Anti Bribery & Corruption
- Our Expectations of You
- Our Commitment to You
- What is Bribery and Corruption?
- Acceptance of Gifts, Gratuities & Services
- Conflict of Interest
- Political Donations
- Use of Third Party Representatives
Our Expectations of You
All employees have a responsibility to help detect, prevent and report instances of bribery and corruption, and any other suspicious activity or wrongdoing in connection with our business.
We are absolutely committed in ensuring that all employees have a safe, reliable, and confidential way of reporting any suspicious activity.
If you have concerns, you should raise it with the Executive Director. In case you are uncomfortable with speaking to the Executive Director than raise your concern with the external contact.
Our Commitment to You
In the event that an incident of bribery, corruption, or wrongdoing is reported, we will act as soon as possible to evaluate the situation.
If you raise a concern it will be dealt with sensitively and with appropriate confidentiality.
You will never be penalized for raising concerns, so even if you are unsure about whether an instance of Bribery or Corruption has occurred please raise this following the procedure we have listed in the policy.
What is Bribery and Corruption?
BRIBERY : The offer of something (e.g. money or gifts) in return for you doing something which is illegal, unethical or a breach of trust.
CORRUPTION: The misuse of office or power or influence for private gain.
Let’s take a look at some examples of where Bribery and Corruption could occur in our business….
A student offers you a financial payment to help process their application more quickly.No
A student’s parents bring in a small gift to say thank you for your support in assisting their son to get accepted and enrolled in their preferred program of study.Yes
An test candidate asks you to help influence the outcome of their test results to ensure they reach the score they need for their university application.No
- Acceptance of Gifts, Gratuities, and Services
This includes the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings.
These activities are acceptable provided they: 1 ) Are of modest symbolic nature 2) Do not influence business judgement. 3) Are not prohibited by the law.
Our employees must not accept gifts or entertainment where to do so might influence, or be perceived to influence, objective business judgement.
Which of these are acceptable under the policy guidelines?
- An airline ticker offered by a travel agent worth more than 100$.
- Business lunch hosted by one of the stake holders.
- Key chain given to you by a stake holder at an event.
Conflict of Interest
Conflicts of interest may arise in many ways, including:
When an employee arranges a contract with or influences a decision regarding an outside individual or entity that results in a personal gain for an employee or an employee’s relative, such as monetary payments, gifts or price breaks.
When an employee is involved with another professional organization or group that may have business interests similar to us, requiring the employee to be careful in discussions of our plans, products or services.
When an employee is seeking appointment or election to a position of authority with other business or professional organizations related to our business.
If you have any influence on transactions involving purchases, contracts or leases, it is imperative that they disclose this information to the Executive Director as soon as the existence of any actual or potential conflict of interest is identified.
Conflict of Interest may arise if you have a contract for food distribution while being an employee of our company?
- Dont Know
We must never make any direct or indirect contributions or payments to any political party, organisation or individual engaged in politics as a way of gaining an advantage in our business.
Our employees, in their individual capacities, can make political donations, attend campaign rallies or meetings. However they should refrain from displaying or making reference to their connection to the company.
Employees can make a political donation in their personal capacity?
Use of Third Party Representatives
Third parties are anyone who is not our employee or officer of the company. This includes licensees, contractors and sub contractors, service providers and joint venture partners.
When a third party conducts business activities on our behalf or distributes our products, they must do so in accordance with our Code of Conduct and the Anti Bribery and Anti Corruption Policy.
Is an Examiner termed as "third party" in view of the policy?
- Dont Know