It is the Company’s policy to conduct its business with honesty and transparency. Thus, it expects the same high standard of behavior from its entire staff.
This policy guides the Company’s staff in their professional relationship with clients or potential clients and business contacts of the Company. The policy provides specific guidelines, based on Maltese law, which prohibit any act intended to bribe or corrupt, or to obtain any unfair advantage from any third party external to the Company.
The policy addresses typical situations which may arise in the employees’ professional dealings with clients, principles or other business contacts of the Company. However, the examples in this policy should not be interpreted as encompassing the whole spectrum of bribery or corruption possibilities. Rather, employees should be guided by the general principles of honesty and transparency mentioned above. In all cases, if any employee is unsure as to whether his/her conduct and actions will be in contravention of this policy or his/her obligations at law, that employee must consult with his/her line manager or the CEO as early as possible.
This policy covers all staff members, consultants, and suppliers of the Company.
Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of his/her functions, or to reward him/her for acting improperly, or where the recipient would act improperly by accepting the advantage.
Advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
Improper behaviour is when persons act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
Corruption is the abuse of entrusted power or position for private gain.
No employee of the Company shall either directly or indirectly (via a third party) offer, pay or authorise payment or the giving of anything of value, even from his/her own personal funds, to any customer, government official, or any third party for the purpose of obtaining any improper business advantage.
Anything of value includes, but is not limited to:
Employees of the Company are authorised to offer modest and occasional meals to customers (third parties) as a business courtesy in the context of a business meeting to discuss a specific business topic. In such cases, all expenses are to be documented and a record kept of date, time, place, names of business guests, value of meals and reason for meals.
Employees of the Company are prohibited from paying for meals, whether modest or not, as a purely social interaction and are prohibited from offering meals, other hospitality, travel or accommodation to spouses, partners or guests who have nothing to do with the Company or who have no direct professional interest in the matter being discussed.
Employees of the Company may, after having obtained written authorisation from the line manager or the CEO, offer support for a training event or conference to clients. This support can include modest travel arrangements, the training or conference fees, modest and reasonable accommodation costs, and meal costs covering the days of the training event but not beyond the duration of the training event. The training event or conference must address appropriate topics with direct relevance to our company business. Support is not extended to partners/spouses/friends of clients. All expenses are to be recorded in a clear manner, specifying time, date, place and reason for support.
The Company may sponsor local educational events in connection with the business of the Company. Written approval for such a sponsorship must be obtained a priori from the CEO. All expenses in connection with such events must be recorded.
Employees of the Company may not give gifts to clients or third parties unless the gifts are given around Christmas time, as is the local custom. The gift may not exceed the cost of €20 and each client can only be given ONE gift. All relevant details of such gifts, namely, name of client receiving gift and the corresponding cost, must be recorded, with a copy of such record passed to the CEO. It is understood that the recipient of any such gift is not in any way, manner or form obliged to give any advantage to the company or its employees.
Private meals may be provided to employees by clients (third parties), but these will only be allowed if there is a clear business purpose, and there is no intention to influence any action or inaction. The same can be said for group meals, that is, they will only be allowed if there is a clear business purpose. Costs for such meals must also be kept moderate and should not exceed €45 per person.
Lodging expenses may be paid for employees by clients (third parties), but these expenses must be moderate. Hospitality must be reasonable and proportionate such that it would not be perceived to compromise employees’ judgement or integrity.
Meals and lodging expenses must not be covered by clients for spouses, partners or guests of employees.
Except in the limited cases mentioned below, customers shall not give gifts to employees. However, employees may be given gifts by customers (third parties) at Christmas time. The price of such a gift should be moderate. Employees may also be provided with items which have a genuine educational function.
The Company does not make contributions to political parties.
The Company may make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the CEO.
All employees are required to fully understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your line manager or the CEO as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future, for example, if a client or potential client offers you something to gain a business advantage with the Company, or indicates to you that a gift or payment is required to secure their business.
All employees are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or the CEO OR report it in accordance with the Company’s Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your manager or the CEO in strict confidentiality.
Individuals who refuse to accept or offer a bribe, or who raise concerns are assured that they will not suffer any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the CEO immediately.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
The Company may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.
The Company’s top management is responsible for the contents of this document.
The responsibility for adherence to this policy shall rest with the CEO and the employees.
The Company shall from time to time conduct training and information sessions to all employees and managers so that they understand the application of this policy.
The Company reserves the right to change this policy at any time as required. Such changes will be communicated to the employees prior to their implementation.