Government-private partnership: anti-corruption & anti-bribery practice
|
|
- Baldric Spencer
- 6 years ago
- Views:
Transcription
1 International Business Integrity Conference (IBIC) 2016 Government-private partnership: anti-corruption & anti-bribery practice 1
2 Government-private partnership: anti-corruption & anti-bribery practice Wayne P. Borduin Vice President Finance Jakarta, November 16, 2016
3 Integrity is doing the right thing, even if nobody is watching. Unknown author 3
4 Chevron worldwide One of the world s largest integrated energy companies Over 58,000 employees million BOE daily net production in 2015 Exploration & Production Refining Chemicals 4
5 Chevron indoasia business unit (IBU) Produces over 40% of Indonesia s crude oil production Generates approximately 50% of Indonesia s geothermal energy Chevron Geothermal Philippines Holding Inc. Chevron Malampaya Mak-Ban Field Tiwi Field South Natuna Sea Block B PT. Chevron Pacific Indonesia Oil & Gas Exploration and Production Geothermal PT. Chevron Geothermal Suoh-Sekincau Chevron Geothermal Salak Chevron Geothermal Indonesia Chevron Indonesia Company Chevron Makassar, Ltd Chevron Rapak & Ganal (IDD) 5
6 The chevron way: Guiding our business and core strategies 6
7 The chevron way Vision and values Vision Values To be the global energy company most admired for its people, partnership and performance How does Chevron achieve its vision? By getting results the right way The Chevron Way Our company s foundation is built on our values Integrity Trust Diversity Ingenuity Partnership Protecting People and the Environment High Performance 7
8 Preventative measures for ethical decision making Is it consistent with company policy? Is it legal? Is it consistent with the Chevron Way? Would I be comfortable if it were made public? 8
9 3 steps in implementing anti-corruption / anti-bribery practice Policy Develop and implement strict anticorruption/ anti-bribery policy Program & Tools Develop and implement anti-corruption/ anti-bribery programs and supporting tools Monitoring & Evaluation Monitoring and evaluation The Chevron Way: Integrity 9
10 Step 1: develop anti-corruption/ anti-bribery policy 1. Business Conduct & Ethic Codes, which guide us to fully comply with the law and conduct our business in accordance with the highest standard of honesty and integrity 2. Conflict of Interest, which prohibits employees from engaging in any activities which conflict with Chevron s business; adversely affect Chevron s reputations or relations with others; interfere with the fulfillment of the employee s job responsibilities 3. Foreign Corruption Practice Act (FCPA), a US Government policy which prohibits any offer or payment of anything of value to non-us officials, political parties, political party officials and candidates for non-us public office in order to influence any action or gain any improper advantage for the purpose of obtaining or retaining business 10
11 Step 2: develop and implement anti-corruption/anti-bribery program 1. Manage Internal Control & Compliance Organization under Finance to ensure the Company Policies are understood and executed by all 2. Develop Tools to implement and monitor the compliance programs: Incorporate compliance into employee annual performance agreements Conduct mandatory computer-based training for all employees and contractors, e.g. Business Conduct & Ethic Codes; Conflict of Interest Survey; Foreign Corruption Practice Act/FCPA, Leading with Integrity Establish and maintain a designated Compliance Hotline Conduct face-to-face workshops on FCPA / COI / Compliance for Chevron teams, vendors, and other business partners Secure pre-approval / clearance for any activities involving GOI officials prior to executing the program/activity Establish an Investigation Governance Board (IGB) to follow-up any whistle blowers allegation and implement sanctions to employees/vendors Conduct independent Contractor audits 11
12 Step 3: monitoring and evaluation Employee Performance Agreement Compliance Training Annual Rep Letters Quarterly Compliance Committee Meetings Internal Rated Audits Corporate Reporting Compliance Action Database Complianc e Action Database 12
13 Summary and recommendation Successful anti corruption and anti bribery practice requires: Clear vision and values Clear tone from the top, leading by example Availability of policy, regulation and good governance practice (i.e. establish publish rate on government tariffs) Availability of supporting tools/trainings and anti-corruption preventive system Build strong & transparent alliances with GOI agencies and business sector Consistent implementation and equitable sanction for all parties (government and private business) Transparent, consistent and honest justice system on law enforcement 13
14 Thank you 14
CARNIVAL CORPORATION & PLC
CARNIVAL CORPORATION & PLC Business Partner Code of Conduct and Ethics A Letter from our CEO Building and maintaining trust in our business relationships and pursuing the highest standards of ethical behavior
More informationAnti-Corruption/ Business Conduct and Ethics Policy
Anti-Corruption/ Business Conduct and Ethics Strict compliance with the provisions of the Company s Code of Business Ethics and Conduct and the Anti-Corruption and it s annexures is mandatory for all directors,
More informationWORKING WITH THIRD PARTIES POLICY POLICY ADOPTED MARCH 2015, REVISED FEBRUARY 2017
WORKING WITH THIRD PARTIES POLICY POLICY ADOPTED MARCH 2015, REVISED FEBRUARY 2017 TABLE OF CONTENTS WORKING WITH THIRD PARTIES POLICY... 3 Introduction... 3 Working with third parties... 3 Due diligence
More information!! CORDOBA!MINERALS!CORP.!! FOREIGN!CORRUPT!PRACTICES!POLICY!
