bribery and Anti-Corruption Policy Control Risks Group Ltd Commercial in confidence Introduction This document defines Control Risks policy on the avoidance of bribery and corruption.

More information

Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT

Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT Summit ESP, LLC and any related companies (collectively Summit ) will conduct its business transactions

More information

Supplier Anti-Corruption and Anti- Bribery Policy

Supplier Anti-Corruption and Anti- Bribery Policy Supplier Anti-Corruption and Anti- Bribery Policy 2014 Dwellworks Contents Purpose and Scope... 3 Core Principles... 4 Guidelines for Anti-Corruption and Anti-Bribery Compliance... 5 Applicable Definitions...

More information

STATEMENT FROM THE CHAIRMAN

STATEMENT FROM THE CHAIRMAN STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions

More information

Regulation for Compliance with Anti-Corruption Acts

Regulation for Compliance with Anti-Corruption Acts Regulation for Compliance with Anti-Corruption Acts 2014. 2. 24. Samsung Techwin Co., Ltd. Table of Contents Chapter 1 Article 1 Article 2 Article 3 General Rules Purpose Applicability Definition Chapter

More information

Anti-Bribery and Corruption Policy (including Gifts and Hospitality)

Anti-Bribery and Corruption Policy (including Gifts and Hospitality) Anti-Bribery and Corruption Policy (including Gifts and Hospitality) Royal Mail Group has a strict zero tolerance policy towards bribery and corruption. This policy sets out the standards of behaviour

More information

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries

More information

Compliance Management System

Compliance Management System Compliance Management System Compliance Management System Content 1 Opening Remarks from Management Board... 1 2 Introduction... 2 3 Elements of the Compliance Management System (CMS)... 3 4 Goals and

More information

Minerals Technologies Inc. Summary of Policies on Business Conduct

Minerals Technologies Inc. Summary of Policies on Business Conduct Minerals Technologies Inc. Summary of Policies on Business Conduct Lawful and Ethical Behavior is Required at All Times This Summary of Policies on Business Conduct (this "Summary") provides an overview

More information

BARRICK GOLD CORPORATION

BARRICK GOLD CORPORATION BARRICK GOLD CORPORATION Code of Business Conduct and Ethics Introduction Barrick s success is built on a foundation of personal and professional integrity and commitment to excellence. As a company and

More information

CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY (2015)

CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY (2015) CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY (2015) Provides a comprehensive strategic framework for institutional integrity (fraud and corruption), ethics,

More information

Code of Conduct Code of Conduct for Business Ethics and Compliance

Code of Conduct Code of Conduct for Business Ethics and Compliance Allianz Group Code of Conduct Code of Conduct for Business Ethics and Compliance Group Compliance Preamble Allianz Group is based upon the trust which our clients, shareholders, employees and public opinion

More information

PETROBRAS CORRUPTION PREVENTION PROGRAM MANUAL

PETROBRAS CORRUPTION PREVENTION PROGRAM MANUAL PETROBRAS CORRUPTION PREVENTION PROGRAM MANUAL PETROBRAS CORRUPTION PREVENTION PROGRAM MANUAL MESSAGE FROM PETROBRAS Petrobras arose as a result of Brazil s capacity to use its strategic natural resources

More information

WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES

WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES WOLTERS KLUWER COMPANY VALUES AND BUSINESS PRINCIPLES Mission statement and introduction Wolters Kluwer s customers face critical decisions every day; and the need to get them right. That is why Wolters

More information

CODE OF ETHICS ZERO TOLERANCE - BRIBERY AND CORRUPTION ADVANTAGE

CODE OF ETHICS ZERO TOLERANCE - BRIBERY AND CORRUPTION ADVANTAGE 5682340-v1 This Code of Ethics is mandatory for H&M employees, in house working consultants, in house working staff from Temporary Agencies and similar assignments. INTRODUCTION H & M Hennes & Mauritz

More information

Procedure for Managing a Privacy Breach

Procedure for Managing a Privacy Breach Procedure for Managing a Privacy Breach (From the Privacy Policy and Procedures available at: http://www.mun.ca/policy/site/view/index.php?privacy ) A privacy breach occurs when there is unauthorized access

More information

Evergreen Solar, Inc. Code of Business Conduct and Ethics

Evergreen Solar, Inc. Code of Business Conduct and Ethics Evergreen Solar, Inc. Code of Business Conduct and Ethics A MESSAGE FROM THE BOARD At Evergreen Solar, Inc. (the Company or Evergreen Solar ), we believe that conducting business ethically is critical

More information

Code of Ethics and Business Conduct (CEBC)

