Contract and Procurement Fraud. Bribery and Corruption
|
|
- Mae Morrison
- 5 years ago
- Views:
Transcription
1 Contract and Procurement Fraud Bribery and Corruption
2 Corruption The wrongful use of influence to procure a benefit for the actor or another person, contrary to the duty or the rights of others Forms of corruption: Bribery Kickbacks Illegal gratuities Economic extortion Conflicts of interest 2 of 16
3 Bribery The offering, giving, receiving, or soliciting of anything of value to influence an official act or business decision Two types: Official bribery: The corruption of a public official to influence an official act of government Commercial bribery: The corruption of a private individual to gain a commercial or business advantage 3 of 16
4 Methods of Making Corrupt Payments Inappropriate or excessive gifts or favors Loans Use of credit cards or payment of credit card bills Sexual favors Overpaying for purchases Free use or discounted rent for housing/vehicles Outright payments via cash or check Hidden ownership interests Selling/leasing property at less than FMV Promises of favorable treatment 4 of 16
5 Corrupt Influence Improper selection, such as unjustified sole sourcing Paying too much for goods or services Buying too much Continued acceptance of low quality or noncompliant goods or services Late, short, or non-delivery of goods or services 5 of 16
6 Kickbacks A type of bribe in which the commercial or business advantage is favorable treatment in connection with a contract or subcontract 6 of 16
7 Illegal Gratuities Something of value given to an employee to reward a decision after it has been made, rather than influence it before the decision is made A lesser-included offense of official bribery Does not require proof of the intent to influence 7 of 16
8 Economic Extortion Other side of a bribery case Employee or official, through the wrongful use of actual or threatened force or fear, demands money or other consideration to make a particular business decision 8 of 16
9 Conflict of Interest Employee or agent has an undisclosed personal or economic interest in a transaction that adversely affects his professional role 9 of 16
10 Red Flags of Corruption Schemes Red flags in the profiles of the corrupt recipient Red flags of corrupt contracts Internal control red flags Analytical red flags 10 of 16
11 Red Flags of Corrupt Contractors Due diligence reveals any of the following: Inadequate financial resources Poor record of performance Reputation for dishonesty Prior complaints or criminal or civil actions A history of fraudulent conduct Undisclosed outside business interests or front companies owned by the contracting employee Family ties with a procurement employee 11 of 16
12 Red Flags of Corrupt Contractors The contractor s contact information matches any employee s (or employee s relative s) contact information. The contractor s address is not complete. Multiple addresses are listed for the contractor. 12 of 16
13 Red Flags of Corrupt Contractors The contractor, the contractor s industry, or the contractor s country has a reputation for corruption. The contractor does not relate well to other contractors. The contractor is not on the approved contractor list. 13 of 16
14 Analytical Red Flags Repeated selection of particular vendor and decreasing purchases from other vendors Repeat contract awards made to poorly performing contractors Unexplained increases in volumes of purchase Unnecessary or inappropriate purchases 14 of 16
15 Analytical Red Flags Same contractor repeatedly awarded competitive contracts based on bids only slightly lower in price than other competitors Unnecessary or inappropriate purchases of goods or services Questionable or improper method of selecting a contractor Questionable, undocumented, or frequent change orders awarded to a particular contractor 15 of 16
16 Analytical Red Flags Unusual and unexplained delays in the procurement process Unnecessary middleman or broker who offers no obvious value to the performance of the contract Middleman charges high commission Middleman claims to have special influence with a specific buyer 16 of 16
Bribery and Corruption
Bribery and Corruption Introduction Tom Caulfield, CFE, CIG, CIGI Chief Operating Officer Procurement Integrity Consulting Services 2018 Association of Certified Fraud Examiners, Inc. 2018 Association
More information2. WHY IS COMBATING CORRUPTION SO IMPORTANT FOR COMPANIES AND INVESTORS?