CORDOBAMINERALSCORP. FOREIGNCORRUPTPRACTICESPOLICY Purpose ThepurposeofthisForeignCorruptPracticesPolicythe"Policy")istoprovideaproceduretoensure that Cordoba Minerals Corp. the Company ), together with
More informationCommitted to the SDGs PEACE, JUSTICE AND STRONG INSTITUTIONS BUSINESS ETHICS
Committed to the SDGs PEACE, JUSTICE AND STRONG INSTITUTIONS BUSINESS ETHICS STRUCTURE Business Ethics System Evaluations Challenges Gloria María Úsuga Yepes Corporate Auditor "Our commitment and work
More informationI. GENERAL STATEMENT. Corporate Procedure Number: IMCP Subject: Ethics and Anti-Corruption. Date Issued: March 11, 2016
I. GENERAL STATEMENT Iochpe-Maxion S.A. is committed to the highest ethical standards and to conducting its business in accordance with all applicable laws and regulations. The terms established in this
More informationThank you, Mark Mirelez. VP Supply Chain Management. DynCorp International, LLC
Supplier Code of Ethics and Business Conduct It is DynCorp International s commitment to conduct business honestly, ethically, and in accordance with best practices and the applicable laws of the United
More informationJanus Henderson Group plc. Code of Business Conduct
Janus Henderson Group plc Code of Business Conduct This Code of Business Conduct (the Code ) has been adopted by the board of directors (the Board ) of Janus Henderson Group plc. The Code applies to all
More informationFINAL ASSESSMENT M.C. DEAN, INC.
FIL ASSESSMENT M.C. DEAN, INC. The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores: Topic Number of questions
More informationStandards of Business Conduct I N T E RM E D I A RY A N D S U P P L I E R E D I T I O N
Standards of Business Conduct I N T E RM E D I A RY A N D S U P P L I E R E D I T I O N OCTOBER 2015 Dear Valued Intermediary or Supplier: Harris has a strong ethics and business conduct program that helps
More informationETHICAL CODE OF CONDUCT
S E C U R I N G T H E F U T U R E ETHICAL CODE OF CONDUCT 1 TABLE OF CONTENT 1. THE ETHICAL CODE OF CONDUCT 4 1.1 Purpose 4 1.2 Commitment 5 1.3 Presentation of the Code of Conduct 5 2. GENERAL PRINCIPLES
More informationThird-party risk management. EY Integrity Diligence
Third-party risk management EY Integrity Diligence A challenging landscape Understanding who you conduct business with has become more than just good business practice; it is increasingly smart compliance.
More informationCDM Smith Code of Ethics
CDM Smith Inc. and all of its subsidiaries are committed to ethical conduct in our business practices. Since the firm s founding in 1947, we have always upheld a policy to conduct all business in a lawful
More informationB. Braun Group. Code of Conduct
B. Braun Group Code of Conduct Principles In accordance with our Corporate Strategy we, the family-owned B. Braun Group, have adopted legality and corporate responsibility into our Corporate Governance
More informationSupplement to the Epson Group Principles of Corporate Behavior
Supplement to the Epson Group Principles of Corporate Behavior Anti-Bribery and Competition Law Guidelines for Business Partners Established July 1, 2016 Amended October 1, 2017 Re: Page 1 Contents 1.
More informationCODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN
CODE OF CONDUCT FOR DOING BUSINESS WITH LINKEDIN TABLE OF CONTENTS INTRODUCTION 1 Expectations LINKEDIN VALUES 2 MAINTAINING BUSINESS INTEGRITY 3 Anti-Corruption Competition Laws PROMOTING TRANSPARENCY
More informationDriving Top-Level Commitment. The road to compliance begins with educating the C-Suite
Driving Top-Level Commitment The road to compliance begins with educating the C-Suite We need to manage risk related to antibribery laws! How much will this cost? Who will do this? How big is our risk?
More informationFINAL ASSESSMENT KOREA AEROSPACE INDUSTRIES, LTD.
FIL ASSESSMENT KOREA AEROSPACE INDUSTRIES, LTD. The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores: Topic
More informationSUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders.
SUNRISE TELECOM CODE OF BUSINESS CONDUCT AND ETHICS Overview Sunrise Telecom is committed to its customers, partners, employees and stockholders. Accordingly, we believe that operating with integrity is
More informationGlobal Expectations for Addressing Fraud Risk and the Investigative Process
Global Expectations for Addressing Fraud Risk and the Investigative Process Waheed Alkahtani CFE, CISA, and CCEP-I Saudi Aramco Internal Auditing Special Audits Division Copyright 2014, Saudi Aramco. All
More informationManaging Compliance Risk in M&A, and Special Considerations for Joint Ventures
Managing Compliance Risk in M&A, and Special Considerations for Joint Ventures SCCE Upper Midwest Regional Conference April 26, 2013 Agenda Compliance risk and threat landscape overview Four areas we ll
More informationRights and Engagement of Indigenous Peoples. Workforce Safety and Health. Governance and Accountability. Economic Impact
MATERIALITY MATRIX CATEGORIES: STRATEGY AND GOVERNANCE SAFETY AND HEALTH COMMUNITIES ENVIRONMENTAL STEWARDSHIP OUR PEOPLE IMPORTANCE TO STAKEHOLDERS LOW IMPORTANCE AVERAGE IMPORTANCE HIGH IMPORTANCE CRITICAL
More informationPRYSMIAN GROUP ETHICAL CODE
PRYSMIAN GROUP ETHICAL CODE the Prysmian ethical code Ethical Code Introduction pag. 1 Articles: Article 1 Article 2 Article 3 Article 4 Article 5 Article 6 Article 7 Article 8 Article 9 Article 10 Article
More informationProcedure: Sasol Supplier code Of Ethics
Procedure: Sasol Supplier code Of Ethics >Document number< Revision: 01 SAX-10029304 Purpose This Procedure is intended to govern the Conduct of Sasol and all of its subsidiaries, sub-contractors, consultants,
More informationB. Braun Group. Code of Conduct
B. Braun Group Code of Conduct Principles In accordance with our Corporate Strategy we, the family-owned B. Braun Group, have adopted legality and corporate responsibility into our Corporate Governance
More informationImplementing and Managing an Effective Anti Corruption Compliance Program
Implementing and Managing an Effective Anti Corruption Compliance Program Mvolkov@volkovlaw.com http://corruptioncrimecompliance.com effective compliance The Importance of an Ethics and Compliance Program
More information"Finnair" and "Finnair Group" as used herein refer to Finnair Plc and its subsidiaries.
Code of Conduct 1 INTRODUCTION 1.1 Purpose and scope of this document Finnair is an iconic national airline and a respected member of the international aviation community with a solid reputation in safety,
More informationWestRock is committed to honest and ethical business practices. All forms of bribery are forbidden.
