NETCARE LIMITED CORPORATE GOVERNANCE ANTI-CORRUPTION POLICY POLICY NUMBER COR12 CORPORATE GOVERNANCE PREPARED BY PREPARATION DATE JUNE 2014
|
|
- Randall Pope
- 5 years ago
- Views:
Transcription
1 NETCARE LIMITED CORPORATE GOVERNANCE POLICY POLICY NUMBER COR12 PREPARED BY APPROVED BY CORPORATE GOVERNANCE CORPORATE GOVERNANCE PREPARATION DATE JUNE 2014 ISSUE DATE FEBRUARY 2017 REVISION DATE FEBRUARY 2019 VERSION 1.1 (2017)
2 COPYRIGHT WARNING NOTICE This policy and procedure is the property of Netcare Limited. Copyright subsists in this work. Any unauthorised reproduction, publication or translation of the work are acts of copyright infringement and may lead to criminal prosecution. The compilation and input to the guide was obtained from experts in the field. Any changes and alterations can only be made with the approval of the authors. Reference to one gender can be interpreted to imply belonging to either gender. Any deviations from this policy and its supporting standard operating procedures require the approval from the assigned approval committee. All deviations, comments and suggestions could be ed to Page 2 of 9
3 1. POLICY STATEMENT AND PURPOSE RISKS POLICY APPLICABILITY DEVIATION FROM THIS POLICY PROMOTING ETHICAL AND LAWFUL CONDUCT CONTROL MEASURES AND STRATEGIES GIFTS AND HOSPITALITY CONTRACTUAL RELATIONSHIPS UNAUTHORISED PAYMENTS COMPLIANCE WITH ETHICAL STANDARDS IN THE SUPPLY CHAIN PROCUREMENT PRACTICES CONTRIBUTIONS TO POLITICAL PARTIES AND CHARITIES TRAINING POLICY FRAMEWORK AND LEGAL FRAMEWORK APPLICABLE WHISTLE-BLOWING, REPORTING AND REMEDIAL ACTION TERMINOLOGY REFERENCE... 9 Page 3 of 9
4 1. POLICY STATEMENT AND PURPOSE The Netcare Group prohibits corruption, bribery and economic crime in any form. The Group is committed to do everything lawful, ethically and with integrity, ensuring Group values are upheld. A zero-tolerance stance is adopted and corruption will not be tolerated, whether the influence is internal or external to the organization. Netcare is a proud participant to the UN Global Compact Principles. This policy provides the framework to guide employees in dealing with corruption and economic crime situations. Due consideration has been given to the South African legislative framework, the UK Bribery Act, 2010 and the Foreign Corrupt Practices Act 1977 and the Prevention of Corrupt Activities Act No 12 of RISKS i. A corrupt transaction of any kind represents a legal, and compliance risk. ii. Significant reputation risk can be attributed to Netcare if it is accused of, or found to be guilty of corrupt practices, ultimately destroying the trust relationship with stakeholders of the Group. 3. POLICY APPLICABILITY This policy is applicable to all employees and directors of the Netcare Group. Employees of the Group include full-time, part-time and consultants that render services in any of the divisions, subsidiaries and associated companies. All suppliers dealing with the Group will declare their compliance and support with this policy to eradicate corrupt practices. 4. DEVIATION FROM THIS POLICY Any breach of applicable anti-corruption laws, regulations and guidelines are seen in a very serious manner. If reasonable grounds exist, demonstrating negligent conduct, a dismissal may follow. Employees may be subject to civil and/or criminal prosecution. The business Page 4 of 9
5 relationship with non-employees and business partners that violates this policy will be terminated. 5. PROMOTING ETHICAL AND LAWFUL CONDUCT i. Netcare acknowledge the importance of promoting a culture and behavioural conduct that is ethical and lawful at all times. This is achieved by means of the following key guiding principles. It includes: a. Commitment from the Board and Executive committee to set the moral and ethical direction of the organisation so that others can follow in their guiding footsteps; b. Risk assessments conducted in high risk areas with mitigating controls introduced; c. Regular awareness and staff training to take place to ensure diligence and awareness of actions that may be interpreted as corrupt activities or bribery; d. Ongoing communication within the stakeholder community of Netcare will take place to ensure all are aware of the zero tolerance attitude. This include the role of senior management to ensure all people reporting to them, are aware of this policy. e. Monitoring, auditing and reviewing the environment as a preventative step to mitigate risk and exposure. 