This policy sets out the Company’s commitment to responsible ethical, social and environmental considerations. This policy shall be issued to each employee so that each employee is fully aware of the policy and its aims.
It is the Company’s responsibility to be prepared to discuss any element of this policy and proactively provide enough information to enable the Company to monitor compliance with the policy.
The Principles (The "Principles")
The Company’s business operations must comply with the following principles:
The Company has internal procedures relating to anti-corruption and the prevention of bribery.
The Company shall use reasonable endeavours to ensure that each Supplier and Agent shall comply with the standards contained within this policy by undertaking reasonable due diligence in respect of the identity and business practices of each Supplier and Agent.
PAYMENTS AND RECORDS
The Company shall maintain books and records that, in reasonable detail, accurately and fairly reflect the Company’s transactions.
In particular, employees must ensure that the Company maintains books and records that substantiate that (i) all invoices and other charges submitted to the Company for payment were valid and proper and (ii) no improper payments have been made, directly or indirectly, by or on behalf of the Company to or for the benefit of any person (including a Government Official).
All such books and records must be maintained in accordance with generally accepted accounting principles and applicable sanctions, Anti-Corruption, Anti-Terrorism and Anti-Money Laundering Laws.
No undisclosed or unrecorded funds or assets shall be established for any purpose.
No false or artificial entries shall be made in such books and records for any reason, such as mischaracterising the purpose or recipient of a payment.
No payment shall be approved or made with the agreement or understanding that any part of such payment is to be used for any purpose other than that described by documents supporting the payment.
The Company and each employee must not take any action, directly or indirectly which would cause the Company to fail to comply with any of this policy. Additionally, each employee must proactively seek assistance if he or she becomes aware of a possible policy violation. Employees will not be penalised for diminished productivity attributable to their refusal to violate this policy or for their good faith reporting of a suspected or actual violation of this policy.
Any failure by employees to comply with this policy will result in severe sanctions, up to and including dismissal and referral for prosecution. If any employee is in any doubt as to whether any act or omission is proper, they must seek guidance from the General Manager.
The following definitions apply in this policy:
Agent: any agent, consultant, lobbyist or other similar intermediary having relations with third parties (including Government Officials) on behalf of the Company
Anti-Corruption Laws: any laws, regulations or conventions related to combating bribery and corruption, including the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions; the Bribery Act 2010 in the United Kingdom; the Foreign Corrupt Practices Act in the United States; or other comparable laws in any jurisdiction Anti-Terrorism and Anti-Money Laundering Laws: any laws, regulations or conventions related to terrorism or money laundering, including the European Union Money Laundering Directives (as amended and/or supplemented from time to time and as implemented in the UK); the Money Laundering Regulations 2007, the Proceeds of Crime Act 2002, the Serious Organized Crime and Police Act 2005 and the Anti-Terrorism, Crime and Security Act 2001 in the United Kingdom; the Bank Secrecy Act of 1970 and the PATRIOT Act of 2001 in the United States; or other comparable laws in any jurisdiction
Employees: all officers or employees of the Company or any members of its group
Government Entity: any (a) national, municipal, provincial, state or federal government, (b) department, agency or instrumentality thereof (including any state-owned or controlled enterprise or government agency) or (c) public international organization (including the World Bank and the International Finance Corporation)
Government Official: any (a) officer, employee, or official advisor of a Government Entity, (b) political party or official thereof or candidate for any political office, or (c) person acting for or on behalf of any of the foregoing
Social Obligations: (a) any laws, regulations or conventions in any jurisdiction related to the relationship between an employer and its employees, any potential employee or any trade union, or the health and safety of employees or (b) any agreements or arrangements between any Portfolio Company and its employees and/or any trade union or other body which represents some or all of its employees
Supplier: any supplier, manufacturer or any other person involved in supplying goods or materials to the Company