POLICY NAME: DEPT/GROUP: POLICY SCOPE: POLICY REGION: ANTI-BRIBERY LEGAL DEPARTMENT ALL EMPLOYEES GLOBAL REVISION DATE: 4/13/2018 OWNER JOSEPH HUTCHISON WestRock is committed to honest and ethical business
More informationAmgen GLOBAL CORPORATE COMPLIANCE POLICY
1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers, secondees, and temporary staff worldwide ( Covered Persons ). Consultants, contract
More information1.1 What is Ethics? Why is it important to apply this Code?.. 2
PPI CODE OF ETHICS CONTENT 1. Our Code of Ethics 2 1.1 What is Ethics? 2 1.2 Why is it important to apply this Code?.. 2 2. Ethic Principles.3 2.1 Respect.4 2.2 Equality and non-discrimination....4 2.3
More informationHAVYARD GROUP ASA Code of Conduct for Business, Ethics and Corporate Social Responsibility
Adopted by the Board of Directors of Havyard Group ASA on 17 March 2014, last amended on 26 February 2015. www.havyard.com 1. CORPORATE VALUES Havyard Group ASA (the Company ) shall enjoy an invaluable
More informationA Shared-Cost Approach to Anti-Bribery Compliance
12 th Annual Compliance & Ethics Institute A Shared-Cost Approach to Anti-Bribery Compliance Alexandra Wrage President, TRACE International Alexandra Wrage President TRACE International, Inc. Contact Information
More informationHenkel s Compliance Management System (CMS)
Henkel s Compliance Management System (CMS) As a company that operates in an ethically and legally correct manner, Henkel s image and reputation is inseparable from the appropriate conduct of each of its
More informationNavistar Defense Code of Conduct
Navistar Defense Code of Conduct INTRODUCTION Navistar Defense, LLC (hereinafter Navistar Defense or the Company ) is committed to conducting its business according to the highest standards of ethics and
More informationGlobal Supplier Code of Business Conduct & Ethics
Global Supplier Code of Business Conduct & Ethics Version 2.0 2/15/2017 Contents Document Statement... 3 Scope... 3 1.0 Related or Referenced Policies... 3 2.0 Compliance with Laws, Regulations and the
More informationThe Compliance- Heroes of HARTMANN. Code of Conduct 3 rd edition
The Compliance- Heroes of HARTMANN Code of Conduct 3 rd edition MAN-M5.2-01 Code of Conduct, Version 1.0. Valid from January, 01, 2017. HARTMANN Our Mission, our Values, our Code of Conduct. HARTMANN is
More informationSUPPLIER CODE OF BUSINESS CONDUCT
SUPPLIER CODE OF BUSINESS CONDUCT August SUPPLIER CODE OF BUSINESS CONDUCT TABLE OF CONTENTS 1 INTRODUCTION... 3 2 LCBO CORE VALUES... 3 3 APPLICABILITY OF THE CODE... 4 4 RESPONSIBILITIES... 4 5 PRINCIPLES...
More informationSprint Nextel Code of Conduct for Consultants, Contractors and Suppliers
Sprint Nextel Code of Conduct for Consultants, Contractors and Suppliers 1 TO OUR VALUED CONSULTANTS, CONTRACTORS AND SUPPLIERS: Sprint Nextel's reputation for service, quality and fair dealing attracts
More informationPostNL group procedure
1 January 2017 PostNL Holding B.V. Audit & Security PostNL group procedure on fraud prevention guidance on bribery and corruption Author Director Audit & Security Title PostNL group procedure on Fraud
More informationDeveloping An Effective Global Anti-Bribery Compliance Program
Developing An Effective Global Anti-Bribery Compliance Program The International Pharmaceutical Regulatory and Compliance Congress Brussels, Belgium June 6, 2007 Gordon M. Chapman Bristol-Myers Squibb
More informationARCADIS GENERAL BUSINESS PRINCIPLES. July 2016
ARCADIS GENERAL BUSINESS PRINCIPLES July 2016 ARCADIS GENERAL BUSINESS PRINCIPLES 1. INTRODUCTION At Arcadis we define our mission as: Our mission is to create exceptional and sustainable outcomes for
More informationVerisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018
Verisk Analytics, Inc. Code of Business Conduct and Ethics As Amended June 5, 2018 1. Introduction This Code of Business Conduct and Ethics ( Code ) has been adopted by our Board of Directors and summarizes
More informationSlavery and Human Trafficking Statement for financial year ended March, 2018
