In 2008, the government merged the korea independent commission. Align human rights and anticorruption policy commitments. For additional guidance regarding contractors and other third parties, please refer to the section on fedex representatives below. Tarkett anticorruption policy drafted by group legal department and division legal directors corruption risks today, businesses are under great pressure to have processes in place to deter, detect and prosecute corruption. The anticorruption laws apply for all government officials with no exception, as well as, to the business partners. The purpose of this antibribery and anticorruption policy is to reiterate barricks commitment to full compliance by the company, its subsidiaries and affiliates, and its officers, directors, employees and agents with canadas corruption of foreign public officials act cfpoa, the. Unicredit to combine resources in order to achieve common goal. Foreign corrupt practices act fcpa, the uk bribery act and similar anticorruption laws worldwide and b more broadly, reinforce our intention and obligation to act honestly and ethically in all of our business dealings.
This global anticorruption compliance policy the policy represents a part of. Combining the probability and potential impact assessments for each. This policy, updated in 2015, is straight forwardthe company prohibits offering or receiving bribes or. Employees who act contrary to this policy are subject to discipline, which could include termination as well as possible legal proceedings and penalties. While there is no single best practice, experience has shown that anticorruption strategies are very likely to fail if they are not based on a countrys own. It is the policy of arcelormittal and its subsidiaries and affiliates to comply with anti. Make known its abc policy and business principles to contractors, agents, intermediaries, suppliers, joint venture partners and other business partners and expect compliance from them. The barloworld policy on antibribery and corruption 1. This anticorruption policy applies globally to all employees of norma group. Designing and implementing anticorruption policies coe. We will uphold all laws relevant to countering bribery and corruption. Anticorruption and bribery policy university of bristol.
Manpowergroup and its subsidiaries and affiliates worldwide are committed to conducting our business with honesty, integrity, trustworthiness, and accountability. Despite the general favorable data and the large improvements in the last years, many problems and. It replaces the existing version of the antibribery policy dated july 1, 2016. Corruption continues to corrode the global economy, 18 years after member governments of the organization for economic cooperation and development oecd signed a convention. The attitude in general terms of the consecutive polish governments to corruption was also monitored. This policy explains our individual responsibility in complying with antibribery or anticorruption laws around the world and ensuring that any third parties that we engage to act on our behalf, do the same.
The anticorruption policy is an expression of our commitment to the fight against bribery and corruption. In this publication we would like to propose both theoretical and practical material, making use of acquired theoretical knowledge as well as familiar. Repsol will not tolerate any retaliation against anyone who in good faith asks questions or makes a report of actions that may be inconsistent with this policy. Gemma aiolfi, legal counsel integrity, abb asea brown boveri ltd. You may not offer or give or promise anything of value to a government official with the intent to obtain or retain any business or any other advantage. Companies must proactively investigate potential corrupt practices. This document describes spoks policies and procedures designed to prevent corruption in any location in which spok conducts business around the world. Pdf corruption and anticorruption policies in korea. Anticorruption policy 1 introduction bmc is committed to conducting its business in an honest and ethical manner and in compliance with all applicable laws and regulations, including anticorruption, antibribery and antimoney laundering laws such. Antibribery and corruption policy modern times group. The investigations team reports on data and trends and educates employees through case studies. Microsoft corporation, and all of its subsidiaries and joint ventures worldwide microsoft, requires its channel partners for example, resellers, software advisors, original equipment manufacturers, and distributors, suppliers, vendors, consultants, lobbyists, and any other thirdparty. Arcelormittal code of business conduct and these anticorruption guidelines. Introducing anticorruption policies in companies transparency.
A signature page is added automatically by the edms as the last page. European unions anticorruption policy, outlined in article 29 of the treaty on. Policy document grc 004 global anti bribery and corruption revision 01 april 2011 page 3 of 7 1. A document like this should outline a state anti corruption policy whose implementation should lead to the creation of a durable system of anticorruption safeguards. The anticorruption program of the stefan batory foundation was monitoring the anticorruption strategy implementation from the very beginning. The purpose of this anticorruption policy the policy is to help ensure compliance by freeportmcmoran inc. Corporate antibribery policy 1 antibribery policy statement bribery is both a criminal offence and bad business. Wherever permitted by local law and applicable labor agreements, all salaried associates must certify annually as part of their certification as to the danaher standards of conduct that they have complied with danahers policies relating to antibribery and anticorruption.
