COMPLIANCE WITH LAWS, RULES AND REGULATIONS
It is the Company’s policy to act in full accordance with all USA and foreign laws, rules and regulations applicable to it or the conduct of its business wherever located. Violation of laws, rules or regulations or compromise of the Corporation’s ethical expectations could result in written reprimands or other disciplinary action, including termination and criminal or civil legal proceedings where applicable.
The Company is committed to the principles of fair competition in the purchase and sale of products and services. All purchasing decisions are to be based on normal commercial considerations, including quality, price, availability, service, HSE and other specific factors regarding the product or service. The Company will not seek, encourage nor tolerate special favors or arrangements that impact normal commercial relationships.
ANTI CORRUPTION AND BRIBERY
The Company has a fundamental commitment to comply with all laws (domestic and foreign) governing our global business. This commitment includes conforming to laws such as United States Foreign Corrupt Practices Act.
The Company prohibits bribery and corruption in all forms, whether direct or indirect. This includes the offering of anything of value to employees of government or government controlled entities for the purpose of improperly influencing their acts or decisions.
USA BRIBERY ACT & FOREIGN CORRUPT PRACTICES ACT (“FCPA”)
The USA Bribery Act prohibits improper payments to government officials and to others who are not government officials. The FCPA is a U.S. law that prohibits offering, giving or promising to give anything of value to a non-U.S. government official to obtain or retain business, or obtain any improper business advantage. It is the policy of the Company that all directors, officers, employees and others who represent the Company comply with the FCPA, and that we keep accurate records of all transactions involving government officials, regardless of the amount involved.
Foreign officials are defined as:
• Any officer, employee or other person acting for, or on behalf of, a “public international organization” (such as the World Bank, the International Monetary Fund, or the Inter-American Development Bank)
• Any person acting in an official capacity or on behalf of any such government or governmental department (including government-owned companies, such as national oil companies, or NOC’s)
• Any officer or employee of a government.
Under anti-bribery rules, excessive hospitality including travel, lodging, meals or entertainment can also be considered a bribe. Directors, officers or employees should always consult the Company policy or contact the Legal Department before giving any form of gift to a government official. Under anti-bribery rules, excessive hospitality including travel, lodging, meals or entertainment can also be considered a bribe. Directors, officers or employees should always consult the Company policy or contact the Legal Department before giving any form of gift to a government official.
AGENTS
The Company periodically engages the services of Agents who may interact with customers and vendors on the Company’s behalf. Illegal or improper actions of Agents can have serious and detrimental consequences for the Company and it is therefore essential that Agents understand and comply with the requirements in this policy and all applicable laws. Before an Agent can perform any services for the Company, the Agent must, as necessary:
• Undergo a due diligence background.
• Sign a written agreement which includes standard requirements relating to USA anti-Bribery and FCPA compliance.
IMPORT/EXPORT CONTROLS
The Company requires compliance with all applicable import and export control laws and regulations of country in which the company conducts its business.
FAIR TRADING
The Company is committed to deal fairly with our customers, suppliers, competitors and employees. Although the Company is committed to compete aggressively in our business activities, we seek to succeed over our competitors honestly and fairly through hard work and having the highest quality of equipment and most professionally trained personnel and never through illegal or unethical business practices. The company must never use any unfair practices to take an achieve an advantage.
MONEY LAUNDERING
The Company prohibits business with any known criminal or criminal organization or and including making payments for furtherance of illegal activities such as money laundering and commercial bribery.
ANTI-TERRORISM
The Company will never knowingly participate in activities that directly or indirectly aid in criminal or terrorist activities around the world. This includes never knowingly buy or sell technology or goods that will be used for purposes associated with the manufacture of chemical, biological or nuclear weapons or missiles.