ISG POLICY
ANTI-BRIBERY & ANTI-CORRUPTION POLICY
ISG - POLICY
Anti-bribery & Anti-corruption Policy
- Objective
The objective of this Anti-Bribery & Anti-Corruption Policy is:
a) Setting out the Company’s obligations & the responsibilities of Board members, Employees & third Parties to operate and function while complying with applicable bribery and corruption laws.
b) Providing guidance on how to recognize and deal with bribery and corruption issues.
That ISG (hereinafter “Company”) will undertake a periodic bribery and corruption risk assessment across its business to understand the bribery and corruption risks it faces and ensure that it has adequate procedures in place to address those risks. The risk assessment will be documented and periodically reviewed and the appropriate committee of the Board of Directors of ISG be updated on a half yearly basis in accordance with applicable regulations.
- Applicability
This Policy applies to all Board Members, Employees, Directors & all Third Parties. This will include all subsidiaries and affiliate companies and such other persons, including those acting on behalf of the Company. This further includes the financial consultants, insurance intermediaries (corporate agents, brokers etc.), distributors, vendors, consultants, advisors, suppliers, contractors and other third parties engaged with ISG across all locations.
- Purpose And Scope
The Company is committed to conducting business with honesty and integrity. This includes operating in compliance with all applicable Anti-Bribery & Corruption Laws
The Purpose of this Anti-Bribery and Anti-Corruption Policy (this Policy) is to facilitate compliance with Anti-Bribery and Anti-Corruption Laws and protect the Company along with its employees from reputational damage, loss of licenses and permits, costly investigations and penalties (including significant fines), and imprisonment for individuals. This policy shall ensure safeguarding and promoting legitimate business practices throughout the organization and act to prevent and prohibit corruption, bribery and similar acts in connection with the organization.
- Anti-bribery & Corruption
Under no circumstances shall any employee offer, promise or grant anything of value to:
- a) Government Official
- b) Any person, or members of their family
- c) A Third Party
- d) Charitable organization suggested by such a recipient
For influencing the recipient to take or refrain from taking any official action, or to induce the recipient to conduct business with ISG.
UNDER THIS POLICY, THE FOLLOWING IS NOT ACCEPTABLE:
a) Giving, promising to give, or offer, a payment, gift or hospitality to secure or award an improper business advantage;
b) Giving, promising to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate, expedite, or reward any action or procedure;
c) Accepting payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
d) Inducing another individual to indulge in any of the acts prohibited in this policy;
e) Threatening or retaliating against another individual who has refused to commit a bribery offence or who has raised concerns under this policy;
f) Giving or accept any gift where such gift is or could reasonably be perceived to be a contravention of this policy and / or applicable law; or
g) Engaging in any activity that might lead to a breach of this policy.
THE COMPANY IS COMMITTED TO:
- Operating in compliance with this Policy in all countries in which we do business, regardless of whether the country has specific Anti-Bribery and Anti-Corruption Laws;
- Maintaining complete and accurate books and records; and providing a mechanism for reporting any known or suspected violation of Anti-Bribery and Anti-Corruption Laws and this Policy.
The Company expects all its employees to comply with all Anti-Bribery and Anti-Corruption Laws & other similar laws as may be applicable to the Company, its business or to the foregoing persons individually.
- Accepting Gifts And Hospitality (Exception)
This policy does not prohibit normal business hospitality, so long as it is reasonable, appropriate and in form of bona fide corporate hospitality, and if its purpose is to present the Company image, showcase its products & services, or to establish cordial relations.
- All gifts and hospitality, even in the normal business use must be duly approved at the appropriate level of Company management.
- It must not appear to or be intended to improperly induce any individual or employee. Any act conducted shall not have an influence on the decision making or making the recipient feel unduly obligated in any way. The representative of the Company should always consider how the recipient is likely to view the hospitality. Further, the representative must also decline any invitation or offer of hospitality or entertainment when made with the actual or apparent intent to influence their decisions.
- The representative should think very carefully before making, or receiving, gifts. The gifts can occasionally be offered to celebrate special occasions but should not be of significant value.
- Certain gifts are always prohibited. Some types of gifts are never acceptable including gifts that are illegal or unethical, or involve cash or cash equivalent (e.g. loans, stock options, etc).
- Modest promotional gifts are permitted. It is acceptable to offer modest promotional materials to contacts e.g. branded pens. The Company usually permits employees occasionally to receive unsolicited gifts of a very low intrinsic value from business contacts provided the gift is given unconditionally and not in a manner that could influence any decision-making process.
- Personal payment does not cure. Employees may never pay on their personal account for gifts or hospitality in order to avoid this policy.
- Donations And Sponsorships
Any donation & sponsorship offered or made by or on behalf of the Company must be based on legitimate objectives and comply with applicable laws, this Policy and the Related Policy Documents. While it may be appropriate to make a donation aiming to promote the well-being of and generate goodwill in the Community, in certain circumstances donations and sponsorships may be viewed as a disguise for bribery. For example, donating to a Public Official’s favored charity in exchange for favorable action by that Public Official may be construed as a bribe.
You must not offer a donation or sponsorship:
- To improperly influence or reward a Public Official or
- In any circumstances where the donation/sponsorship may be perceived as a bribe. In addition, before offering donation or a sponsorship for or on behalf of the Company, the representative must:
- Conduct due diligence on the intended donation/sponsorship recipient and beneficiary (if different) in accordance with the applicable Company process; and
- Obtain approval from the Compliance Officer or, in his/her absence, from the Chief Executive Officer, in accordance with the Company’s Investment Policy, if the intended donation or sponsorship is in any way, directly or indirectly, related to a Public Official. This could include donations/sponsorships requested by a Public Official, or that are intended for an organization in which a Public official or a close family member of a Public Official has a prominent role (for example, as a board member or trustee), or for an organization known or believed to be closely associated with a Public Official.
- Employee Responsibility
All Employees need to be alert about possible violations of this Anti-Bribery and Anti-Corruption Policy and report them to the HR/Legal/ Audit department or the Managing Director of the Company or their Head of Department. The Employee must cooperate in any internal or external investigations of possible violations. If one is asked to make a payment on the Company’s behalf, one should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. One should always ask for a receipt, which details the reason of the payment. If one has any suspicions, concerns or queries regarding a payment, one should raise these with the HR/ Legal/ Risk department /Compliance Officer, wherever possible, prior to taking any action.
- Breach Of Obligations
The violation of any of the orders, laws, rules and regulations under this policy may subject the employee to criminal or civil liability, including potential prosecution, fines and other penalties for improper conduct, as well as imprisonment or may result in corrective/ disciplinary action by ISG, including immediate termination from the employment.
- Policy Review
This policy shall be periodically reviewed and updated by the Legal & Human Resources team, in case there are significant changes in the applicable regulations. This policy will be read with the Code of Conduct of the company. Awareness on this policy will form part of the induction process where if required, employees will receive relevant inputs on how to implement and adhere to this Policy.
The Human Resources Department will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvement identified will be made and incorporated as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. This policy does not form part of the employee’s contract of employment and it may be amended at any time by the Company.
- What To Do If You Are A Victim Of Bribery Or Corruption
If the individual is offered a bribe by a third party, or if he/she are asked to make a bribe, or if it is suspected that he/she may be asked to commit such a violation, or if he/she believes that you or anyone else is a victim of any form of unlawful activity, he/she must comply with this policy.