ANTI-CORRUPTION 1. INTRODUCTION 2 2. WHY IS COMBATING CORRUPTION SO IMPORTANT FOR COMPANIES AND INVESTORS? 3 3. ADVICE FOR FUND MANAGERS 4 4. FURTHER RESOURCES 6 1. INTRODUCTION CDC defines corruption
More informationReview of Elements of Fraud
Review of Elements of Fraud Elements of Fraud It is critical to understand that there are several elements of fraud. Each type of fraud includes these elements, and all these specific elements must be
More informationI. STATEMENT OF COMMITMENT AGAINST CORRUPTION, BRIBERY & EXTORTION
CITY DEVELOPMENTS LIMITED ANTI-CORRUPTION POLICY & GUIDELINES* (*All employees of CDL are required to read the full version of the CDL Anti-Corruption Policy & Guidelines, which is available on CDL s intranet,
More informationAnti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy 1. Introduction PRG demands the highest standards of integrity and ethical conduct in its business dealings. PRG will not tolerate any bribery or corrupt practices related
More informationThis policy and Code of Conduct will form part of the induction of new EMPLOYEES (as defined below).
ANTI CORRUPTION POLICY STATEMENT OF COMMITMENT RICHLAND GROUP (as defined below) is fully committed to conduct our business with utmost integrity and with the highest ethical standards, and in compliance
More informationGlobal Anti-Corruption Policy. I. Purpose. III. We Prohibit Bribery in All Its Forms
I. Purpose Our Policy is very simple-- we do not tolerate bribery or corruption at LinkedIn. That s because this practice is contrary to our culture and values which seek to create economic opportunity
More informationANTI-BRIBERY & CORRUPTION POLICY
GABRIEL RESOURCES LIMITED ANTI-BRIBERY & CORRUPTION POLICY 1 INTRODUCTION 1.1 The Board of Directors of Gabriel Resources Ltd. 1 (the Company or "Gabriel") has determined that, on the recommendation of
More information1. offering, promising or giving a bribe (in the UK or overseas); 2. requesting, agreeing to receive or accepting a bribe (in the UK or overseas);
BRIBERY ACT POLICY Explanation - Bribery Act Bribery can be defined as an inducement or reward offered, promised or provided in order to gain commercial, contractual, regulatory or personal advantage.
More informationJOHNSON MATTHEY GROUP GLOBAL ANTI-BRIBERY AND CORRUPTION POLICY
JOHNSON MATTHEY GROUP GLOBAL ANTI-BRIBERY AND CORRUPTION POLICY 2011 TABLE OF CONTENTS Sections 1 Johnson Matthey Anti-Bribery And Corruption Statement 2 Introduction 3 Who Is Covered By This Policy? 4
More informationRenishaw Group Anti-Bribery Policy
1. Zero Tolerance Statement Renishaw Group Anti-Bribery Policy Renishaw plc and its subsidiaries ( the Group ) have a zero tolerance approach to all forms of bribery and corruption and this global Renishaw
More informationProcurement. Anti Bribery Policy
Procurement Anti Bribery Policy Policy Manager Andy Hay Policy Group Procurement Policy Established March 2014 Policy Review Period/Expiry Last Updated March 2014 This policy does / does not apply to Medical/Dental
More informationANTI-CORRUPTION AND BRIBERY POLICY
Issue 2 Date: June 2017 Page 1 ANTI-CORRUPTION AND BRIBERY POLICY This policy is endorsed by Harworth s Board of Directors and will be reviewed regularly. This policy may be changed from time to time and
More informationTECHNO BRAIN ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
TECHNO BRAIN ANTI-BRIBERY AND ANTI-CORRUPTION POLICY 1 INTRODUCTION This document sets out the Anti-Bribery and Anti-Corruption Policy ( Policy ) of TechnoBrain group of companies ( Group ). The Group
More informationRING POWER CORPORATION GLOBAL ANTI-CORRUPTION POLICY
Effective Date 4/12/2012 Approved by David Alban RING POWER CORPORATION GLOBAL ANTI-CORRUPTION POLICY Statement of Policy. It is the policy of Ring Power Corporation ( Ring Power or the Company ) to conduct
More informationAnti-Fraud, Corruption and Bribery Policy
Anti-Fraud, Corruption and Bribery Policy Policy Reviewed and Adopted by Board of Trustees: Version Date of Next Review: Responsible Officer: 1 Purpose The purpose of this policy is to confirm Prince Regent
More informationBUSINESS INTEGRITY POLICY
BUSINESS INTEGRITY POLICY Introduction Integrity and accountability are core values for Anglo American. Earning and continuing to command trust are fundamental to the success of our business. Our stakeholders
More informationREF: Legal & Resources Recommended Policy. APPROVAL BODY: DATE: July 2016 REVIEW DATE: July 2019
POLICY: ANTI-BRIBERY & CORRUPTION REF: Legal & Resources Recommended Policy VERSION: 1 APPROVAL BODY: DATE: July 2016 REVIEW DATE: July 2019 LEAD PERSON/ COMPLIANCE OFFICER: VERSION REVIEWER/ APPROVAL
More informationIt is the responsibility of all Fletcher Personnel to understand and comply with this Policy, including any reporting requirements set out below.
