1.0 – INTRODUCTION
This Anti-Bribery Policy (“Policy”) sets out the guidelines and standards to be followed by Amax Supplies Limited, a business-to-business reseller of goods (“the Company”), and all its employees, contractors, agents, and representatives in relation to bribery and corrupt practices. The Company is committed to conducting its business in an ethical manner and complying with all applicable laws and regulations related to anti-bribery and anti-corruption.
2.0 – SCOPE
This Policy applies to all individuals associated with the Company, including but not limited to employees, directors, officers, contractors, agents, and representatives. It covers all business activities, whether conducted within the Company’s premises or outside, including interactions with customers, suppliers, business partners, government officials, and other third parties.
3.0 – DEFINITIONS
For the purposes of this Policy, the following definitions apply:
3.1. Bribery: Offering, giving, receiving, or soliciting of any item of value, such as money, gifts, favours, or services, with the intent to influence the actions or decisions of an individual or entity in a position of trust.
3.2. Facilitation Payments: Small payments or gifts made to expedite routine administrative actions or processes that individuals are already obligated to perform.
4.0 – COMPLIANCE WITH ANTI-BRIBERY LAWS
The Company and all its employees must comply with all applicable anti-bribery and anti-corruption laws, including but not limited to the laws of the countries in which the Company operates. It is strictly prohibited to engage in any form of bribery, corruption, or facilitation payments.
5.0 – ZERO TOLERANCE FOR BRIBERY
The Company has a zero-tolerance approach to bribery and corrupt practices. No employee or representative of the Company shall directly or indirectly offer, promise, give, request, or accept any bribe, kickback, or inappropriate payment to or from any person or entity, whether in the public or private sector.
6.0 – Gifts, Hospitality, and Expenses
6.1. Gifts and Hospitality: The Company recognizes that the exchange of gifts and hospitality is a common business practice. However, all gifts, hospitality, or other benefits offered or received must be of nominal value, legal, transparent, and intended for legitimate purposes. Any gifts or hospitality exceeding nominal value must be reported to the management for approval.
6.2. Business Expenses: All business expenses incurred must be accurate, legitimate, and supported by appropriate documentation. Employees must ensure that expenses are reasonable and proportionate to the business purpose.
7.0 – DUE DILIGENCE AND THIRD-PARTY RELATIONSHIPS
7.1. Suppliers and Business Partners: The Company will conduct due diligence on all suppliers, business partners, agents, and representatives to ensure they comply with anti-bribery laws and uphold ethical standards. Contracts and agreements with such entities must include anti-bribery and anti-corruption clauses.
7.2. Joint Ventures and Subsidiaries: The Company will ensure that joint venture partners and subsidiaries adhere to the same standards outlined in this Policy and have appropriate anti-bribery controls in place.
8.0 – REPORTING AND WHISTLEBLOWING
8.1. Reporting Suspected Violations: Any employee who suspects or becomes aware of a violation of this Policy must report it to their immediate supervisor or the designated compliance officer. Reports may be made anonymously, and the Company will protect whistleblowers from retaliation.
8.2. Investigation and Remedial Action: Upon receiving a report, the Company will promptly investigate the allegations and take appropriate remedial action if a violation is confirmed. This may include disciplinary action, termination of employment, or legal action.
9.0 – TRAINING AND COMMUNICATION
The Company will provide regular training and awareness programs to employees and relevant stakeholders to ensure they understand the requirements of this Policy, anti-bribery laws, and their obligations. The Policy shall be communicated to all employees and made available to external parties upon request.
10.0 – COMPLIANCE MONITORING AND REVIEW
The Company will regularly review and assess the effectiveness of this Policy, its controls, and procedures to ensure compliance with anti-bribery laws and identify areas for improvement. Changes to the Policy will be communicated to all relevant parties.
CONCLUSION
The Company is committed to preventing bribery, corruption, and unethical practices in all aspects of its business operations. This Policy provides a framework for employees and representatives to uphold high ethical standards and comply with anti-bribery laws. Any breaches of this Policy will not be tolerated and may result in disciplinary and legal action.
By adhering to this Policy, we contribute to a business environment that is fair, transparent, and free from bribery and corruption.
Amax Supplies Ltd
27/06/2023