6. CONTROL MEASURES AND STRATEGIES 6.1 Gifts and Hospitality Netcare recognise that gifts and hospitality is perceived to affect the outcome of business transactions and as such a strict policy is in place limiting the value of offers that can be received. See policy COR10 Gifts and Hospitality. 6.2 Contractual relationships All contractual relationships between Netcare and its business partners should be reduced to writing and signed by the parties. All contracts have to be approved in line with the Limits of Approval Framework of the Group (Finance Policy FIN01). Page 5 of 9
6 Business partners may be subject to vetting, verification of information and due diligence to ensure Netcare limits inappropriate business association. As such all business partners must keep proper books and record that may be subject to the Internal Audit Division of the Netcare Group. 6.3 Unauthorised payments No unauthorised payments are allowed. All payments must have supporting documentation and or contracts to ensure underlying services are in place to justify the payment. 6.4 Compliance with ethical standards in the supply chain Netcare will communicate and make known to all business partners its policy relating to antibribery and corruption. This will also be used as an encouragement to pledge compliance and adoption of this policy. Suppliers will further sign the Procurement PRC05 Terms and Conditions that states their compliance with anti-corruption and eradication of economic crime. 6.5 Procurement practices Netcare will conduct all procurement in a fair and transparent manner. Where it is reasonably suspected that a specific supplier or contractor pays bribes, Netcare will avoid and discard any further dealings with such a supplier, and may terminate any agreement where bribes have been confirmed. Tender documents will include a declaration of interest and anti-corruption clause. Netcare staff must disclose all their related business transactions as per the Conflict of Interest standard operating procedure COR04.S Contributions to political parties and charities Netcare is an ardent supporter of democracy in South Africa. If any donation is made, it would be done in accordance with internal policies and the Independent Electoral Commission s (IEC) formula for political party funding, and would be accompanied by detailed disclosure in the Annual Financial Statements. Page 6 of 9
7 6.8 Training The Group will on an annual basis endeavour to train all staff to whom this policy is applicable. 7. POLICY FRAMEWORK AND LEGAL FRAMEWORK APPLICABLE The following legislation is applicable to the Anti-Corruption and Bribery environment. i. The Constitution of South Africa Act No 108 of 1996 which deals with the principles regarding procurement to be fair, equitable, transparent, cost effective and competitive for all trading in the public domain. ii. The Promotion of Administrative Justice Act No 3 of 2000, which aims to promote good governance, openness, transparency and accountability in the exercise of public power. iii. The Prevention and Combating of Corrupt Act No 12 of 2004 Activities Act that requires people in positions of authority to report corruption over R Failure to report activities is a criminal offence. iv. The Companies Act No 71 of 2008 incorporates anti-corruption measures in the regulations that require the establishment of social and ethics committees. This committee is required to perform a wide range of activities, including monitoring the company s anti-corruption activities. The importance of directors' conduct to ensure no misleading or false records are made is noted as mindful provisions of the governance structures of the Netcare Group. v. The Financial Intelligence Centre Act 38 of 2001 requires reporting of activities that may constitute money laundering activities. The Group's action with regards to this act is encapsulated in the Netcare Group Risk, Audit and Forensic policy GR02 Fraud and Corruption. vi. The Promotion of Access to Information Act 2 of 2000, which is intended to foster a culture of transparency and accountability in public and private bodies and promote a society where people have access to information in order to protect their rights. vii. The Protected Disclosures Act 26 of 2000 which aims to promote the eradication of criminal. Other relevant guiding documents that form part of the stance against corruption include: Page 7 of 9
