Anti Corruption Policy

BACKGROUND

ACME and its management are committed to conducting all of its operations ethically and honestly.  We believe that the way we achieve results is as important as the results themselves.  Complying with anti-corruption and anti-bribery laws is a condition of employment and a condition of doing business with the Company.

BRIBERY

A bribe refers to a financial or similar reward designed to induce the recipient to provide an improper business advantage. Bribes can be offered by government officials, customers, vendors and others. Bribes can take the form of money, gifts, loans, fees, services, discounts, the award of a contract or other advantage or benefit. The act of bribery includes offering, promising, giving, accepting or seeking a bribe.

Specifically you must not:

  • Give or offer any payment, gift, hospitality, or other benefit with the expectation that a business advantage will be received in return, or to reward any business received;
  • Accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or
  • Give or offer any payment to a government official in any country to facilitate or speed up a routine or necessary procedure;
  • Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

GIFTS AND HOSPITALITY

Gifts and hospitality are sometimes used for legitimate purposes such as building relationships and promoting the Company. Any gifts or entertainment provided on the Company’s behalf to any recipient, or received by any Company employee must be:

  • Reasonable in value and appropriate to the circumstances;
  • Permitted under applicable law
  • Approved within the Company’s procedure

For purposes of this policy, gifts will include, but not be limited to, cash, cash equivalents (such as gift cards), gifts, travel, meals, entertainment, use of vehicles, accommodations or valuable favors such as educational and employment opportunities for friends and relatives, loans and use of vacation property with a value. Such gifts will have a value of at least $50. Employees are prohibited from offering or receiving gifts as defined here without approval from Management.

REPORTING

Employees are required to report any actual or suspected violations of this policy by the Company, an employee or any third party. Violations can be reported to any member of Management. Failure to do so may result in disciplinary action.

No employee will be penalized for refusing to pay a bribe, even if it results in the Company suffering a loss of business or having a negative impact on production schedules. The Company will not permit retaliation against an employee who in good faith reports suspected misconduct.

No policy can anticipate every possible situation that can arise. If you are ever confronted with a situation in which you question the legality of a request or a payment, contact a member of Management before proceeding. Avoid even the appearance of dishonesty.