POLICY: ANTI-BRIBERY AND CORRUPTION 1. POLICY STATEMENT AND PURPOSE Fletcher Building Limited ( Fletcher Building ) is committed to complying with the law in all jurisdictions in which we operate, as well
More informationProper Business Practices and Ethics Policy
Proper Business Practices and Ethics Policy Synopsis 1. Crown Castle International Corp. ( Crown Castle ) and its affiliates 1 strive to conduct their business with honesty and integrity and in accordance
More information1.3 The required standards of integrity confer a level of personal responsibility upon individuals. This Policy thus applies to:
ANTI-BRIBERY POLICY 1. Introduction 1.1 The University has an absolute commitment to acting ethically, lawfully and with integrity in all its dealings, wherever it operates in the world. As part of this
More informationSimply Media TV Limited: Anti-corruption and bribery policy. DATED JUNE 2013 ANTI-CORRUPTION AND BRIBERY POLICY
Simply Media TV Limited: Anti-corruption and bribery policy. DATED JUNE 2013 ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement... 1 2. Who must comply with this policy?... 1 3. What
More informationAVOIDING BRIBERY AND CORRUPTION POLICY
AVOIDING BRIBERY AND CORRUPTION POLICY INTRODUCTION TransCanada conducts its business in compliance with its Code of Business Ethics and the applicable Anti-Bribery and Anti-Corruption Laws of each country
More informationANTI-BRIBERY AND ANTI-CORRUPTION POLICY. Guidelines for Compliance with the Canadian Corruption of Foreign Public Officials Act
ANTI-BRIBERY AND ANTI-CORRUPTION POLICY Guidelines for Compliance with the Canadian Corruption of Foreign Public Officials Act Red Eagle Mining Corporation (the Company ) and all of its affiliated entities,
More informationBest Buy Anti-Corruption Policy
Best Buy Anti-Corruption Policy 1. Scope 2. Policy Statement 3. Prohibited Conduct and Obligations 4. Definitions 5. Transparency 6. Communication and Reporting 7. Business Partners and Commercial Intermediaries
More informationUK Bribery Act. Document Reference: EXT008
UK Bribery Act Document Reference: EXT008 Version: 2 First approved: September 2009 Last reviewed: May 2015 Date of next review: December 2015 Review History Date of Review September 2009 March 2015 Comments
More informationAnti-bribery and corruption policy & guidelines. December 2011
Anti-bribery and corruption policy & guidelines December 2011 Progressio s organisational statement : Progressio seeks to operate to a high standard in all it does. It works with integrity, accountability
More informationAnti-Bribery Policy. Anti-Bribery Policy
1. Introduction 1.1 It is ASET s policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally,
More informationAnti-corruption and bribery policy.