8 i. UN Global Compact - as a signatory and participant Netcare upholds the principle that businesses should work against corruption in all its forms, including extortion and bribery. ii. OECD recommendations on anti-corruption that prohibits bribes and extortion. iii. King III Report on Corporate Governance for South Africa encourages an inclusive stakeholder approach as adopted and confirmed by the Netcare Corporate Governance Policy COR 09 Stakeholder engagement. The following policies should be read in conjunction with COR12 Corporate Governance Anti-Bribery and Corruption: i. Corporate Governance Gifts and Hospitality COR10 ii. Corporate Governance Code of Ethics COR04 iii. Corporate Governance Conflict of Interests COR04.S01 iv. Corporate Governance Fraud and Corruption Policy GR02 v. Corporate Governance Fraud and Ethics Hotline GR07 vi. Corporate Governance Finance Limits of Approval FIN01 vii. Corporate Governance Procurement PRC03 Supplier Management viii. Corporate Governance Procurement PRC03.S01 Anti-bribery declaration Suppliers ix. Corporate Governance Stakeholder engagement COR09 8. WHISTLE-BLOWING, REPORTING AND REMEDIAL ACTION Reporting of incidents of violation or concerns is the duty of each and every stakeholder of the Group. The prescribed reporting mechanisms include: i. Directly to Line Manager; ii. Directly to the Group Risk, Audit and Forensic Services; iii. Directly to the Chief Executive; or iv. The Netcare Fraud and Ethics Hotline a. Fraud and Ethics Hotline b. Fraud address fraud@netcare.co.za Page 8 of 9
9 9. TERMINOLOGY Fraud: the unlawful and intentional false representation or concealment of facts resulting in actual or potential prejudice to another, Theft: the unlawful and intentional misappropriation of another s property with the intention to deprive the owner of its rights, Corruption: the abuse of a position of employment by; the offering or acceptance of a benefit that is not legally due, for the commission or omission of an act in connection with that position of employment, Irregularity: any act or omission of a material nature that may lead to the diminishing of shareholder value, where the act or omission is committed within the framework of the employee s: 10. REFERENCE 1. Netcare Staff. 2. UK Bribery Act. 3. Foreign Corrupt Practices Act The Prevention of Corrupt activities Act 12 of The Protected Disclosure Act 26 of Promotion of Access of Information Act 2 of The Financial Intelligence Centre Act 38 of The Companies Act 71 of The Promotion of Administrative Justice Act 3 of The Constitution of South Africa 11. UN Global Compact Principles. 12. OECD Guidelines for multinational enterprises. Page 9 of 9
ALTRON POLICY MANUAL PART B SECTION 4 ANTI-CORRUPTION AND ECONOMIC CRIME POLICY
ALTRON POLICY MANUAL PART B SECTION 4 ANTI-CORRUPTION AND ECONOMIC CRIME POLICY Updated March 2012 CONTENTS 1. Introduction 3 2. Applicability 3 3. Purpose 3 4. Message from the Chief Executive 4 5. Policy
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 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 informationTHE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES
THE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES DECEMBER 2011 CONTENTS Page 1. Introduction 2 2. Objective of This Policy 3 3. The Joint Committee s Commitment to Action 3 4. Policy Statement Anti-Bribery
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 informationAnti-Bribery Policy. Anti-Bribery. Policy. Working Together. January Borders College 15/2/ Working Together.