Code of Ethics and Business Conduct (CEBC) Code of Ethics and Business Conduct (CEBC) Amadeus Group October 2015 Index _ Preamble... 3 _ Our People... 3 _ Beyond Compliance... 3 _ Commitment to the Environment... 3 _ Conflicts of Interests, Gifts,

More information

Nyrstar Group Policy: Anti-Corruption. Revision 1. Review Date September 2013. Page 1 of 6

Nyrstar Group Policy: Anti-Corruption. Revision 1. Review Date September 2013. Page 1 of 6 Nyrstar Group Policy: Anti-Corruption Document No. (English) Revision 1 Review Date September 2013 Page 1 of 6 Contents 1 CONTEXT 3 2 SCOPE 3 3 REFERENCES AND RELATED DOCUMENTS 3 4 DEFINITIONS 3 5 BRIBERY

More information

Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Amgen GLOBAL CORPORATE COMPLIANCE POLICY 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,

More information

Supplier Code of Conduct

Supplier Code of Conduct Delta Air Lines Supplier Code of Conduct Delta Air Lines 3/11/13 [Type the author name] Table of Contents A Legal Compliance 2 B Labor and Human Rights 3 C Health and Safety 3 D Environment 3 E Supplier

More information

The purpose of this policy is to encourage all related parties to report wrongdoings without the risk of subsequent negative consequences.

The purpose of this policy is to encourage all related parties to report wrongdoings without the risk of subsequent negative consequences. MILLICOM INTERNATIONAL CELLULAR S.A WHISTLEBLOWER POLICY Introduction Millicom is committed to the highest possible standards of openness, honesty and accountability. In line with that commitment, we expect

More information

2 We guarantee that concerns raised in line with the procedure detailed below will be handled sensitively and in confidence.

2 We guarantee that concerns raised in line with the procedure detailed below will be handled sensitively and in confidence. Whistleblowing (Public interest disclosure) Policy Introduction 1 The NMC is committed to an environment of openness, transparency and accountability. In doing so we would expect and encourage anyone who

More information

The way we do business.

The way we do business. a b The way we do business. Our Code of Conduct and Ethics. Our Code of Conduct and Ethics In this Code, the Board of Directors and the Group Executive Board set out the principles and practices that define

More information

Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics

Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics Introduction This Code of Business Conduct and Ethics ( Code ) covers a wide range of business practices and procedures. It does not

More information

Code. of Conduct for Suppliers

Code. of Conduct for Suppliers Code of Conduct for Suppliers Code of Conduct for Odebrecht Oil & Gas Suppliers 1 INTRODUCTION The operation in domestic and foreign markets and in different business units, geographical regions and cultural

More information

Wowprime Corporation Ethical Corporate Management Best Practice Principles

Wowprime Corporation Ethical Corporate Management Best Practice Principles Wowprime Corporation Ethical Corporate Management Best Practice Principles Chapter I General Provisions Article 1: Purpose and scope The Ethical Corporate Management Best Practice Principles ("Principles")

More information

Foreign Corrupt Practices Act (FCPA)

Foreign Corrupt Practices Act (FCPA) Compliance Guideline Foreign Corrupt Practices Act (FCPA) Dachser GmbH & Co. KG Introduction The purpose of this guideline is to provide employees of DACHSER GmbH & Co. KG ( DACHSER ) involved in international

More information

CONTRACT MANAGEMENT POLICY

CONTRACT MANAGEMENT POLICY CONTRACT MANAGEMENT POLICY Division I : General provisions 1. Purpose The Town of Kirkland hereby establishes various rules pertaining to contract management with a view to promoting transparency, fairness,

More information

Code of Business Conduct and Ethics THE WOODBRIDGE WAY. integrity honesty respect responsibility

Code of Business Conduct and Ethics THE WOODBRIDGE WAY. integrity honesty respect responsibility Code of Business Conduct and Ethics THE WOODBRIDGE WAY integrity honesty respect responsibility Reissued June 12, 2015 Code of Business Conduct and Ethics THE WOODBRIDGE WAY INTRODUCTION Woodbridge Foam

More information

THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES

THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES 1. INTRODUCTION 1.1 The purpose of this policy is to provide all employees, directors and officers of DRDGOLD Limited, its

More information

1. Compliance with Laws, Rules and Regulations

1. Compliance with Laws, Rules and Regulations CODE OF BUSINESS CONDUCT - EXAMPLE INTRODUCTION This Code of Business Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic

More information

Anti-Corruption Model

Anti-Corruption Model 15 Dicember 2014 1 Todini commitment to fight corruption Todini prohibits its personnel and partners, within the limits of its responsibility, and in general any person working on behalf of the Company

More information

ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. POLICY STATEMENT This Foreign Corrupt Practices Act Compliancy Policy (the Policy ) has been adopted by Elephant Talk

