iv. (�� You’re right to be concerned. (�� ���ڱx8�����Z@�.^�s�ZL��/�^'�� <0;�O&��K��:�. Associated Person Observe and uphold HLBG’s zero-tolerance position on corruption and bribery; Observe the ABC Policy; �� � w !1AQaq"2�B���� #3R�br� %&'()*456789:CDEFGHIJSTUVWXYZcdefghijstuvwxyz��������������������������������������������������������������������������� (�� d�g^���%-���I�h O-H�V���Z�RS��޷E����i*�T.��A �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� .�BW8��ZͦP��r���w endstream 4 GROUP ANTI-BRIBERY AND CORRUPTION POLICY Ref. endobj (�� Policy on Anti-bribery & Anti-corruption Revision no. ANTI-BRIBERY AND CORRUPTION POLICY 1. endobj �b��3-~����}M��k�B�eN��&� Some of the guidelines are designed to prevent situations in which bribery and corrupt practices may take root. (�� Nowadays business is becoming increasingly exposed to the many threats and dangers associated with corruption. (�� stream +#Y֎�. conducting business with zero tolerance of any forms of bribery and corruption. << /Length 5 0 R /Filter /FlateDecode >> !(!0*21/*.-4;K@48G9-.BYBGNPTUT3? MPay has adopted a zero-tolerance approach against all forms of bribery and corruption. (�� 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. bribery and corruption is allocating responsibility for the task and assigning sufficient resources. (b) An inducement is something which helps to bring about an action or desired result. endobj endobj 5. 8. endobj ��f7�]1��������҆�+��l��m�n�l7簸(�(;�GV�g�mz���X�uV�u��0�kv�v�y�?��e��I�ߨdV3d�W���ݴFqi����+,%0|�F��`��}�$���v�-u�w�v�a�s�+���u�ִ�L����C��e�E��si��Vͨd���ڢ�'ϵ�}N���x�B`��띞*FI�v�)�����"����_�T�s�?�R���^:��K��6��T ,�fV-�)F�E�Y�%����^DIV��};7��e܊1�՝�N����U�+�)��;�K]T��]D�/j�^߳?�XO�Z�k�1�*��n����i��+�̞Q�Ck�L��E��W&F�M�N1F;誈.u۩_��y[gq�����^ͣ_Q�{b����?�����w� w�"�~C�����>�"��%X7�ëZ�u^�\b�����C��S&&�#z��E�]�No~]���|*���!�_Ŭg_�T�&��.��x��������������|����,%�YSS�=�1�)Xf�ĶV��)�c���P\i�����P|ذ�}C�!�!��!Y� �+�� �~x�� (�� 4 0 obj 1塬�s/S��ݶ�=���j� KW��_��6�n� ښ��h����?�� ���8��%�c�M�}���{���m��eg��.�n�ï�����"�V���C���_Aƫ������&S�e��a�E�Cߣ!�^�D�aۢ a�V�3�[-����!�]�~�K �xk0�+8l��`l�a�E�Cߣ!�^�D�aۢ a�V�3,Z-&;�~� sc��ʔ76�ؓ@�'��``&p�������̋d��GC̽L��öE²W+��c�š�jY#d�*��n��ԝZf)f!� Targeting Corruption in India: How India Can Bolster Its Domestic Anticorruption Efforts Using Principles of the FCPA and the U.K. A bribe refers to any In general the BBA guidance refers to the concept of ‘bribery’. (�� (�� 3 0 obj (�� << /Type /Page /Parent 3 0 R /Resources 6 0 R /Contents 4 0 R /MediaBox [0 0 595 842] “Clearly, a lot more needs to be done to manage third-party risk throughout the whole life cycle of the business 5 0 obj �� � } !1AQa"q2���#B��R��$3br� By Elisa Solomon Lord, N. and Doig, A. <> endobj anti-bribery and corruption information you are given. �?I�6 ����R������ޘVo�0�(2�z��d:f0���l��# ��a�*��Zm��|,�m˓�� � 8 0 obj If you have any doubt about the scope of applicable laws or the application of the group’s policies 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. (�� (�� (�� (�� <> ���� JFIF x x �� C (�� (�� (�� • Harness the efforts of the full staff. 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. This anti-bribery and corruption policy sets out Informa’s policies to prevent acts of bribery and corruption. “Corruption” is the … 5.1 Corruption is the abuse of public or private office for personal gain. <> 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. endobj 5 0 obj (�� 14 0 obj | … 2 0 obj 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. 8 /Filter /FlateDecode >> endobj stream ��O����}���{���m��e'�Vv_c�f,��ˍ5��zŤ�TW�"~�@�'���D���c^܎��5�ۘ{��-��E²W;'��4V�i�%L�'��I���1�� �KW@�^��1���v˜������˔naw. 1. that establishes legally binding standards to criminalize the bribery of public officials. (�� (�� (�� endobj ANTI-BRIBERY AND CORRUPTION POLICY Effective Date 1st Revision 2 January 2020 - 3 1.0 INTRODUCTION Lion Group has adopted a zero tolerance policy against all forms of bribery, fraud and corruption. 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. %PDF-1.3 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. stream <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S>> ANTI-BRIBERY AND CORRUPTION COMMITMENT MPay is committed to conducting business dealings with integrity, honesty and respect. ]c\RbKSTQ�� C''Q6.6QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ�� s^" �� (�� ڐ�)l?�����A�z��M~�Ot�~ 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. 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