Anti-corruption and bribery policy. 1. Policy statement 1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption
More informationAnti- Bribery Policy. Date of Approval: 4 th February 2014 Date for Next Scheduled Review: February 2017 Review Body:
Anti-Bribery Policy Policy Title: Anti- Bribery Policy Policy Author: Kenny Stocks Date of Approval: 4 th February 2014 Date for Next Scheduled Review: February 2017 Review Body: MC Equality Impact Assessment
More informationANTI-FRAUD AND CORRUPTION POLICY. For the ACT Alliance
ANTI-FRAUD AND CORRUPTION POLICY For the ACT Alliance Approved by ACT International Executive Committee on April 27 th, 2009 This document was updated in March 2010 to take in account the change of name
More informationOrange group anti-corruption policy
Orange group anti-corruption policy Hello, We have chosen to build tomorrow s digital world as a responsible and trustworthy company. We are committed to conducting our activities soundly and with integrity,
More informationMcCRACKEN COUNTY BOARD OF EDUCATION
McCRACKEN COUNTY BOARD OF EDUCATION INVITATION TO BID OFFICE SUPPLIES The McCracken County Board of Education invites you to submit a sealed bid for Office Supplies, as shown in the following pages, for
More informationAIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY
AIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement... 3 2. Who is covered by the policy?... 4 3. What is bribery?... 4 4. Hospitality and gifts... 5 5. What is not acceptable?...
More informationAnti-bribery Policy. Approving Body: Council. Date of Approval: 26 November Policy owner: Director of Finance and Corporate Services
Anti-bribery Policy Approving Body: Council Date of Approval: 26 November 2018 Policy owner: Director of Finance and Corporate Services Policy contact: Stephen Forster, stf17@aber.ac.uk Policy status:
More informationnib holdings limited ABN and all related entities within the nib Group ( nib Group ) or ( nib ) Dated 13 February 2017
nib holdings limited ABN 51 125 633 856 and all related entities within the nib Group ( nib Group ) or ( nib ) Dated 1 Purpose 2 1.1 Scope of this document 2 1.2 Who does the anti-bribery policy apply
More informationSCOTTISH JUNIOR FOOTBALL ASSOCIATION ANTI-CORRUPTION AND BRIBERY POLICY
SCOTTISH JUNIOR FOOTBALL ASSOCIATION ANTI-CORRUPTION AND BRIBERY POLICY ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement 3 2. About this policy 3 3. Who must comply with this policy?
More informationANTI-BRIBERY AND CORRUPTION POLICY
ANTI-BRIBERY AND CORRUPTION POLICY Cubiks Group Limited Ranger House Walnut Tree Close Guildford GU1 4UL United Kingdom Registered Office as above, registered number 4999756 Bribery And Corruption Policy.Doc
More informationREPRESENTATIONS, CERTIFICATIONS, AND ACKNOWLEDGEMENTS
REPRESENTATIONS, CERTIFICATIONS, AND ACKNOWLEDGEMENTS NOTE: If the offeror has registered at the SAM (System For Award Management) site https://www.sam.gov for the Federal representations and certifications,
More informationANTI BRIBERY AND CORRUPTION POLICY
ANTI BRIBERY AND CORRUPTION POLICY (ADOPTED BY THE BOARDS OF BOWLEVEN PLC AND EUROIL LIMITED ON 30 JUNE 2011) Bowleven plc 50 Lothian Road Festival Square Edinburgh EH3 9WJ Tel: 0131 524 5678 Fax: 0131
More informationZen Internet ANTI-CORRUPTION AND BRIBERY POLICY. Zen Legal Department. Issue: v.2.final. Date: Wednesday, 05 August 2015
Zen Internet Zen Legal Department Issue: v.2.final Date: Wednesday, 05 August 2015 Contents 1 Policy Statement...1 2 About this policy...2 3 Who must comply with this policy?...3 4 Who is responsible for
More informationTSB CONSTRUCTIONS LTD
BRIBERY PREVENTION 86 Stockwell Road Handsworth Birmingham, B21 9RJ West Midlands www.tsbconstructionsltd.tsbpvtltd.com constructions@tsbpvtltd.com Management System ANTI-CORRUPTION POLICY STATEMENT As
More informationAnti-Corruption Policy
Anti-Corruption Policy Version: 1 Page 1 of 10 INTRODUCTION 1 Our Commitment Accolade Wines conducts all of its business in an honest and ethical manner. We take a zero-tolerance approach to bribery and
More informationAnti-Bribery & Anti-Corruption Policy
Anti-Bribery & Anti-Corruption Policy Table of Contents Anti-Bribery & Anti-Corruption Policy... 1 1. What does your policy cover?... 2 2. Policy Statement... 2 3. Who is covered by the policy?... 2 4.