More information

EADS INTERNATIONAL COMPLIANCE PROGRAMME

EADS INTERNATIONAL COMPLIANCE PROGRAMME EADS INTERNATIONAL COMPLIANCE PROGRAMME 1 I. Case Abstract The topics covered by this business case are the several rules and processes implemented by EADS since the year 2000, aiming at ensuring the groups

More information

Ethical Corporate Management Operating Procedures and Conduct Guide

Ethical Corporate Management Operating Procedures and Conduct Guide Ethical Corporate Management Operating Procedures and Conduct Guide Article 1. Goal Based on the principles of fairness, honesty, credibility and transparency in business activities, in order to implement

More information

Corporate Code of Conduct

Corporate Code of Conduct 1. Background Corporate Code of Conduct 1.1. For over a century, the Swire group of companies has been recognised as acting responsibly in the course of achieving its commercial success. Our reputation

More information

Business Ethics Policy

Business Ethics Policy BUSINESS ETHICS POLICY Table of Content Page Content 1 Message from the Chief Executive Officer 2 Business Integrity 3 No Improper Advantage 4 Disclosure of Information 4 Intellectual Property 5 Fair Business,

More information

METHANEX CORPORATE MANUAL

METHANEX CORPORATE MANUAL SUB- 1.0 Scope All directors, officers and employees of Methanex Corporation and its subsidiaries ( Employee(s) ). 2.0 Purpose To provide Methanex Employees with: a) a set of standards meant to assist

More information

ANTI-CORRUPTION COMPLIANCE GUIDELINES

ANTI-CORRUPTION COMPLIANCE GUIDELINES ANTI-CORRUPTION COMPLIANCE GUIDELINES INTRODUCTION These guidelines establish procedures for handling, and should help you identify anti-corruption concerns. If you are ever uncertain or feel uneasy about

More information

FOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD.

FOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD. FOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD. 1.0 Purpose and Scope of this Manual The purpose of this Policy is to ensure compliance by Project Professionals Group Pty.

More information

QUMU CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS POLICY INTRODUCTION

QUMU CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS POLICY INTRODUCTION QUMU CORPORATION CODE OF BUSINESS CONDUCT AND ETHICS POLICY INTRODUCTION Our Commitment The Code Applicability of Code We are committed to conducting our business lawfully and ethically. We promote a culture

More information

Business Ethics Policy

Business Ethics Policy Business Ethics Policy The WCH Ltd Ethics Code The business philosophy of WCH has been developed around a core set of values which are fundamental to the organisation s development and success. One of

More information

GoodWeave International-Certification Division (GWI-CD) Ethics Programme - Anti-Bribery and Anti-Corruption

GoodWeave International-Certification Division (GWI-CD) Ethics Programme - Anti-Bribery and Anti-Corruption GoodWeave International-Certification Division (GWI-CD) Ethics Programme - Anti-Bribery and Anti-Corruption Basis for Programme This programme is inspired by GoodWeave International s values of ethics

More information

HILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide

HILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains

More information

Spirit. The TTS GROUP ASA

Spirit. The TTS GROUP ASA Spirit The of TTS TTS GROUP ASA TTS VISION The global supplier of handling systems to the marine and offshore industry that has the strongest focus on end user satisfaction. 2 CLOSE TO CUSTOMERS Our vision

More information

Personal Account Trading Policy

Personal Account Trading Policy Type: Name: Level: Policy Personal Account Trading Policy Stanbic IBTC Owner: Governance committee Approved by: Chief Compliance Officer Board Risk Management Committee Board Risk Management Committee

More information

ANTI-CORRUPTION POLICY AND PROCEDURES

ANTI-CORRUPTION POLICY AND PROCEDURES ANTI-CORRUPTION POLICY AND PROCEDURES EXECUTIVE SUMMARY The nature of the oil, gas and power industries requires STS Consulting Services, LLC ( Company ) to operate in a wide range of legal and business

More information

Ethical Corporate Management Best Practice Principles

Ethical Corporate Management Best Practice Principles Ethical Corporate Management Best Practice Principles Article I: Last Updated: 2015/11/06 (Purpose of establishment and scope of application) This set of principles was instituted in accordance with the

More information

Business Ethics Policy

Business Ethics Policy Business Ethics Policy Page 1 of 12 Preface and document control This document is intended to provide information in respect of G4S Group Head Office policy, procedure, standards or guidance and will be

More information

Fit and Proper Assessment Best Practice

Fit and Proper Assessment Best Practice Fit and Proper Assessment Best Practice Final Report EMERGING MARKETS COMMITTEE OF THE INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS DECEMBER 2009 CONTENTS Chapter Page 1 Introduction 3 1.1 Objectives

More information

PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Phoenix New Media Limited (together with its subsidiaries, the Company ) is committed to conducting all aspects of its business

More information