Anti-Bribery Working Together Policy January 2016 Borders College 15/2/2016 1 Working Together History of Changes Version Description of Change Authored by Date 1.1 New Policy approved at Audit Committee
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 informationIMC Worldwide Ltd. Business Ethics Policy
IMC Worldwide Ltd. Business Ethics Policy Business integrity is the quality of being honest and having strong moral principles. A business that holds itself to consistent moral and ethical standards earns
More informationNORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY
NIPEC/12/12 NORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY Anti-Bribery Policy May 2012 Review date: April 2015 Centre House 79 Chichester Street BELFAST BT1 4JE Tel: (028) 9023
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-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 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 informationDirector of Customer Care & Performance. 26 April The Board is asked to consider and approve the attached draft
To: From: Subject: Status: Date of Meeting: BSO Board Director of Customer Care & Performance Anti Bribery Policy For Approval 26 April 2012 The Board is asked to consider and approve the attached draft
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 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 informationThis Policy sets out Sewtec s position on any form of bribery and corruption and provides guidelines aimed at:
ANTI-BRIBERY & CORRUPTION POLICY Introduction Sewtec Automation Limited ( The Company ) is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business
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 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 information[company name] Anti-Bribery & Anti-Corruption Policy
[company name] Anti-Bribery & Anti-Corruption Policy Contents 1. What does your policy cover?...3 2. Policy statement...3 3. Who is covered by the policy?... 3-4 4.. Definition of bribery...4 5.. What
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 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 informationAnti-Bribery and Corruption Policy. Intouch Holdings Plc
Anti-Bribery and Corruption Policy Intouch Holdings Plc MESSAGE FROM THE CHAIRMAN OF THE BOARD AND THE CHIEF EXECUTIVE OFFICER To: All directors, members of management and employees of the Company We at
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 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 informationNORTHERN IRELAND SOCIAL CARE COUNCIL
NORTHERN IRELAND SOCIAL CARE COUNCIL BRIBERY POLICY FINAL SEPTMBER 2012 1. INTRODUCTION The Bribery Act 2010 (the Act) introduces a new, clearer regime for tackling bribery that applies to all commercial
More informationAnti-Bribery Policy. Perform Green. Perform Green Limited. Registered organisation number:
Anti-Bribery Policy Perform Green Anti-Bribery Policy Page 2 Table of Contents Anti-Bribery & Anti-Corruption Policy... 3 1. Policy statement... 3 2. Who is covered by the policy?... 3 3. Definition of
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 UK ENGINEERING RECRUITMENT LTD
Page 1 of 5 Contents: ANTI-BRIBERY AND CORRUPTION POLICY 1. Definitions 2. Introduction 3. Purpose and scope of this policy 4. The Bribery Act 2010 5. The risks of not acting with integrity 6. The benefits
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-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 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 informationANTI-BRIBERY & CORRUPTION POLICY
ANTI-BRIBERY & CORRUPTION POLICY 0 Anti-Bribery and Corruption Policy 1 Anti-Bribery and Corruption Policy Introduction This policy applies to Portmeirion Group PLC and its subsidiaries, (including Wax
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 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 informationIMC Worldwide LTD. Anti-Bribery and Corruption Procedures March IMC Worldwide LTD. Ethics and Anti - Corruption Policy & Guidelines
IMC Worldwide LTD. Ethics and Anti - Corruption Policy & Guidelines IMC Worldwide Ltd Ethics and Anti-Corruption Policy Statement Our Commitment The IMC Worldwide Ltd (IMC) Board of Directors is fully
More informationGLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT]
GLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT] 1. POLICY STATEMENT 1.1 We take a zero tolerance approach to bribery and corruption and will uphold all laws relevant to countering
More informationSUBMISSION TO THE SENATE ECONOMICS REFERENCES COMMITTEE INQUIRY INTO FOREIGN BRIBERY
SUBMISSION TO THE SENATE ECONOMICS REFERENCES COMMITTEE INQUIRY INTO FOREIGN BRIBERY AUGUST 2015 CONTENTS Summary... 2 A. Introduction... 3 B. Anti-bribery and anti-corruption policies... 3 C. Government
