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UNIEKART Anti Bribery Policy
ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
Universal Enterprise / Uniekart (“Company”) through the adoption of Anti-Bribery and Anti-Corruption Policy (the “Policy”) is committed to conduct its business in fair and ethical manner and comply with all Applicable Laws and regulations relating to anti Bribery (as defined hereinafter)and anti Corruption (as defined hereinafter) including but not limited to U.S. Foreign Corrupt Practices Act, 1977and the UK Bribery Act 2010, The Prevention of Corruption Act, 1988 and all other applicable anti-Bribery/Corruption laws and subordinate legislations. The Company prohibits bribery and corrupt practices and ensures strict adherence to the Policy.
The expression like “We” used in this Policy refers to the Company.
The Company is committed to conducting its business honestly, fairly and with integrity and highest possible ethical standards. The Company has “zero-tolerance approach” to fraud, Bribery (as defined hereinafter) and corrupt business practices. The Company prevents Bribery (as defined hereinafter) and Corruption (as defined hereinafter) in all parts of its business.
- “Bribery” shall include any act of giving, receiving, soliciting, promising or offering of undue reward or anything of value, directly or indirectly which is given to influence or secure an unfair business advantage, financial or otherwise, which the Company otherwise is not entitled. Bribery do not just involve cash payment but anything of value can be a bribe, including but not limited to Gift in kind, luxury goods, charitable donations, tickets, entertainment, business & employment opportunities or any other favour which influence the behaviour of government or any to do something that is dishonest, illegal or a breach of trust in order to secure improper business or commercial, contractual, regulatory or personal advantage.
- “Corruption” shall include Bribery, facilitation payments or other forms of improper business practices which is the misuse of power or office in the public or private sector for private or commercial gain.
- “Facilitation Payments” shall mean the payment of bribe or enticement to a government or public official to secure or expedite a routine or specific government action by a government official involved under said transaction to which the payer is entitled.
- “Gift” shall mean cash, gift voucher and gift cards payments or other gifts (whether having monetary value or otherwise and shall include travel, entertainment, hospitality, meals and any other items of like nature. However, card, thank you notes, certificates and others forms of thanks and recognition shall not be considered as gift.
- “Third Party” shall mean any individual or organization who has done business with the Company and shall include actual and potential clients, business contacts, intermediaries, agents, advisers and any other person who acts on behalf of the Company.
The purpose of this Policy is to:
- Set out the responsibilities of its employees and the Third Parties to comply with anti-Bribery and anti-Corruption practices adopted by the Company;
- Set out standards of conduct for the prevention of Corruption;
- Set out adequate procedures followed by the Company to prevent Bribery and Corruption;
- To reflect the Company’s best practice measures towards anti-Bribery and anti- Corruption;
- To provide information and guidance including training to employees and other Third Parties to deal with and monitor issues related to Bribery and Corruption.
The Policy is applicable to the Company and all its’ subsidiaries, partners, directors, employees, consultants, agents and other Third Parties or any other person associated with the Company or acting on behalf of the Company.
Each of them has a personal responsibility and obligation to strictly adhere with this Policy and conduct business activities ethically and in compliance with the laws.
4.RESPONSIBILITY AND ACCOUNTABILITY
The top management of the Company is committed to prevent Bribery and is responsible and accountable for the maintenance, implementation and revision of the Policy. Also, the Human Resources Team of the Company should ensure that each employee of the Company is being provided with copy of the policy and is made fully aware of and understand the Policy in letters and in spirit.
Neither any employee nor any person acting on behalf of the Company shall make or accept Facilitation Payments of any kind. Under any circumstances, if such payment is made, the person acting on behalf of the Company should insist on an official receipt. Also, any such concerns or demands should promptly be reported to the higher authority.
6.GIFTS, HOSPITALITY AND ENTERTAINMENT
The Company’s employees shall not offer, give or receive any Gifts or entertainment or other incentives. The Company prohibits any exchange of Gifts for business or for an improper benefit.
The Company has implemented ‘No-Gift Policy’ for its’ employees effective from day one the company started (“No-Gift Policy”). Every employee of the Company and every person acting on behalf of the Company must ensure to strictly adhere to the No- Gift Policy, a copy of which is annexed as Annexure A to this Policy.
