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Elanders Anti-Corruption, Anti-Fraud and Anti-Money Laundering Policy

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Elanders Anti-Corruption, Anti-Fraud and Anti-Money Laundering Policy SEPTEMBER 2019 ANTI-CORRUPTION, ANTI-FRAUD AND ANTI-MONEY LAUNDERING POLICY CONTENTSANTI-CORRUPTION, ANTI-FRAUD AND ANTI-MONEY LAUNDERING POLICY INTRODUCTION advantage to perform their responsibilities im- Since its founding, Elanders has a long-standing properly and/ or to influence the decision making commitment to govern and conduct its busi- in different ways. ness by integrity, honesty, fair dealing and full compliance with all applicable laws and regula- Bribes can take many different forms, such as: tions. We do not participate in or endorse any corrupt practices and within our business, there • money (or other cash equivalent such as is zero-tolerance for any types of fraud, bribes, shares), for example; money is given to ensure facilitation payments or other improper benefits being awarded a contract contrary to this policy, local laws and regula- • unreasonable gifts, entertainment, travel tions, industry standards or ethical codes in the or unjustified allowances or expenses, for countries in which we operate. example; giving a luxury handbag or other The purpose of this policy is to describe the gifts to customs official to convince her/him to forms that corruption and fraud takes and to permit clearance of items provide guidelines of how to handle situations • unjustified rebates or excessive commissions, involving corruption and fraud. We expect that for example; a commission payment of 25% Elanders’ employees in all their operations, un- of transaction value is being asked for buying derstand and comply with this Anti-Corruption, land for a new facility through the real estate Anti-Fraud and Anti-Money Laundering Policy, brokers’ connection to the local government and follow the national laws in the countries • kickbacks, such as a supplier who agrees to where we operate. pay a purchasing manager some amount “Elanders”, hereinafter refers to full and of money in exchange for the award part-time employees, temporary workers, senior of a supply contract by that manager. Other managers and Board of directors of Elanders examples could be rental agreements and Group companies, subsidiaries and those who sale of fixed assets, where the payments for works on Elanders’ behalf, which includes sup- these might not be market value in exchange pliers and vendors, agents, consultants and other for a kickback to the manager third parties. • facilitation payments, like for example a In the unlikely event of a conflict between the payment is made in order to speed up customs law and this policy, the law shall be followed and clearance the conflict must be reported to Elanders Group. • inappropriate donations seeking to lead to specific benefits WHAT IS CORRUPTION AND BRIBERY? • usage of company services or facilities without Corruption is defined as the abuse of someone’s reimbursement entrusted power often for private gain which • other things of value, such as certain benefits also includes the situation where someone is without a financial value, e.g. memberships in abusing its entrusted power for group benefit or clubs, prestigious awards or similar. advantage. Corruption includes a wide variety of behav- In most of the times, common sense will deter- iours, including bribery, fraud, embezzlement, mine if a bribe is being offered or not. In doubt conflicts of interest and misuse of company the following questions could be used as a help: assets. Corruption is often hidden, non-transpar- ent, and may involve a select group of people. • Am I being asked to pay something or Bribery is defined as the offering, giving, provide any benefit over and above the cost promising, authorizing, soliciting or accepting of the services being performed, such as an of something of value to/by another person or excessive commission, an unreasonable gift or entity, either directly or through a third party in a kickback? exchange for an aim to encourage or reward the • Am I being asked to pay for services to a receiver for a particular action, favour, benefit, different individual than the service provider? 2 ANTI-CORRUPTION, ANTI-FRAUD AND ANTI-MONEY LAUNDERING POLICY • Are the hospitality, entertainment or gifts FACILITATION PAYMENT I am giving or receiving reasonable and Facilitation payments are payments, no justified? Would I be embarrassed to disclose matter how small, given to an official to them? When a payment or other benefit is secure or increase the speed at which they being offered or received, do I know or do their job. Examples are: suspect the reason behind is to encourage or recompense for favourable treatment, to • a payment to clear goods through customs change the normal way of decision-making • a payment to allow entry/exit to/from a process or to persuade an individual to do country when all documentation is in order something that is inappropriate regarding • a payment to prevent delay of an order performance of their job? • a payment to get some kind of benefit, e.g. a tax