Purpose

The purpose of this policy is to clearly define the company's approach to legal compliance and anti-corruption. It aims to protect the company's image and ensure compliance with anti-bribery and anti-corruption laws, as well as ethical, professional, and universal standards. This policy provides the necessary information to prevent corruption in all company activities and outlines the responsibilities and rules in this regard.

Scope

The Anti-Corruption and Legal Compliance Policy covers not only company employees but also all business partners who provide services to the company. This includes:

All company employees

Employees of companies providing support services (e.g., consultants, lawyers)

Employees of companies providing outsourced services (e.g., suppliers, subcontractors)

Authority and Responsibilities

Senior Management is responsible for the creation, implementation, and maintenance of this policy. Managers must ensure that the principles within this policy are understood, implemented, and upheld by the business partners they are responsible for and the employees under their supervision. All employees and business partners must act in accordance with the principles of this policy. Under no circumstances can employees or business partners be forced to act contrary to this policy. It is everyone's responsibility to report any situation that violates legal compliance and anti-corruption rules.

Policy

Our company is committed to complying with all legal and anti-corruption laws and regulations, universal legal rules, and ethical and professional principles in all the cities and countries where it operates and is represented. We adopt a "zero tolerance" approach within this principle and commit to conducting our activities fairly, honestly, and in compliance with the law.

It is strictly forbidden to offer payments or anything of value to gain an illegal or unethical advantage, even if it benefits the company, or to accept similar benefits from other organizations or individuals. Any behavior that could be considered bribery or corruption is prohibited, even if such practices are common in the country or business sector where the activity takes place. The monetary value of the corrupt benefit or whether anything is done in return is irrelevant. Even if the value of the benefit is very low or the promised action has not yet been carried out, acting in this manner is a violation of this policy.

It is forbidden to make any payments to facilitate or expedite any work. Employees should not tolerate or allow a third party to offer, promise, ask for, demand, give, or accept such things in their dealings. Unless explicit approval is granted (specific or general for a certain level of gift/hospitality), offering, promising, or giving gifts, hospitality, or other benefits, directly or indirectly, to foreign or domestic, government, or private sector employees is not allowed.

Encountering or Suspecting Corruption

All company employees are responsible for immediately reporting any situation they encounter or suspect regarding bribery and corruption to their manager. Examples of such situations include:

Being offered a bribe.

Witnessing or knowing of improper benefit relationships or conflicts of interest.

Any irregularities you notice in company records.

Favoritism or benefit-seeking behaviors you encounter in tenders and procurements.

Providing a benefit to any customer or supplier in a manner that is contrary to legal regulations.

Any institution or person, from within or outside the company, forcing you or your colleagues to act in a manner contrary to the policy.

Sanctions for Inappropriate Behavior and Conduct

Our Anti-Corruption and Legal Compliance Policy must be adopted and implemented by all employees. It should be noted that a violation of this policy can lead to sanctions, including the termination of the employment contract in accordance with internal company regulations, and that in many countries, such actions are subject to significant penalties, including imprisonment.

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