7.CHARITABLE DONATIONS AND SPONSERSHIPS
The Company supports charitable donations and sponsorship which serves a legitimate public purpose or is taken as a programme under Corporate Social Responsibility. Any such donations or sponsorship should be transparent and properly documented. The Company prohibits any such donation or sponsorship which is linked to obtaining commercial advantage and improper business purpose. The Company prohibits all cash dealings and subject itself to high standard of transparency and accountability for all such charitable purposes.
The Company does not make contributions to any political parties, organizations, candidates or individuals engaged in politics. Any payment, contribution or participation, directly or indirectly in any political activities for any unlawful and unauthorized purpose is prohibited.
The Company is responsible for acts of Bribery by agents, representatives and any of its Third Parties with which it does business. All Third Parties acting for or on behalf of the Company must comply with all Applicable Laws relating to anti- Bribery and anti-Corruption. The Company takes reasonable steps to ensure that its business partners are made aware of, understand and adhere to this Policy and has adopted appropriate anti-Bribery clause to be included in both vendor and customer contracts through which it obligates them to prevent Bribery and Corruption. In addition, the Company verifies the integrity and reputation of its business partners through appropriate and reasonable due diligence checks.
10.RISK ASSESSMENT AND MONITORING
The Company shall assess the nature and extent of its exposure to potential external and internal risk of Bribery periodically. The Company shall also conduct due diligence to mitigate identified Bribery risk.
The Company keeps a check on compliance risk and the adequate procedures on an ongoing basis and ensures that appropriate system of internal control are in place which includes continuous monitoring and review of the compliances. The
Company ensures to regularly review and update their programmes and processes as required and to monitor and investigate instances of alleged Corruption.
The Company shall maintain proper books, records, and accounts, which accurately and fairly detail the transactions and payments. The Company strictly maintains and follows the internal control and procedures while making payments from the Company.
The Company has taken adequate measures to prevent offering, receiving or extorting bribes by adopting strict procedures and policies. The Company conducts regular anti-Bribery programmes and training which outlines the policies, procedures and internal controls. This policy shall be available on the Company’s intranet for all employees and an e-learning programme shall be conducted to educate the Company towards the approach to Bribery and Corruption and the practices prevalent.
We encourage partners, directors, employees, consultants, agents and other Third Parties to report their concerns in a timely manner and by the appropriate mechanism in case they observe or suspect Bribery within the Company or with the Third Parties to their Reporting Manager and/or Whistle Blower committee at e- mail id- email@example.com immediately and the said committee shall take prompt cognizance and action against such complaints.
Such complaints can be forwarded to CEO/MD of the Company and the Company shall maintain the identity of the complainants confidential, whenever requested.
Compliance with this Policy is mandatory and any non-compliance or breach of the Policy shall not be tolerated and strict disciplinary proceedings including immediate termination of the employment or other civil or criminal action (penalties) as the case may be shall be taken.
15.RAISING CONCERNS & PROTECTION
Any genuine concern in good faith and in true spirit with respect to this Policy to be reported to whistle blower committee of the Company at e-mail id- firstname.lastname@example.org. The Company will ensure that no such reporting person shall suffer any detriment as a result of raising concerns about Bribery, even if the claim or report made in good faith turns out vague of untrue at end.
ANNEXURE-A NO-GIFT POLICY
This policy requires employees to demonstrate the highest standards of ethics and conduct, in relationship to potential vendors, suppliers, and customers. The gift policy ensures that employees practice equal treatment, unbiased professionalism, and non- discriminatory actions in relation to all vendors, and should not accept gifts from them under any circumstances.
COMPANY GIFT POLICY STANDARDS AND REQUIREMENTS:
All employees must abide by the following “NO-GIFT” policy requirements
- No gifts of any kind, that are offered by vendors, suppliers and customers or any other individual or organization, no matter the value, will be accepted by any employee, at any time, on or off the work premises.
- GIFT includes any item like pens, hats, t-shirts, mugs, calendars, bags, key chains, portfolios, perishable items or other sample product.
- This policy includes all vendors or suppliers we work with.
- This policy includes any business courtesy offered such as a product discount or any other benefit if the benefit is not extended to all employees.
- Employees are required to professionally inform vendors and others of this "NO GIFT" policy, and the reasons why the company has adopted the policy.
- If an employee or department receives a gift, it should be returned.
GIFT POLICY EXCEPTIONS:
Gifts exempted from this policy are cards, thank you notes, certificates, or other written forms of thanks and recognition.
Disciplinary action will be taken against any employee, who fails to abide the policy’s standards and requirement.