More informationOFFICE OF ANTICORRUPTION AND INTEGRITY ANTICORRUPTION SEMINAR FOR CONSULTANTS, CONTRACTORS, AND SUPPLIERS
OFFICE OF ANTICORRUPTION AND INTEGRITY ANTICORRUPTION SEMINAR FOR CONSULTANTS, CONTRACTORS, AND SUPPLIERS 1 Main Objectives Increase understanding and compliance with ADB s Anticorruption Policy Raise
More informationANTI-BRIBERY AND CORRUPTION POLICY
Table of Content 1. Purpose... 2 2. Scope... 2 3. Responsibility... 2 4. General principles... 3 a. What is Bribery?... 3 b. Bribery of Government Officials... 4 c. Commercial Bribery... 6 d. Preventing
More informationFurness Building Society. Bribery Policy
Furness Building Society Bribery Policy 1. Objectives 1.1 The aim of the Furness Building Society s Bribery Policy ( Bribery Policy ) is to set out our practice and approach for countering bribery. 1.2
More informationFirstRand Suppliers Code of Conduct
FirstRand Suppliers Code of Conduct - 2 - table of contents 1. WHY DOES FIRSTRAND HAVE A SUPPLIERS CODE OF CONDUCT POLICY? 3 2. POLICY SCOPE 3 2.1 Who does the policy apply to? 3 2.2 Who is a supplier
More informationFighting Corruption: What Should Internal Auditors Do? Hans Nieuwlands CIA CGAP CCSA RA
Fighting Corruption: What Should Internal Auditors Do? Hans Nieuwlands CIA CGAP CCSA RA International initiatives to combat bribery Agenda Laws and regulations What with is corruption/bribery? a global
More informationUNIVERSITY OF ROEHAMPTON ANTI-CORRUPTION & BRIBERY POLICY
UNIVERSITY OF ROEHAMPTON ANTI-CORRUPTION & BRIBERY POLICY Originated by Legal Officer: May 2014 Recommended by Nominations & Governance Committee 2 March 2015 Endorsed by Senate: 18 June 2014 Approved
More informationThe offering, giving, soliciting or acceptance of an inducement or reward which may influence the action of any person.
Anti-Bribery Policy Responsible Officer Director of Finance 1.0 WHAT IS BRIBERY Bribery can be defined as: The offer or receipt of any gift, loan, payment, reward or other advantage to or from any person
More informationCorruption in Procurement
Corruption in Procurement Presentation to the Institute of Brazilian Issues Christopher Yukins The George Washington University 2 Topics Introduction Christopher Yukins/GWU Law School Anti-Corruption in
More informationCARIBBEAN DEVELOPMENT BANK PROCEDURES FOR DEALING WITH FRAUD AND CORRUPTION IN CDB-FINANCED PROJECTS
CARIBBEAN DEVELOPMENT BANK PROCEDURES FOR DEALING WITH FRAUD AND CORRUPTION IN CDB-FINANCED PROJECTS OCTOBER 2014 TABLE OF CONTENTS 1. INTRODUCTION 2. DEFINITIONS 3. PREVENTION AND DETECTION OF PROHIBITED
More informationAnti-Bribery Policy WHC reserves the right to amend this policy at its discretion. The most up-to-date version can be downloaded from our website.
