Anti-Bribery & Corruption Policy
Policy brief & purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that Continental Van Lines, Inc. employees conduct themselves in a socially responsible manner.
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as a reward for action which is illegal or a breach of trust. This includes accepting anything of material value to gain a commercial, contractual, regulatory or personal advantage. Inducements can take the form of gifts, loans, fees, rewards or other advantages (taxes, services, donations, etc.)
It is Continental Van Lines’ code to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and in implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
Scope
In this policy, third party means any individual or organization you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, public bodies, representatives and officials.
This policy applies to all individuals working at all levels, including senior managers, officers, employees, consultants, contractors, trainees, interns, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.
This policy covers:
- Bribes
- Gifts and hospitality
- Facilitation (foreign officials) payments
- Charitable contributions
Bribes
Employees must not engage in any form of bribery, either directly or through any third party.
A person is guilty of ‘bribing’ when the person offers, promises or gives a financial or other advantage to another person, and intends the advantage to induce or reward the other person to perform improperly a relevant function or activity.
A person is guilty of ‘being bribed’ where the person requests, agrees, to receive or accepts a financial or other advantage intending that, in consequence, a relevant function or activity should be performed improperly.
Gifts and Hospitality
Employees must not offer or give any gift or hospitality:
- Which could be regarded as illegal or improper, or which violates the recipient’s policies.
- To any public employee or government officials or representatives, or politicians or political parties.
- Which exceeds $50 in value for each individual or event gift, unless approved by Senior Management.
Employees may not personally accept any gift or hospitality from any business partners. Such gifts shall be accepted and distributed fairly to all staff as per Senior Management approval.
Facilitation payments and kickbacks
Our strict policy is that facilitation payments must not be paid.
Facilitation payments are made from the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage.
Charitable Contributions
Charitable support and donations are acceptable and encouraged; whether they be in-kind services, knowledge, time or direct financial contributions.
However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices.
Record-Keeping
We keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
You must disclose to Senior Management all hospitality or gifts accepted or offered.
All expenses claims relating to hospitality, gifts or expenses incurred to third parties must be documented including specific details of the reason for the expenditure.
All accounts, invoices and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off-book” to facilitate or conceal improper payments.
Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this code, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result or refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Senior Management immediately.
Seeking Advice and Reporting
If you are a victim of bribery or corruption it is important that you inform Senior Management as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
If you suspect or know you are being asked to pay, or are offered a bribe, you must report it to Senior management.
If you wish to report anonymously, for example, if you suspect your manager of paying bribes, you should use your company’s confidential reporting mechanism such as a ‘whistleblower hotline’.
Review:
The above policy and procedures are reviewed for relevance and effectiveness on an annual bases in February or each year. The review is scheduled on the calendar of the FIDI Representative and procedures are updated as necessary.
Supply Chain monitoring is performed at a monthly meeting at Continental International. Agent/Vendor performance is a required topic and minutes are kept of these meetings. Corrective actions, if necessary, are initiated at this time. Corrective action can be in the form of e-mail, telephone call, or in person conversation to discuss the improvement required or the vendor being added to the Unapproved Vendors List.
Disciplinary Consequences
All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.