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 informationFirstRand anti-bribery policy
FirstRand anti-bribery policy - 1 - table of contents 1. DEFINITIONS 3 2. POLICY CONTEXT 4 2.1 Ensuring integrity in all business dealings 4 2.2 What is bribery? 4 2.3 Purpose of the policy? 5 2.4 How
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 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 information6.23 Anti-Bribery Policy
6.23 Anti-Bribery Policy Message from the General Director At BMS World Mission we are committed to doing the right thing, the right way. This is more important than ever because of the strict new rules
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 informationPolicy/Procedure WORKING WITH INTEGRITY
Reference Policy/Procedure Version No. Date January 2014 Page 0 of 8 WORKING WITH INTEGRITY Briefing Note on the Anti-Corruption and Bribery Programme Status Owner Checked Approved CADOGAN PETROLEUM PLC
More informationMalaria Consortium Anti-Bribery Policy
Malaria Consortium Anti-Bribery Policy Last updated: October 2018 Author: Finance Director Review date: October 2020 Anti-bribery policy, September 2018 Page 1 1. Purpose and context This policy applies
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 informationProject Anti-Corruption System. (Construction Projects) Template 2. Anti-Corruption Agreement
GIACC Global Infrastructure Anti-Corruption Centre TRANSPARENCY INTERNATIONAL (UK) - PACS - Project Anti-Corruption System (Construction Projects) Template 2 Anti-Corruption Agreement Licence to use: This
More informationRecommendation of the Council for Development Co-operation Actors on Managing the Risk of Corruption
Recommendation of the Council for Development Co-operation Actors on Managing the Risk of Corruption 2016 Please cite this publication as: OECD (2016), 2016 OECD Recommendation of the Council for Development
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 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 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 informationstandards for appropriate ethical, responsible and professional behaviours
Code of conduct 1. Policy statement A code of conduct is a central guide to support day to day decision making. It clarifies an organisation s mission, values and principles and sets out the minimum standards
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 informationAnti-Bribery & Anti-Corruption Policy Ounch Sdn Bhd
Ounch Sdn Bhd 1. What does your policy cover? a. This anti-bribery policy exists to set out the responsibilities of Ounch Sdn Bhd and those who work for us in regards to observing and upholding our zerotolerance
More informationTo: All contacts in England, Wales, Scotland and Northern Ireland
Briefing 11/32 July 2011 Bribery Act 2010 To: All contacts in England, Wales, Scotland and Northern Ireland Key issues New offences created to replace previous bribery crimes Both the private and public
More informationThis guidance applies to all members of the University including all employees and independent members of Council and its Committees.
UNIVERSITY OF ULSTER ANTI- BRIBERY GUIDANCE 1. Introduction This guidance applies to all members of the University including all employees and independent members of Council and its Committees. 2. Position
More informationThe Institute of Company Secretaries of India Northern India Regional Council Seminar on. Dr. Sanjeev Gemawat
The Institute of Company Secretaries of India Northern India Regional Council Seminar on Fraud Risk & Governance: Professionals Responsibility & Liability Dr. Sanjeev Gemawat PHD House, New Delhi Saturday,
More informationANTI-CORRUPTION & BRIBERY
Page 1 of 11 ANTI-CORRUPTION & BRIBERY Page 2 of 11 CONTENTS CLAUSE 1. Policy statement... 3 2. Who is covered by the policy?... 4 3. What is bribery?... 4 4. Gifts and hospitality... 5 5. What is not
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 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 informationFORENSIC. Doing business under the UK Bribery Act. Survey kpmg.com/in
FORENSIC Doing business under the UK Bribery Act Survey 2012 kpmg.com/in Executive summary Following several law commission papers, a first draft of the Bribery Bill was published in March 2009. After
More informationANTI-CORRUPTION AND BRIBERY POLICY
ANTI-CORRUPTION AND BRIBERY POLICY THIS POLICY APPLIES TO MILLFIELD, MILLFIELD PREP SCHOOL, MILLFIELD PRE-PREP SCHOOL (INCLUDING EYFS) AND MILLFIELD ENTERPRISES, TOGETHER REFERRED TO IN THIS POLICY AS
More informationBartington Instruments Ltd. Anti-Bribery Manual. The copyright of this document is the property of Bartington Instruments Ltd.