ANTI-BRIBERY POLICY ELT manager Director of Finance Responsible officer Director of Finance Date first approved by BoM 29 th March 2012 Date review approved by BoM 4 th October 2017 Next Review Date October
More informationAnti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy Policy # BW-GRP- ABC-01 Effective Date 30 September 2017 Email hilaryw@barloworld.com Version V2.2 Contact Hilary Wilton Phone 011 445 1168 Purpose... 1 Scope... 1 Regulatory
More informationCHINESE SUPREME COURT AND PROCURATORATE ISSUE OPINIONS TO CLARIFY ISSUES RELATED TO BRIBERY
January 15, 2009 CHINA ALERT CHINESE SUPREME COURT AND PROCURATORATE ISSUE OPINIONS TO CLARIFY ISSUES RELATED TO BRIBERY On November 21, 2008, the Supreme People s Court and Supreme People s Procuratorate
More informationSTMICROELECTRONICS ANTI-BRIBERY & CORRUPTION POLICY
STMICROELECTRONICS ANTI-BRIBERY & CORRUPTION POLICY INDEX PAGES 1. PURPOSE AND SCOPE 2 1.1 Purpose 2 1.2 Scope 2 2. ORGANIZATIONAL UNITS AFFECTED 2 3. POLICY STATEMENT 2 4. GENERAL PRINCIPLES 3 4.1 Definitions
More information2. Anti-Bribery and Corruption Policy
2. Anti-Bribery and Corruption Policy This document sets out the policy of Canary Wharf Group plc and its group of companies (the Group ) in relation to bribery and corruption. It may be amended by the
More informationCommunity Development and CSR: Managing Expectations & Balancing Interests
Community Development and CSR: Managing Expectations & Balancing Interests The 8 th Risk Mitigation and CSR Seminar Canada-South Africa Chamber of Business Tuesday, October 16, 2012 Introduction OBJECTIVE:
More informationAnti-Corruption and Bribery Policy
1. POLICY STATEMENT 1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zerotolerance approach to bribery and corruption and are committed to acting professionally,
More informationAnti-Corruption & Bribery Policy (including gifts and hospitality)
Anti-Corruption & Bribery Policy (including gifts and hospitality) Academy Transformation Trust Further Education (ATT FE) Policy adopted by FE Board 4 th November 2015 This policy links to: Whistle Blowing
More informationThe Bribery Act Southampton Solent University Key Guidance (May 2017)
The Bribery Act 2010 Southampton Solent University Key Guidance (May 2017) Bribery is a criminal offence in the UK and in most countries in which the University operates and from which our students come.
More informationPURCHASING ETHICS 2017 AGENCY PURCHASING CONFERENCE PRESENTED BY: JIMMY MEADOWS, GENERAL COUNSEL
PURCHASING ETHICS 2017 AGENCY PURCHASING CONFERENCE PRESENTED BY: JIMMY MEADOWS, GENERAL COUNSEL PURCHASING ETHICS History of the Purchasing Division Division created in the 1940 s Relative Issues: Invest
More informationIntegrity Declaration Form. Instructions for Submitting an Integrity Declaration Form
Integrity Declaration Form An Integrity Declaration Form must be submitted only when: Protected B when completed 1. the supplier, one of its affiliates 1 or a proposed first-tier subcontractor 2 has, in
More informationGAC Anti-Corruption and Bribery Policy. November 2015
November 2015 1. POLICY STATEMENT 1.1 This Anti-Corruption and Bribery policy complements the GAC Code of Ethics. The GAC Code of Ethics emphasises that the values promoted in the Code must underlie all
More informationANTI-BRIBERY POLICY AND PROCEDURES
ANTI-BRIBERY POLICY AND PROCEDURES For use by: All Society employees; Members undertaking activities on behalf of the Society; agents, consultants and contractors acting for the Society. Owner Director
More informationGAC Anti-Corruption & Bribery Policy. January 2018
GAC Anti-Corruption & Bribery Policy January 2018 1.1 This Anti-Corruption and Bribery policy complements the GAC Code of Ethics. The GAC Code of Ethics emphasises that the values promoted in the Code
More informationGroup Business Integrity Policy
Group Business Integrity Introduction Regrettably, bribery and corruption is a feature of corporate and public life in many countries across the world. Even the suggestion of corruption may damage the
More informationFraud and Corruption Control Plan
Fraud and Corruption Control Plan 2018-2019 1. INTRODUCTION 1.1 Commitment to fraud and corruption control University of Adelaide ( the University ) recognises that it has a responsibility to develop,
More informationBrookfield Renewable Partners L.P. ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
ANTI-BRIBERY AND ANTI-CORRUPTION POLICY TABLE OF CONTENTS APPLICATION OF THE POLICY 1 COMMITMENT TO ANTI-BRIBERY AND ANTI-CORRUPTION 1 PROHIBITION 1 DEALING WITH PUBLIC OFFICIALS 2 GIFTS AND ENTERTAINMENT
More informationCorruption in Procurement