Slavery and Human Trafficking Statement for financial year ended March, 2018 Page 1 of 5 Vedanta Resources plc. Slavery and Human Trafficking Statement for financial year ended March, 2018 This statement
More informationIntel s Ethical Expectations for Suppliers and their Employees Supplier Ethical Expectations
Intel s for s and their Employees 1 Agenda Business Principles Intel s Code of Conduct EICC and Key Policies Bribes, Kickbacks and Commissions Gifts and Gratuities Conflicts of Interest Use of Intel s
More informationWho Owns Fraud Uniting Corporate Executives to Manage Your Anti-Fraud Program
Who Owns Fraud Uniting Corporate Executives to Manage Your Anti-Fraud Program Monday June 13, 2011 10:20 11:40 San Diego, California Who owns fraud why is it important? Many companies struggle to determine
More informationBearing the Bad News Reporting to the Board on Internal Corruption. Peter Dent, National Leader Deloitte Forensics September 11, 2013
Bearing the Bad News Reporting to the Board on Internal Corruption Peter Dent, National Leader Deloitte Forensics September 11, 2013 Agenda Assessment of Risk in Canada Recent trends in enforcement activity
More informationSupplier Ethical Expectations
Supplier Ethical Expectations Training for Suppliers and Their Employees Revision 9, 2017 Course ID 00016572 1 Overview 1. What Intel Expects of Intel Employees Intel s Code of Conduct Intel s Anti-corruption
More informationLetter From Crown s President
Code of Conduct Letter From Crown s President Crown s reputation for integrity is built not only on the quality of Crown s products and services but also on Crown s employees history of honest, ethical
More informationChina Airlines Ltd. Ethical Corporate Management Best Practice Principles
China Airlines Ltd. Ethical Corporate Management Best Practice Principles Amended and approved by the Shareholders Meeting on March 25, 2016 Article 1 These Principles are adopted to assist the Company
More informationANTI-CORRUPTION POLICY December 2017
ANTI-CORRUPTION POLICY www.ngahr.com Document Control Document Information Document Title Anti-Corruption Policy Document Owner Head of Compliance & Privacy Document Author XXX XXX Issue Date December
More informationHAMASPIK OF ROCKLAND COUNTY, INC. CORPORATE COMPLIANCE PLAN JANUARY 2011
HAMASPIK OF ROCKLAND COUNTY, INC. CORPORATE COMPLIANCE PLAN JANUARY 2011 1 TABLE OF CONTENTS I. Introduction Page 3 II. Written Compliance Standards Page 3 A. Codes of Ethical Conduct Page 3 B. Policy
More informationID Rev. 01. Code of conduct POLICY
ID 633336 Code of conduct POLICY Code of conduct 2 (6) Contents Introduction... 3 Compliance with laws... 3 Openness... 3 Respect for human and labour rights... 3 Fair employment practices... 3 Occupational
More informationTriple C Housing, Inc. Compliance Plan
Triple C Housing, Inc. Compliance Plan Adopted by Board of Directors on draft November 13, 2014 Overview Triple C Housing, Inc. is committed to its consumers, employees, contractual providers, vendors,
More informationAcceleron Pharma Inc. Code of Business Conduct and Ethics
I. INTRODUCTION Acceleron Pharma Inc. Code of Business Conduct and Ethics (Amended & Restated as of March 1, 2018) This Code of Business Conduct and Ethics ( Code ) provides a general statement of the
More informationGlobal Compliance Audit. Understanding the Critical Importance of FCPA and Export Management Compliance
Global Compliance Audit Understanding the Critical Importance of FCPA and Export Management Compliance THE CRITICAL IMPORTANCE OF COMPLIANCE 2 When embarking on the promising and exciting endeavor of international
More informationGUIDANCE FOR SUPPLIERS OF PURDUE PHARMA L.P.
GUIDANCE FOR SUPPLIERS OF PURDUE PHARMA L.P. PURDUE PHARMA L.P. PURDUE S GUIDING PRINCIPLES 1 Table of Contents PURDUE S GUIDING PRINCIPLES... 1 ETHICAL BUSINESS PRACTICES... 4 Business Integrity... 4
More informationVIRTUA DATE OF LAST REVIEW 5/11; 4/14, 8/16
8/16 POLICY Virtua is committed to helping the people of our region be well, get well, and stay well. Part of our commitment to the communities we serve is to provide services of the highest quality to
More informationFINAL ASSESSMENT HONEYWELL INTERNATIONAL INC.