Linking human rights and anticorruption compliance deutsches. If the investigation uncovers violations of policy or law, the company takes appropriate remedial action, including discipline of employees and sanctions or removal of partners or vendors. Under the bribery act 2010, bribery is widely defined. We take a zerotolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to. Yet anticorruption policymaking has taken different shapes and forms and been implemented in a variety of ways, with mixed results. They are required to avoid any activities that could lead to, or imply, a. Since then, a growing number of governments have passed antibribery and. Anticorruption policy for microsoft representatives. The principles in this policy apply to both internal and external audiences. Anticorruption policy scope cognizant is subject to various anticorruption laws, including the u. The objective of our anticorruption policy is to ensure that appropriate anticorruption and bribery procedures are in place across the globe to avoid any violations of relevant laws and regulations, including, among others, the u. A company should have guidelines for managing corruption risk in its merger and. The university takes a zerotolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships wherever the.
Anticorruption policy oando recognizes the principles of fairness, integrity and transparency in all its business dealings as entrenched in our code of business conduct and ethics. Fcx and its affiliates the company with applicable global anticorruption laws. This policy focuses on anticorruption laws, including the u. A transaction involving millicom and at least one other company, such as a merger, acquisition. Foreign corrupt practices act, the uk bribery act 2010, the india prevention of corruption act, and other laws that apply in the various jurisdictions where we do business. Our reputation is based on trust we have earned from the people we work with and the customers we serve. Justification why a company needs and wants to adopt anticorruption policy. Anticorruption compliance procedures, which, together with this policy, comprise the manual, and are applicable to the company and all company personnel referred to as anticorruption procedures or procedures. This antibribery and corruption policy establishes principles that must govern our conduct in order to. Your company must do all they can to ensure risks of bribery and corruption are kept to an absolute minimum. As a result, it is now possible to evaluate the effectiveness of the anticorruption policy of.
Anticorruption policy franklin templeton investments. Group companies which merge with or acquire other companies run the risk of. Our antibribery and corruption policy policy forms part of asxs risk management framework, which includes asxs enterprise risk management policy, asxs risk appetite statement and other associated risk and compliance policies. Not only can individuals be guilty of an offence but a company can be prosecuted if it fails to prevent bribery, whether in the uk or overseas.
Compliance, integrity and anticorruption policy adopted by the board on 4 february 2016 with entry into force as of 22 february 2016. The purpose of this policy is to establish controls to ensure compliance with all applicable antibribery and corruption regulations, and to ensure that the organizations business is conducted in a socially responsible manner. Purpose the purpose of this policy is to state the bsigroups position on bribery and corruption and to provide information and guidance on recognising and dealing with bribery and corruption. Bribing to a government official or business partner, no matter hisher position, shall be a violation of the anticorruption laws or to these policies. Dealing with public officials including gifts tofrom public officials while it is the policy of nyu to prohibit the provision of improper payments or other benefits to all individuals in both the private and public sectors, interactions with public officials are of heightened concern due to the increased risk for violations of applicable antibribery laws. Expert seminar anticorruption policy and integrity training held in vilnius, lithuania on 23 25 march 2011 organised by the oecd anticorruption network for eastern europe and central asia coorganised by the office of the coordinator of osce economic and environmental activities and 2011 lithuanian osce chairmanship. Anticorruption policy the use of company funds, assets, or personnel for any unlawful, improper, or unethical purpose is strictly prohibited. Antibribery and corruption policy the strict rules and regulations in many countries. This policy cancels and replaces the previous version of anticorruption global policy. Statement on anticorruption and antibribery criminal activity has no place at bmo. This global anticorruption policy applies to every officer, director, employee, and representative of fedex, our subsidiaries and affiliated companies. Antibribery and anticorruption policy unicredit group.
109 389 483 224 914 563 1262 1125 588 277 586 1266 672 732 437 892 235 1604 1161 195 1563 917 1089 1203 223 325 1650 1408 72 474 390 1505 1272 1275 396 543 88 751 930 980 1037