refund or benefit; and Elanders do not tolerate bribery or any other • a payment made in order to get a specific form of corrupt behaviour. We must never, di- permit which is part of the official normal rectly or indirectly through intermediaries, offer duties. or promise any personal or improper financial or other advantage from a third party nor accept All facilitation payments are generally prohibited any such advantage in return for any preferential even if such procedures are accepted or common treatment of a third party. Furthermore, we must practice locally. If you have any questions or if refrain from any activity or behaviour that could you are being asked to pay facilitation payments give rise to the appearance or suspicion of such please contact Elanders Group. conduct or the attempt thereof. This may not only entail disciplinary sanctions but also may THIRD PARTY result in criminal charges. You must not involve any third party in brib- ery or reasonably suspect of being engaged in GIFT, MEALS AND ENTERTAINMENT bribery. Giving or receiving gifts, meals and entertain- Appropriate due diligence should be carried ment could be a significant part of maintaining out before any contract with third parties is and developing business relationships. However, signed. The due diligence should for example when giving or receiving gifts, meals and enter- include inquiry about the third party’s back- tainment there are some important rules you ground, qualifications and reputation. must follow: Be on the lookout for these red flags when dealing with third parties and subcontractors: • No improper influence or special treatment – Never give or receive anything of value to • the transaction involves a country known for influence a decision or obtain special treatment corrupt payments • No cash – Cash or cash equivalents (such as • rumours regarding the third party of, or a gift certificates and checks) are never reputation for, offering or accepting bribes acceptable business gifts • the third-party objects to anti-bribery • Infrequent – Frequent gifts to the same representation in company agreements individual, even if inexpensive, are • the third party has a family relationship with inappropriate a government official or claims a special • Transparency – The gift must be given openly, relation with a particular official or ministry at an appropriate time and circumstance-not • the third party lacks qualifications to perform secretly, or through a third party the required services • Understand local laws – Examine a country’s • the third party lacks transparency in its local laws prior to giving or receiving any gift accounting records to ensure compliance. • the third-party requests unusual contract terms or payments arrangements such as a payment Please also see local guidelines regarding com- in cash, payment in a third country or pany representation, if any. payment to another person/company than the service provider 3 ANTI-CORRUPTION, ANTI-FRAUD AND ANTI-MONEY LAUNDERING POLICY • the third party is suggested by a government • accept or seek value from third parties by official, particularly one with discretionary virtue of official positions or duties, authority over the business at issue or • use of subcontractors because of personal • the third party’s commission or fee exceeds relationship or favour, profit from an official fair and reasonable compensation for the work position; and to be performed • impropriety in the handling or reporting of • the third party insists on using a specific money or financial transactions. consultant or one who provides little or no obvious added value. Any engagement in fraudulent or any other dis- honest conduct involving the company’s All payments and commissions to third parties assets and the financial reporting is prohibited. must: Elanders shall never participate, directly or indi- rectly through any intermediaries in any fraudu- • be made in accordance with the Group’s lent or other misconduct practices. This may not authorization rules and the local policies only entail disciplinary sanctions but also may relevant in each company; result in criminal charges. • be made via bank transfer through the accounts payable system as well as being fully WHAT IS MONEY LAUNDERING? accounted for; Money laundering is defined as the process to • must be in line with generally accepted rates cover up illegally obtained money. The original and business practice for the service in source of the money or asset, usually a criminal question and should be justifiable and action, is hidden and exchanged to appear supportable; and legitimate. The organisation of money laun- • must be made in accordance with the terms of dering can often be complex and can involve the relevant contract. criminal actions such as drugs, people smuggling, bribery, fraud, tax crimes, trafficking or terrorist If you have any concerns that arrangements funding. with a third party are not in accordance with Money laundering is forbidden by law and this policy, you should ask your local Managing Elanders do not support or facilitate money Director or Elanders Group for advice.
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