Nonetheless, this policy/document is subject to amendment, modification and variation. We’ll send you a link to a feedback form. It is illegal to offer, promise, give, request, agree, receive or accept bribes - an anti-bribery policy can help protect your business.You should have an anti-bribery policy if there is a risk that someone who works for you or on your behalf might be exposed to bribery.Your anti-bribery policy should be appropriate to the level of risk your business faces. Concerns can be raised verbally or in writing. This training shall also be given to Intermediaries.The Company will establish and put in place appropriate performance measures and reporting systems to monitor performance against metrics and compliance with the relevant policies, procedures and controls.Compliance Department will monitor the effectiveness and review the implementation of this policy in coordination with Heads of Department regularly considering its suitability, adequacy and effectiveness. To flourish an anti-bribery and corruption culture in the company, the employees and others acting for and on behalf of ABAC CoE are strictly prohibited from making, soliciting or receiving any sort of bribes or unauthorized payments and get indulged in corrupt practices.Nonetheless, a breach of Anti-Bribery and Corruption policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal, and expose the responsible to other penal consequences under the laws. Initially scheduled to enter into force in April 2010, this was changed to 1 July 2011. Any “corrupt” payment, promise or offer to pay, or authorization of the giving of anything of value to or for an Official – or to anyone else while knowing it will be shared with such a person – is prohibited.UAE has had anti-bribery legislation in place since 1987, in the form of the UAE Federal Penal Code (the “Code”). ABAC CoE communicates views to government and others, on matters which affect its business interests or those of its shareholders and employees, as a way of assisting in the development of regulation and legislation affecting the business.The Company believes in contributing to the communities in which it does business. Thus, the employees, agents and all those associated with ABAC CoE are required to comply with these laws regardless of where you are conducting business on behalf of ABAC CoE or one of its subsidiaries. Any amendment, variation or waiver of any provision of this Policy must be approved in writing by the Company’s Board of Directors. In addition, employees of ABAC CoE Joint Ventures or subsidiaries, whether in the Pakistan, UAE, U.K. or elsewhere, are required to follow these standards. 11 February 2012 This becomes more desirable and important than ever because of emergence of anti-bribery and corruption legislations across the world and international commitments as to curb the menace of bribery and corruption.ABAC Certification has a zero-tolerance approach for giving or receiving of bribes or corrupt payments, in any form.
Whilst the written local law would influence what would constitute “improper” action, local custom and practice are disregarded. The Designated Person will send a written acknowledgement of the concern to the individual and will inform the individual making the disclosure, (and as the case may be) the Company Secretary, the chief executive officer, and the Chair of the Board of Directors of what action, if any, is to be taken. It will take only 2 minutes to fill in. The Compliance Officers will inform the Chairman of the Board of Directors of any serious issues as a matter of urgency.If you wish to raise a concern using the confidential employee helpline as the nature of the concern is such that you feel it cannot be raised internally, or if you feel that, after reporting the concern internally, the matter still remains unresolved, you can raise the concern via the Company’s confidential employee helpline on +92 51 111 888 400.The Company recognises that there may be some cases where no wrongdoing is found through internal procedures. Company being fully cognizant of its corporate social responsibility has devised this policy keeping in view the local as well as international laws relating to bribery and corruption in order to aid company’s board, senior management and staff in ensuring strict compliance with relevant anti-bribery and corruption laws at all times. In the UK these requirements are covered by the Companies Act.The US FCPA prohibits the offer or agreement to give “anything of value” to an Official for a corrupt purpose, including: gifts, entertainment, free travel, meals or training, business, employment or investment opportunities, personal discounts or credits, assistance to or support of family members, or other benefits. The Board and senior management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, corruption and corrupt practices pursuant to laws of the countries in which jurisdiction ABAC CoE conducting its business. This law provides that a company or other “commercial organization” can be prosecuted if a person “associated with it” bribes another person intending to obtain or retain business or an advantage in the conduct of business for that organization.
Although Company has assessed its bribery risk as ‘low’ due to the nature of its business, ‘bribery’ is included in the regular training provided by the Company.As an incorporated and regulated company ABAC CoE has already in place a monitoring programme. Alternatively, it might form the basis of a special investigation. Any employee concerned about any form of malpractice, improper action, or wrongdoing by the Company, its employees or other stakeholders are strongly encouraged to report the matter through the dedicated Employee Assistance Programme staff helpline.We believe it is essential to create an environment in which you feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against you, that you will be taken seriously, and that the matters will be investigated appropriately and as far as practicable be kept confidential.ABAC CoE believes that any employee with knowledge of bribery in any form should not remain silent. In particular, employees should be timely and thorough when preparing all reports and records required by management.
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