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Some of the guidelines are designed to prevent situations in which bribery and corrupt practices may take root. 6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. 4 0 obj x�͘�n1��+�;��E�03���cBK)��B*9Tx�مC�dIAۡ9Dr��{����۶A��S���\9|�n�wO�Y�m��9� They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. <>
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What are bribery, corruption and influence peddling? (�� (�� “Corruption” is the … Lion Group’s Code of Business Ethics & Conduct (S19A) and Employee Code of Conduct (S19B) set out the Group’s core principles in this regard. d�g^���%-���I�h O-H�V���Z�RS��E����i*�T.��A ANTI-BRIBERY AND CORRUPTION POLICY 1. In general the BBA guidance refers to the concept of ‘bribery’. (�� 10 0 obj
This Policy also serves as an enhancement on IWK’s current efforts in mitigating the governance weaknesses and integrity breaches. You’re right to be concerned. (�� 1013 The CIMB Group Anti-Bribery and Corruption Policy sets out the guiding principles for CIMB to address and managebribery and corruption risks in all its dealings and related issues that may arise in the course of business. (c) A business advantage means that Ascendant is placed in a better position (�� 4. The FCPA and the UK Bribery Act encourage regulated organizations to implement anti-corruption programs. 4 GROUP ANTI-BRIBERY AND CORRUPTION POLICY Ref. e stream This policy provides … stream
8. 2 0 obj Bribery and corruption can take many forms including cash or gifts to an individual or family members or associates, inflated commissions, fake consultancy agreements, unauthorized rebates, non-monetary favours and false political or charitable donations. ���ڱx8�����Z@�.^�s�ZL��/�^'�� <0;�O&��K��:�. As such, the Company strongly opposes any practice that improperly or illegally disrupts proper business conduct. WHAT IS BRIBERY AND CORRUPTION Bribery is defined as an act of offering, giving, agreeing to give, receiving or soliciting something of monetary or non-monetary value in an attempt to illicitly influence the decisions or actions of a person �b�)�W��Et붳֙{n���@���pO�a�^�sn�͟ �Wk&V�61X��9���V7��/��=��L�����lw��b�p۬�^=�W�ۯ'���:���f]ɜ���[�)[d�tg�d2��$�b& ��H ������T8ϩ;�}�A#�2>�����/&h'�iƦ�$�m�qݔ��u� �2��31�Y;��[1I�mJHD &~�e0lj����U��5�
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anti-bribery and corruption information you are given. 5.1 Corruption is the abuse of public or private office for personal gain. 2.1 The objective of the Anti-Bribery and Corruption Policy (“the policy”) is to establish clear, practical, accessible, and enforceable procedures to prevent, detect, and report bribery and corruption incidents, whether accidental or intentional in the course of carrying out our business. Use of the words ‘bribery and corruption’ simultaneously reflect FCA regulatory obligations, which require banks to have in place adequate systems and controls to prevent both bribery and corruption. endobj
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ANTI-BRIBERY & CORRUPTION POLICY 3 (a) A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or business or personal advantage. (�� WRITTEN BY EXPERTS, READ BY EXPERTS Corruption– WORLD The Don’t Pay Medicines TODAY Volume 57 Number 6 JUNE 2001 £2.50 $4.50 for all China: Nationalism The Internet Taiwan BRIBERY AND PETTY CORRUPTION John Bray Don’t Pay Are all informal payments to a small thing. (�� Integrated Management System F05 Anti-fraud, Bribery and Corruption Policy Version: 2.0 Date: April 2020 Page 5 of 8 Definitions Fraud is knowingly making an untrue or misleading representation or failing to disclose information with the intention of making a gain for oneself or … INTRODUCTION 1.1 Corruption is the single greatest obstacle to economic and social development around the world. Bribery and corruption is a major global issue, causing damage to societies and individuals worldwide. << /ProcSet [ /PDF /Text /ImageB /ImageC /ImageI ] /ColorSpace << /Cs1 9 0 R (�� <>
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corruption that may be faced in the course of its operations; and • To provide information and guidance on how to recognise and deal with potential acts of bribery and corruption. {�M2y�M���MRqQ�D�QPu�P��Zm��I�jq�� BPAM’s Anti-Bribery and Corruption Policy (hereinafter referred to as the “Policy”) elaborate upon those principles, providing guidance to employees concerning how to deal with improper solicitation, bribery and other corrupt activities and issues that may arise in the course of business. endobj
�b��3-~����}M��k�B�eN��&� >> /Font << /TT3 12 0 R /TT4 13 0 R /TT2 11 0 R >> /XObject << /Im2 14 0 R Corruption continues to corrode the global economy, 18 years after member governments of the Organization for Economic Co-operation and Development (OECD) signed a convention. BRIBERY, FRAUD & CORRUPTION Between the Foreign Corrupt Practices Act, the UK Bribery Act, other local acts and international conventions, bribery, fraud and corruption are heavily regulated areas — and likely top of mind when it comes to your compliance program. (�� It undermines democracy and the rule of law, leads to violations of human rights, distorts markets, erodes quality of life and allows organised crime, terrorism and other threats to human security to ��(�� endstream 14 0 obj (�� (�� true /ColorSpace 9 0 R /Intent /Perceptual /SMask 16 0 R /BitsPerComponent 6 0 obj