Anti-Bribery Manual The copyright of this document is the property of Bartington Instruments Ltd. DCN 1109 DO0067 Issue 2 Page 1 of 10 Contents 1. Introduction to this manual... 3 2. Who is covered by
More informationANTI-BRIBERY POLICY. (Covering all employees) Contents
ANTI-BRIBERY POLICY (Covering all employees) Contents 1. Introduction 2. Scope 3. Compliance 4. What is Bribery? 5. What is HITRANS Position on Bribery? 6. Preventing Bribery Adequate Procedures 7. Employee
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-Fraud, Bribery and Corruption Response Policy. Telford and Wrekin Clinical Commissioning Group
Anti-Fraud, Bribery and Corruption Response Policy 2018 Telford and Wrekin Clinical Commissioning Group The Anti-Fraud, Bribery and Corruption Policy for Telford and Wrekin Clinical Commissioning Group
More informationPrevention Of Corruption
Prevention Of Corruption Global Compliance Table Of Contents Standards Application page 6 Purpose page 5 Scope page 6 Bribery/Improper Payments, page 8 Ethical Business Practices, page 8 Unfair Business
More informationSt Michael s Prep School Anti-bribery and corruption policy
St Michael s Prep School Anti-bribery and corruption policy Date of Last Review: 31.08.16 Review Period: Every 2 years Date of Next Review: 31.08.18 Owner: DBI Type of Policy: Compliance with Bribery Act
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 informationFraud and Corruption Prevention Policy
Fraud and Corruption Prevention Policy Version Approved by Approval date Effective date Next review 2.3 Director of Governance 15 January 2018 15 January 2018 January 2016 Policy Statement Purpose Scope
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 informationTHE INTERNATIONAL IMPACT OF FRAUD THE UK BRIBERY ACT RAISING THE BAR ABOVE THE FOREIGN CORRUPT PRACTICES ACT
THE INTERNATIONAL IMPACT OF FRAUD THE UK BRIBERY ACT RAISING THE BAR ABOVE THE FOREIGN CORRUPT PRACTICES ACT The UK Bribery Act has an effective date of April 2011. Prior to this act, the U.S. Foreign
More informationGUIDANCE NOTE. Bribery Act June 2011
GUIDANCE NOTE Bribery Act 2010 June 2011 This Guidance Note outlines the offences that will be introduced by the Bribery Act 2010 ( the Act ) which comes into force on 1 st July 2011 and the penalties
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 Bribery Act 2010:
The Bribery Act 2010: Government Guidance on Adequate Procedures Introduction to the Bribery Act 2010 The Bribery Act came into force on 1 July 2011. The Act updated the UK law on bribery and brought it
More information3.1 A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
ANTI-BRIBERY POLICY Last review October 2016 Next review October 2018 It is Canoe Wales policy to conduct all of our business in an honest and ethical manner. Canoe Wales takes a zero-tolerance approach
More informationThe Bribery Act Adequate procedures.
