Anti-Corruption Policy
Purpo of the Anti-Corruption Policy
This policy outlines acompanyptable and non-acompanyptable behaviours to ensure compliance with anti-corruption laws,such as the China Anti-corrupt laws,This includes compliance with all laws,domestic and foreign,prohibiting improper payments,gifts or inducements of any kind to and received from any person, including officials in the private or public ctor,customers and suppliers.
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Helpful Definitions
Bribe:Anything of value given in an attempt to affect a person’s actions or decisions in order or to gain or retain a business advantage.Anything of value includes cash,entertainment or other gifts or courtesies.逸乐
Corruption:The misu of a public office or power for private gain or the misu of private power in relation to business outside the realm of government.
可怜的拼音Facilitation payments:Small sums paid to government officials to facilitate or expedite routing. Non-discretionary government actions are considered facilitation payment.
Kickbacks:The return of a sum already paid or due as a reward for awarding of furthering business.
What Does'Anti-Corruption'Mean to You?
Corruption can take place in many types of activities.It usually is designed to obtain financial benefits or other personal gain.For example,bribes are intended to influence behavior–they could be in the form of money,a privilege,an object of value,an advantage,or merely a promi to influence a person in an official or public capacity.Usually,two people are involved and both will benefit.Examples of a bribe include:
北京辅导班Offer or receipt of cash in the form of a kickback,loan,fee or reward
Giving of aid,donations or voting designed to exert improper influence
The areas of business where corruption,including bribery,can most often occur include:
1.Gifts,Entertainment and Hospitality
2.Facilitation Payments
3.Procurement Process
4.Political,Community and Charitable Contributions
1.Gifts,Entertainment and Hospitality
Gifts,entertainment and hospitality are acompanyptable if they are reasonable,proportionate and made in good
大学英语六级听力下载faith and in compliance with our company policies.The activities must be in compliance with our Code of Business Conduct(guiding principle:‘avoiding conflicts of interest’),Customer Entertainment Policy and Corporate Hospitality Guidelines.Although no two situations are the same,the Corporate Hospitality Guidelines define what is usually acompanyptable and what is never acompanyptable.
火锅 英文Examples of gifts,entertainment and hospitality include the receipt or offer of gifts,meals or tokens of appreciation and gratitude,invitations to events,functions,or other social gatherings,in connection with matters related to our business.The activities are acompanyptable provided they fall within reasonable bounds of value and occurrence.
How do you know if an offered gift,entertainment or hospitality is acompanyptable?First,take a step back and ask yourlf the following:
What is the intent–is it to build a relationship or is it something el?
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How would it look if the details were on the front of a newspaper?四六
What if the situation were reverd–would there be a double standard?
If you find it difficult to provide a comfortable answer to one of the above questions,ASK your manager,local Legal Department or the Ethics and Compliance Office.
What to do when you doubt if you can acompanypt?If you are unsure if you should acompanypt something of value–ASK.Ask your manager.If your manager is participating,ek a higher-level manager.If you prefer, ask your local Legal Department or contact the Ethics and Compliance Office.
As a general rule,employees and business partners should not provide gifts or hospitality to,or receive them from,a government or other public official(or their clo families and business associates).You may give a modest gift to the parties when appropriate and allowed by local law provided you discusd it with and received written approval in advance from the legal department.Plea refer to our Code of Business Conduct,“Engaging in Government and Political Activities”which allows political contributions as permitted by law and only when approved in advance by our nior public affairs officer and legal counl.
2.Facilitation Payments
Facilitation payments are not allowed.If you are unsure whether certain payments reprent facilitation payments,plea contact your local Legal Officer,or the Ethics and Compliance Office.
3.Procurement Process
You must follow company process and adhere to the system of internal controls around supplier lection. Supplier lection should never be bad on receipt of a gift,hospitality or payment.When supplier lection is a formal,structured invitation for the supply of products or rvices(often called a‘tender’),it is most important we maintain documentation supporting our internal controls.In the public ctor,such a tender process may be required and determined in detail by law to ensure that such competition for the u of public money is open,fair and free from corruption.
A tender process includes an invitation for other parties to make a proposal,on the understanding that any competition for the relevant contract must be conducted in respon to the tender,no parties having the unfair advantage of parate,prior,clod-door negotiations for the contract where a bidding process is open to all qualified bidders and where the aled bids are in the open for scrutiny and are chon on the basis of price and quality.
4.Political Community and Charitable Contributions
You are not allowed to make political contributions from Company funds without authorization.Political contributions,as permitted by law,must be approved in advance by our nior public affairs officer and legal counl.Importantly,company is not permitted to make political contributions in France,Belgium or Great Britain.
Contributions made by company to community projects or charities need to be made in good faith and in compliance with our Code of Business Conduct,this Anti-Corruption Policy and all relevant company’s policies and procedures.
Books,Records and Internal Control Requirements
Expens must never be hidden or purpofully misclassified.Many rious global bribery and corruption scenarios are found to involve inaccurate record-keeping.To prevent this,international anti-corruption laws generally require detailed and accurate accounting records for transactions,including cash and bank accounts. We must ensure we maintain accurate books,records and financial reporting.
All business units must maintain an effective system of internal control and monitoring of our transactions. Certain monitoring controls are identified in our policies,specifically regarding approval of travel and entertainment expens.It is your responsibility to be knowledgeable of control procedures and ensure compliance.
You Are Responsible
company takes corruption and bribery very riously.Any violation of this policy will be regarded as a rious matter by the Company and is likely to result in disciplinary action,including termination,consistent with local law.
Bribery is a criminal offen.As an employee you will be accountable whether you pay a bribe yourlf or whether you authorize,assist,or conspire with someone el to violate an anti-corruption or anti-bribery law. Punishment for violating the law are against you as an individual and may include imprisonment,probation, mandated community rvice and significant monetary fines which will not be paid by company.
Questions or How to Rai a Concern
If you want to ask a question about the requirements in this policy or are concerned that an anti-corruption violation is occurring or has occurred,report it immediately to one of the following:
Your manager
Your local Legal Department
Ethics and Compliance Office,directly by contacting T.J.Wolfe,VP Compliance&Risk;or email at:
Refer to the Ethics and Compliance website for anonymous reporting procedures.
Policy Ownership
月食 英文This Policy is owned by company’s legal department.Plea contact your local legal department or the Ethics& Compliance Office for any questions,or nd an email to
riouslyThe policies on this site apply to all employees of Huixiang Enterpris and Huixiang Enterpris subsidiaries unless otherwi specified or as required by Federal,National,Country,State or Local law or Collective Bargaining Agreement.