endobj He points to the recent Foreign Bribery Report of the OECD 6 which highlighted that more than three quarters of the 427 corruption cases analysed, involved third parties. 6 0 obj ڐ�)l?�����A�z��M~�Ot�~ 5 0 obj
x�X�nG��WTn�ôz_r��C��``��m�ZH)@�>��YH��!%B�z���^m]��w�'�Q#��I^�� • Harness the efforts of the full staff. (�� (�� (�� +#Y֎�. | … to anti-bribery and corruption. Policy on Anti-bribery & Anti-corruption Revision no. 5. ]c\RbKSTQ�� C''Q6.6QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ�� s^" �� ANTI-BRIBERY AND CORRUPTION POLICY 8.1 Bribery and corruption in all its forms as it relates to MRCB’s activities is prohibited. “Clearly, a lot more needs to be done to manage third-party risk throughout the whole life cycle of the business Anti-Bribery & Corruption Policy Version 1.0 Effective Date:28-05-2020 5 Introduction This document is issued pursuant to subsection (5) of section 17A of the Malaysian Anti-Corruption Commission Act 2009 (Act 694) (“MACC Act 2009”), as stated in the Malaysian Anti-Corruption Commission (Amendment) Act 2018 (“Amendment Act 2018”). 8 /Filter /FlateDecode >> (�� 4 0 obj
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(�� This reflects the legal requirements as defined in the UK Bribery Act 2010. (�� INTRODUCTION RAM Holdings Berhad and its subsidiary companies (collective termed as “RAM Group” or “RAM”) have adopted a zero-tolerance policy against all forms of bribery and corruption. conducting business with zero tolerance of any forms of bribery and corruption. Some of the guidelines are They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. regarding bribery and corruption. Some of the guidelines are designed to prevent situations in which bribery and corrupt practices may take root. (�� �c�#C`*����%ವ�� �Ԥ��B �SDIɂ2SP�ͶS������y꿤!�~�������ۛ�"�������7�XS�QŚ�T)-�=)vp���?�����H�e �uC�����Nyav�}�}�ۣQ����FX�^�D��/G�e"���OPB��A����4�+��a�,����IDH|�t��/����|vUWs]Xbg8�
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This means avoiding practices of bribery and corruption of all forms in MPay’s daily operations. 1. that establishes legally binding standards to criminalize the bribery of public officials. anti-bribery and corruption information he/ she is given. (�� (�� (�� All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. �F-U!R���#��i��8a�0�4f���A�c1u`�sAR�*[d��ȱ�Ey��c�ꐍ����3(�2���^����7фM�zԓ�4����&P�#�=��Oĕ�����$3a�`^a���p[q� 2�Jˑ����%
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corruption within the Group without fear of retaliation or reprisal; and (i) promotes a culture of integrity by conducting an awareness programme for all our employees on the Group’s standing with regards to anti-bribery and corruption. /Im1 7 0 R >> >> 7 0 obj
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Bribery Act , 34 J. Int'l L. 901 (2014). These policies and procedures have been designed to comply with legislation governing bribery and corruption on a global basis. It reiterates our commitment to full compliance by our employees and associated person with the Malaysian Anti -Corruption Rather, they are intended to provide employees with a basic introduction to how PETRONAS combats bribery and corruption in furtherance of the group’s commitment to lawful and ethical behavior at all times. 2 0 obj
(�� bribery and corruption is allocating responsibility for the task and assigning sufficient resources. (�� A “bribe” is anything of value that is offered, promised, given or received by any party to influence a decision or to gain or reward an improper or unfair advantage for the benefit of the Organization or any other party. (�� 5.2 A bribe is an inducement or reward offered, promised or provided, directly or indirectly, to a government official or a participant in a private commercial transaction in order to gain any endobj
Definition of bribery and corruption 4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or of an advantage so to induce or influence an action or decision. RK0� �c &G�!��F���� 9 0 obj
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1.2 Bribery and corruption compromises business ethics and damages an organization’s reputation. (�� ��O����}���{���m��e'�Vv_c�f,��ˍ5��zŤ�TW�"~�@�'���D���c^��5�ۘ{��-��E²W;'��4V�i�%L�'��I���1�� �KW@�^��1���v������˔naw. stream Rather, they are intended to provide employees with a basic introduction to how PETRONAS combats bribery and corruption in furtherance of the group‟s commitment to lawful and ethical behavior at all times. (�� Associated Person Observe and uphold HLBG’s zero-tolerance position on corruption and bribery; Observe the ABC Policy; &W�Б`�o���@�)��m�e� 8.2 Bribery and corruption may take the form of anything of value, such as money, goods, services, property, privilege, employment position or preferential treatment. endobj
the anti-bribery and corruption compliance program, as well as the coordination and monitoring of the implementation of the ABC Policy, taking into consideration the Bank’s risk assessment in relation to corruption/bribery. ANTI-BRIBERY AND CORRUPTION COMMITMENT MPay is committed to conducting business dealings with integrity, honesty and respect. endobj �?I�6 ����R������ޘVo�0�(2�z��d:f0���l��# ��a�*��Zm��|,�m˓�� � << /Length 5 0 R /Filter /FlateDecode >> <>
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