October 2010 The Bribery Act 2010. Adequate procedures. We set out in this note our suggestions as to the adequate procedures that a company may consider adopting as part of its process of updating compliance
More information«APPROVED» by a rеsolution of Rоstelecom Management Board. Minutes No 04 dated July 4, PJSC ROSTELECOM АNTI-CORRUPTION POLICY (Version 2)
«APPROVED» by a rеsolution of Rоstelecom Management Board Minutes No 04 dated July 4, 2017 PJSC ROSTELECOM АNTI-CORRUPTION POLICY (Version 2) Моsсow 2017 INTROCUCTORY WORD BY MR. M.E. OSEEVSKIY, ROSTELECOM
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 informationBATA INDIA LIMITED WHISTLE BLOWER POLICY
BATA INDIA LIMITED WHISTLE BLOWER POLICY BATA INDIA LIMITED WHISTLE BLOWER POLICY I. Preamble Bata India Limited ( the Company ) believes in fair conduct of its affairs and sets the highest standards in
More informationPolicy on the Prevention of Bribery and Corruption
UNIVERSITY OF LEICESTER Policy on the Prevention of Bribery and Corruption This University Policy on the Prevention of Bribery and Corruption has been adopted and endorsed by Council, the University s
More informationDate: June 14, 2016 JCM CAPITAL ANTI-BRIBERY AND CORRUPTION ( ABC ) POLICY
Date: June 14, 2016 JCM CAPITAL ANTI-BRIBERY AND CORRUPTION ( ABC ) POLICY TABLE OF CONTENTS Page 1 POLICY STATEMENT...3 2 WHO IS COVERED BY THE POLICY?...5 3 COMMITMENT TO STAKEHOLDERS...5 4 COMPLIANCE
More informationANTI-BRIBERY POLICY Rev Date Purpose of Issue/Description of Change Equality Impact Assessment Completed
ANTI-BRIBERY POLICY Rev Date Purpose of Issue/Description of Change Equality Impact Assessment Completed 1. 29 th March, 2012 Initial Issue 2. 5 th October 2015 Review and approval by Compliance Task Group
More informationANTI-CORRUPTION POLICY. Adopted on June 12, 2012 by the boards of directors
ANTI-CORRUPTION POLICY Adopted on June 12, 2012 by the boards of directors 1. DEFINITIONS 1.1. By corruption, LWBC understands all the ways of using resources and skills that are contrary to the laws,
More informationWHISTLE BLOWING POLICY
WHISTLE BLOWING POLICY CONTENTS 1. INTRODUCTION ------------------------------------------------------------------------------------------------- 2 2. PURPOSE ---------------------------------------------------------------------------------------------------------
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 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 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 informationBribery & Corruption Policy
Adam Smith International Bribery & Corruption Policy October 2017 Bribery & Corruption Policy Last review date: 16 October 2017 Next review date: October 2018 Author: Approver: Who does this policy apply
More informationIndustry Agenda. PACI Principles for Countering Corruption
Industry Agenda PACI Principles for Countering Corruption January 2014 World Economic Forum 2014 - All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any
More informationA GUIDE TO WHISTLE BLOWING WHISTLE BLOWING POLICY AND PROCEDURE
A GUIDE TO WHISTLE BLOWING WHISTLE BLOWING POLICY AND PROCEDURE 1 Version 1 CONTENTS 1. INTRODUCTION 2. WHISTLE BLOWER S RIGHTS. 3. INITIAL STEPS. 4. DECIDING ON PROCEDURES. 5. WHISTLEBLOWER POLICY AND
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 informationAnti-Fraud, Bribery and Corruption Policy and Response Plan
Anti-Fraud, Bribery and Corruption Policy and Response Plan Ref: Finance 2.1 Version: 3.0 Supersedes: Author (inc Job Title): Ratified by: (Name of responsible Committee) 2.1 Anti-Bribery Policy and Procedure
More informationInforma PLC TERMS OF REFERENCE AUDIT COMMITTEE. Adopted by the Board on
Informa PLC TERMS OF REFERENCE AUDIT COMMITTEE Adopted by the Board on 9 TH February 2015 CONTENTS Constitution and Purpose... 3 1. Membership... 3 2. Secretary... 4 3. Quorum... 4 4. Frequency of Meetings...
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 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 informationUK Bribery Act: impact on companies and what to expect
UK Bribery Act: impact on companies and what to expect GADENS BRIEFING PAPER OCTOBER 2015 UK Bribery Act: impact on companies and what to expect 1. Introduction what to expect The UK Bribery Act 2010 (the
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. Jesuit Provincial Offices 114 Mount Street London W1K 3AH Index
Jesuit Provincial Offices 114 Mount Street London W1K 3AH 020 7499 0285 www.jesuit.org.uk Anti-bribery policy Index 1. Purpose of the policy 2. Overall approach 3. Policy statements 4. Scope of the policy
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 information