FINAL ASSESSMENT HONEYWELL INTERNATIONAL INC. The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores: Topic
More informationFINAL ASSESSMENT ISRAEL AEROSPACE INDUSTRIES LTD
FINAL ASSESSMENT ISRAEL AEROSPACE INDUSTRIES LTD The following pages contain the detailed scoring for your company based on public information. The following table represents a summary of your scores:
More informationThis document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers,
This document articulates ethical and behavioral guidance for all NGA Human Resources companies, employees, and business partners (such as suppliers, agents, vendors and sub-contractors). To help guide
More informationENHANCED DUE DILIGENCE
Thomson Reuters ENHANCED DUE DILIGENCE THE RISK OF NOT KNOWING Entering into a contract or business relationship with an individual without full knowledge of their business dealings, past or present, can
More informationTHE FIDI ANTI-BRIBERY AND ANTI-CORRUPTION CHARTER. v. 1.2
THE FIDI ANTI-BRIBERY AND ANTI-CORRUPTION CHARTER v. 1.2 JULY 2015 Leading The Fight against Corruption FIDI is determined to lead the relocation industry by taking a clear stand against bribery and corruption.
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CODE OF BUSINESS INTRODUCTION At Cathedral Energy Services Ltd. and its subsidiaries (together, Cathedral ), we have always recognized the value of growing and developing trusting relationships
More informationPHILLIPS 66 BUSINESS PARTNER PRINCIPLES OF CONDUCT. Doing the right thing always. Phillips66.com
PHILLIPS 66 BUSINESS PARTNER PRINCIPLES OF CONDUCT Doing the right thing always. Phillips66.com 1 BUSINESS PARTNER PRINCIPLES OF CONDUCT At Phillips 66, we take great pride in providing energy and improving
More informationCODE OF CONDUCT. Securing What Matters
1 WHY THIS CODE OF CONDUCT? At Betafence we believe our success depends on relations based on trust and professionalism. This Code of Conduct guides us in building and maintaining these relationships with
More informationAPPROVED. Anti-Bribery and Corruption Policy OBJECTIVES PRINCIPLES WOODSIDE POLICY. Prohibition on corruption. Gifts and entertainment principles
WOODSIDE POLICY Anti-Bribery and Corruption Policy OBJECTIVES Woodside is committed to conducting its business and activities with integrity. To achieve this objective: Woodside will not engage in corrupt
More informationCode of Conduct & Ethics
Code of Conduct & Ethics Interfor Code of Conduct & Ethics Contents Page 1 CEO Message A Message from our CEO 2 Our Code of 2 Conduct & Ethics Our Code of Conduct & Ethics 3 3 Guiding Principles Guiding
More informationCorporate Compliance Plan JANUARY 2011
Corporate Compliance Plan JANUARY 2011 Reviewed and updated at Board Meeting January 29, 2017 1 TABLE OF CONTENTS I. Introduction Page 3 II. Written Compliance Standards Page 3 A. Codes of Ethical Conduct
More informationSumitomo Corporation Group Anti-Corruption Policy
Sumitomo Corporation Group Anti-Corruption Policy Preface At Sumitomo Corporation, compliance is based on the Management Principles rooted in the Sumitomo Business Philosophy of maintaining integrity and
More informationContents. Code of Conduct
Code of Conduct Contents 1 Introduction 3 2 Business ethics Applying responsible business practices 3 2.1 Compliance with laws and regulation 3 2.2 Accuracy of records and reports 3 2.3 Conflicts of interests
More informationBribery and Corruption
Bribery and Corruption Anti-Corruption Programs 2018 Association of Certified Fraud Examiners, Inc. Discussion Questions 1. What companywide policies does your organization have in place to address the
More informationCOMMUNICATION ON ENGAGEMENT (COE)
COMMUNICATION ON ENGAGEMENT (COE) PERIOD COVERED ON THIS COMMUNICATION ON ENGAGAEMENT FROM: APRIL 2015 TO: APRIL 2017 PART I: STATEMENT OF CONTINUED SUPPORT BY THE EXECUTIVE April 07, 2017 To our stakeholders;