Corruption in Procurement Presentation to the Institute of Brazilian Issues Christopher Yukins The George Washington University 2 Topics Introduction Christopher Yukins/GWU Law School Anti-Corruption in
More informationANTI-BRIBERY POLICY 1. INTRODUCTION
ANTI-BRIBERY POLICY 1. INTRODUCTION 1.1 Keele University is committed to the highest standards of openness, transparency and accountability and to conducting its affairs in accordance with the requirements
More informationANTI - BRIBERY POLICY & PROCEDURE
POLICY TITLE ANTI - BRIBERY POLICY & PROCEDURE DOCUMENT AUTHOR AND DEPARTMENT Alison Loudon Assistant Secretary to Court POLICY OWNER Donna McMillan Registrar & Secretary to Court APPROVING BODY DATE OF
More informationLittle Rascals Pre-school Anti-Bribery Policy
Little Rascals Pre-school Anti-Bribery Policy Purpose The purpose of this policy is to establish controls to ensure compliance with all applicable antibribery and corruption regulations, and to ensure
More informationAnti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy CONTENTS CLAUSE 1. Policy statement... 1 2. Who is covered by the policy?... 1 3. What is bribery?... 2 4. Gifts and hospitality... 2 5. What is not acceptable?... 3
More informationAnti-bribery and Corruption Policy
Anti-bribery and Corruption Policy This policy sets out Campbell & Kennedy Ltd's (Henceforth C&K) stance on the implementation and management of anti-bribery and corruption measures across the Companies
More informationPOLICY AGAINST BRIBERY AND CORRUPTION. Introductory Guidance. This policy has been introduced in response to the Bribery Act 2010 ( the Act )
POLICY AGAINST BRIBERY AND CORRUPTION Introductory Guidance This policy has been introduced in response to the Bribery Act 2010 ( the Act ) The Act creates four key offences:- Active bribery (the offence
More informationCHALMERS SUSPENSIONS INTERNATIONAL INC Northam Drive Mississauga, Ontario, Canada L4V 1J1 ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
CHALMERS SUSPENSIONS INTERNATIONAL INC. 6400 Northam Drive Mississauga, Ontario, Canada L4V 1J1 ANTI-BRIBERY AND ANTI-CORRUPTION POLICY APPLICATION OF THE POLICY This Anti-Bribery and Anti-Corruption Policy
More informationANTI-BRIBERY POLICY 1 POLICY STATEMENT
ANTI-BRIBERY POLICY Issued/approved by: Modern Water plc Board on 14 June 2011 Last updated: 17 September 2014 Applies to: Modern Water plc and any company or other entity (registered or operating anywhere
More informationAvoiding FCPA Violations in
Avoiding FCPA Violations in March 14, 2012 Bill Pollard, Partner Deloitte Financial Advisory Services LLP Bill Pollard is a Partner in the Forensic and Investigative Services Practice in Chicago, Illinois,
More informationANTI BRIBERY POLICY. The University s commitment to honest and ethical trading
ANTI BRIBERY POLICY Introduction The Bribery Act 2010 ( Act ) came into force on 1 st July 2011, replacing a number of older laws and creating a single comprehensive code in relation to bribery. The Act
More informationANTI BRIBERY AND CORRUPTION POLICY
ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 The Foundation takes a zero tolerance approach to bribery and corruption and will uphold all applicable laws relevant to countering bribery and
More informationANTI-CORRUPTION & BRIBERY POLICY
ANTI-CORRUPTION & BRIBERY POLICY REVISION HISTORY: ISSUE CHANGES DATE 1 Initial Issue 30/07/2015 2 General updates 09/03/2016 AUTHORISED BY: NAME TITLE SIGNATURE DATE Deon van Aswegen Quality Manager 09/03/2016
More informationVendor Certifications and Representations
Vendor Certifications and Representations The vendor represents and certifies as part of its proposal/quotation that: (Please check or complete all applicable boxes or blocks and initial each page at the
More informationTruform Manufacturing LLC. Anti-Bribery, Anti-Corruption & Rev /22/17
Truform Manufacturing LLC Anti-Bribery, Anti-Corruption & Whistle Blowing Policy Contents 1. What does your policy cover?... 3 2. Policy statement... 3 3. Who is covered by the policy?... 3-4 4. Definition
More informationANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY
ANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY Policy Number 5 July 2015 This Document is for the use of Scotmid Employees and their advisors only. No
More informationCorruption in Procurement
Corruption in Procurement Presentation to the Institute of Brazilian Issues Christopher Yukins The George Washington University November 3, 2009 Topics 2 Introduction Christopher Yukins/GWU Law School
More informationANTI-BRIBERY POLICY. 1. Purpose
ANTI-BRIBERY POLICY 1. Purpose The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company s business
More informationAnti Bribery Policy. 1.2 We will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010.
