Eminence VSP Ltd
Last update: on 17th March 2023
Anti-corruption and Bribery Policy
- Eminence VSP Ltd. (“EVSP”, “We” or “Us”) has in place and upholds the policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
- Any employee who breaches our Anti-corruption and Bribery Policy (this “Policy”) will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this Policy may have their contract terminated with immediate effect.
- This Policy does not form part of any employee’s contract of employment.
- We shall review this Policy regularly and may amend it from time to time.
- This Policy applies to all parties (i.e., individuals, body corporate or otherwise) working for Us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
- Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, award of a contract or any other advantage or benefit.
- Bribery includes offering, promising, giving, accepting or seeking a bribe.
- All forms of bribery are strictly prohibited.
- In any event, you must not:
- give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
- accept any offer from a third party that you know or suspect is made with the expectation that We will provide any business advantage for them or anyone else; or
- give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
- You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
Gifts And Hospitality
- This Policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products or services.
- A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment, for instance, during contractual negotiations or a tender process.
- Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent such as vouchers, or be given in secret. Gifts must be given in our name, not your name.
- Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers or business partners.
- You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
- All accounts, invoices, and other records relating to dealings with third parties including customers, suppliers and business partners should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
- If you are unsure about whether a particular act constitutes bribery, or if you are offered a bribe or asked to make one, or if you suspect that any bribery, corruption or other breach of this Policy has occurred or may occur, you must immediately report to your line manager.
- If the report required under section 6.1 above concerns your line manager, you must report to our Founder/ CEO at email@example.com as soon as possible.