More informationBroadSoft, Inc. Vendor Code of Conduct
BroadSoft, Inc. Vendor Code of Conduct 1 GENERAL APPLICATION BroadSoft, Inc. and its subsidiaries and affiliates (collectively, BroadSoft ) is committed to the highest standards of environmental, social
More informationCODE OF CONDUCT DESCRIPTION PRINCIPLES POLICIES AND DEFINITIONS
CODE OF CONDUCT DESCRIPTION Schneider has adopted the following Code of Conduct ( Code ) to apply to Schneider s directors, officers, managers and associates. While no code or policy can anticipate every
More informationSUPPLIER CODE OF BUSINESS ETHICS AND CONDUCT
Compliance with Laws We expect our suppliers to maintain full compliance with all laws and regulations applicable to their business. When conducting international business, or if their primary place of
More informationCONFLICT OF INTEREST POLICY
CONFLICT OF INTEREST POLICY Compliance & Ethics Version 3.1 January 5, 2018 CONFLICT OF INTEREST POLICY Compliance & Ethics Policy Owner: Emily Grymes, Director, Global Compliance & Ethics Policy Approver:
More informationANNUAL INTEGRATED REPORT 2016 Rotoplas. In_. Rotoplas. Integrity & leadership CORPORATE GOVERNANCE
49 Rotoplas. Integrity & leadership CORPORATE GOVERNANCE 50 GRUPO ROTOPLAS S.A.B. DE C.V. Corporate governance Structure (102-5, 102-18, 102-19, 102-20, 102-22, 102-23, 102-24, 102-27, 102-28, 102-33,
More informationAMETEK, Inc. Code of Ethics and Business Conduct
AMETEK, Inc. Code of Ethics and Business Conduct Code of Ethics and Business Conduct A Message from the Chairman of the Board and Chief Executive Officer Dear AMETEK Colleague: AMETEK has been in business
More informationCODE OF BUSINESS CONDUCT PENN NATIONAL GAMING, INC.
CODE OF BUSINESS CONDUCT PENN NATIONAL GAMING, INC. (as amended March 27, 2015) INTRODUCTION The reputation and integrity of Penn National Gaming, Inc. and its subsidiaries (the Company ) are valuable
More informationCONTENTS Introduction...
Code of Conduct 1 CONTENTS Introduction... 3 IT and Security... 11 Purpose and Values... 5 Data Protection... 11 Employee Commitment... 5 Confidentiality and Ethics... 11 Diversity and Inclusion in the
More informationBUSINESS ETHICS POLICY and GUIDING PRINCIPLES
BUSINESS ETHICS POLICY and GUIDING PRINCIPLES The Guiding Principles form the core of the culture of Kimball International, and transcends decades. Kimball International is committed to ethical practices
More informationBusiness Partner Code of Conduct
Policy Owner: Group Head of Procurement Effective Date: 31 October 2017 Business Partner Code of Conduct This Business Partner Code of Conduct defines basic requirements and responsibilities. VEON reserves
More informationCode of Business Conduct
Code of Business Conduct Table of contents 1 Introduction 4 2 Definitions 4 3 Compliance 4 Compliance with applicable laws Compliance with laws on competition and anti-trust Compliance with laws on corruption
More informationTEEKAY TANKERS LTD. STANDARDS OF BUSINESS CONDUCT POLICY
TEEKAY TANKERS LTD. STANDARDS OF BUSINESS CONDUCT POLICY WHY TEEKAY HAS STANDARDS OF BUSINESS CONDUCT As responsible business leaders, it is not enough to do things right; it is also important to do them
More informationKnowledge grows. Yara s Anti-Corruption Commitment
Knowledge grows Yara s Anti-Corruption Commitment 2 Yara Contents 1. Introduction from the CEO 4 2. About this document 5 2.1 Who is it for? 5 2.2 Other relevant documents 6 3. Corruption 7 3.1 What is
More informationCITY OF GOSNELLS CODE OF CONDUCT
CITY OF GOSNELLS CODE OF CONDUCT The City of Gosnells is committed to establishing and sustaining a corporate culture that upholds high ethical standards and promotes compliance with applicable laws, regulations
More informationGroup Policy. UPM Rules for Sponsorships, Donations and Employee volunteering