Anti Bribery Policy 1. Policy statement 1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zerotolerance approach to bribery and corruption and are committed
More informationNOBLE MOBILITY CHARTER OF CORPORATE SOCIAL RESPONSIBILITY
NOBLECARE NOBLE MOBILITY CHARTER OF CORPORATE SOCIAL RESPONSIBILITY WHO WE ARE NOBLE MOBILITY is a leading provider of moving and relocation services in the corporate market. The company s core values;
More informationWarrego Energy Limited Level 6, 10 Bridge Street, Sydney NSW 2000 T: E: warregoenergy.com ABN
Warrego Energy Limited ACN 125 394 667 WARREGO ENERGY LIMITED ANTI-CORRUPTION & BRIBERY POLICY Contents SECTION 1. Warrego s commitment to ethical performance 1 2. Who is covered by the policy? 2 3. What
More informationThe LTE Group. Anti-Bribery Policy Produced by. The LTE Group. LTEG anti-bribery policy v4 06/2016
The LTE Group Produced by The LTE Group LTEG anti-bribery policy v4 06/2016 All rights reserved; no part of this publication may be photocopied, recorded or otherwise reproduced, stored in a retrieval
More informationANTI-CORRUPTION AND BRIBERY POLICY
ANTI-CORRUPTION AND BRIBERY POLICY Date Approved by Governors March 2017 Review Date March 2019 On behalf of Governors signed Print name On behalf of Governors signed Print name Principal s signature All
More informationGlobal Anti Bribery and Corruption Compliance Program Be transparent and keep it transparent
Global Anti Bribery and Corruption Compliance Program Be transparent and keep it transparent Page 1 of 13 Table of Contents 1 Why a Global Anti Bribery and Corruption Compliance Program?... 3 2 Our approach...
More informationFIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY
! FIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 As indicated in Article 8 of the Internal Regulations of the FIA Institute, we take a zero tolerance approach to bribery and corruption
More informationThe Receipt of Gifts by Federal Employees in the Executive Branch
The Receipt of Gifts by Federal Employees in the Executive Branch Jack Maskell Legislative Attorney July 25, 2014 Congressional Research Service 7-5700 www.crs.gov R43660 Summary This report provides information
More informationSUNTORY BEVERAGE AND FOOD EUROPE ANTI-BRIBERY AND CORRUPTION POLICY OCTOBER 2015 EDITION 001
SUNTORY BEVERAGE AND FOOD EUROPE ANTI-BRIBERY AND CORRUPTION POLICY OCTOBER 2015 EDITION 001 1 TABLE OF CONTENTS 1. POLICY STATEMENT...3 2. ANTI-BRIBERY AND CORRUPTION LAWS...4 3. THE PENALTIES...4 4.
More informationAnti-Fraud, Bribery and Corruption Policy
Anti-Fraud, Bribery and Corruption Policy Anti-Fraud, Bribery and Corruption Policy Version 2 Approved by: Audit and Risk Committee Approved date: 22 May 2017 1.0 Introduction 1.1 Optivo is committed to
More informationAnti-Bribery and Corruption Policy METALSEARCH LIMITED
Anti-Bribery and Corruption Policy METALSEARCH LIMITED Dominion Legal 104 Edward Street Perth WA 6000 Tel: 0431 183 296 Ref: 1. Overview 1.1 Introduction This policy stipulates mandatory compliance requirements
More informationAnti-bribery policy. November 2017
Anti-bribery policy November 2017 1. PURPOSE AND OBJECTIVES The adverse economic and social consequences of bribery and corruption are a major deterrent to development, everywhere in the world. Sanofi
More information