Group Policy UPM Rules for Sponsorships, Donations and Employee volunteering Contents Why co-operate? 3 Definitions 3 What do we sponsor? 4 How does it work? 5 The process 6 Donations 8 Employee volunteering
More informationTHE TIMBERLAND COMPANY CODE OF ETHICS
THE TIMBERLAND COMPANY CODE OF ETHICS Code of Ethics MISSION AND VALUES STATEMENT We believe the honest and ethical conduct of our employees is an essential prerequisite to our success as a company. There
More informationLIBERTY HOLDINGS LIMITED CODE OF ETHICS
LIBERTY HOLDINGS LIMITED CODE OF ETHICS 2 Our Liberty Holdings Limited and all its group and associate companies and subsidiaries (the company) are committed to maintaining the highest standards of ethical
More informationCODE OF BUSINESS CONDUCT AND ETHICS (Amended and Restated as of May 7, 2013)
CODE OF BUSINESS CONDUCT AND ETHICS (Amended and Restated as of May 7, 2013) Introduction One of Matrix Service Company's most valuable assets is its integrity. Protecting this asset is the job of everyone
More informationebook FROM DETECT TO PREVENT : HOW TO USE TRANSLATION SOLUTIONS AS A PREVENTATIVE TOOL PAGE 1 library
ebook library PAGE 1 FROM DETECT TO PREVENT : HOW TO USE TRANSLATION SOLUTIONS AS A PREVENTATIVE TOOL How to use Translation Solutions as a Preventative Tool in Your Anti-Corruption Program As anti-corruption
More informationEthics and integrity. Compliance: A guide for third parties
Ethics and integrity Compliance: Doing the right thing together Living up to our ethical standards is not only the right thing to do, but it is also critical to the efficiency and reliability of our operations.
More informationAES Values Guide. From Words to Action STRIVE FOR EXCELLENCE THROUGH WORK HONOR COMMITMENTS ACT WITH INTEGRITY PUT SAFETY FIRST HAVE FUN
ve Fun Through Work AES Values Guide From Words to Action OUR CODE OF CONDUCT HAVE FUN THROUGH WORK STRIVE FOR EXCELLENCE HONOR COMMITMENTS ACT WITH INTEGRITY PUT SAFETY FIRST Dear AES People, At AES,
More informationJCM Power. The Environmental and Social Governance (ESG) Policy
JCM Power The Environmental and Social Governance (ESG) Policy 21 St. Clair Avenue East Suite 500 Toronto, Ontario, Canada M4T 1L9 1-647-447-1662 info@jcmpower.ca Contents 1. Our Corporate Vision and Mission...
More informationTNT POLICY Title TNT Policy on Fraud, Corruption and Bribery
TNT POLICY Title Date of effect 25 November, 2015 Version 3.0 Policy Owner Tjeerd Wassenaar, General Counsel Direct telephone no. +31 88 393 9000 Document history Approvals Approved by Date of approval
More informationDeveloping Effective Anti-Corruption Ethics and Compliance Programmes. Sven Biermann
Developing Effective Anti-Corruption Ethics and Compliance Programmes Sven Biermann UNODC Multi-Stakeholder Anti-Corruption Workshop, Sarajevo, 29 September 2017 A multitude of definitions Philanthropy
More informationMilliken Supplier. Code of Conduct. The Milliken Guide to Ethical Supplier Relationships
Milliken Supplier Code of Conduct The Milliken Guide to Ethical Supplier Relationships Code of Conduct Introduction The Milliken group of companies is committed to treating our suppliers, customers, communities
More informationTo participate in polling
in the Modern Multi-National: Aligning Trade with Your & Ethics Program Suzanne Bullitt Director, Global Trade Strategy & Eastman Chemical Company This Session Uses Polling To participate in polling Download
More informationDeterrence and detection
Deterrence and detection A growing concern A report by Fraud Investigation & Dispute Services Even before the Indian businesses and industry could recover from the negative impact of big scams from last
More informationBest Buy Political Activity &
Page 1 of 7 A. Policy Overview Purpose: This policy seeks to educate employees on political activity as it pertains to employment with Best Buy as a U.S.-domiciled company. Best Buy encourages employees
More information