Anti-Bribery & Anti-Corruption Policy
OBJECTIVE
This policy establishes Gunship Group’s global standards regarding the prevention of corruption. If local laws or regulations have stricter requirements, those laws supersede the requirements stated in this policy.
All Gunship Group’s employees, partners and suppliers are expected to conduct themselves with honesty, fairness, and high ethical standards, as well as abide by all anti-corruption/anti- bribery laws and avoid even the perception of impropriety.
As a global enterprise, Gunship Group must comply with all applicable laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other similar anti-corruption laws around the world. These laws set prohibitions on giving bribes to government officials, book and records requirements, and criminal and civil penalties for violations. Some laws apply strict liability standards, expand the scope to include giving and receiving bribes, and even prohibit commercial bribery among private sector individuals.
POLICY STATEMENT
Consistent with laws around the world, we at Gunship Group do not promise, offer, give or authorize, directly or indirectly, a bribe or anything of value to ANYONE to attempt to improperly influence any act or decision to obtain or retain business, or to secure any improper advantage for Gunship Group.
Corruption violates the public’s trust, threatens economic and social development, and hurts fair trade. To combat corruption, most countries have enacted anti-corruption/anti-bribery laws and regulations. These laws make it a crime to give, pay or promise “anything of value” (bribes) to:
• Influence an act or a decision to obtain, retain and/or direct business, or
• Secure an improper advantage of any kind.
It is also a crime to accept “anything of value” (bribes) in these circumstances.
WHAT IS A BRIBE?
A bribe is not just cash in an envelope passed under a table. International laws and Gunship Group policy defines a bribe as “anything of value,” such as: cash, gift cards, home repairs/services, tickets to a theatre or sporting event, guest passes to a private club, a no-bid contract, a summer job for a teenage family member, free courtesy car service rides, and other items of value, where given to obtain an improper advantage or influence an action.
Just offering a bribe is a violation, even if the transfer of the item of value does not occur, or the purpose of the bribe is not fulfilled.
THIRD PARTIES MAY NOT BRIBE FOR GUNSHIP GROUP
Third parties (also called “intermediaries”) cannot be used to facilitate or hide bribery. Suppliers, agents, consultants, distributors, and business partners cannot offer or receive a bribe when working on Gunship Group behalf. Inducing, facilitating, or causing a third party to perform an act that would violate this policy is also a violation of this policy. If a Gunship Group employee becomes aware that a third party is being used to violate this policy, the employee must immediately report it to Gunship Group HR.
GIFTS AND ENTERTAINMENT
Gunship Group recognizes that, when conducted appropriately, informal interactions and exchange of gifts or other offerings with our business associates may be an important part of building goodwill and developing relationships with customers, partners, and suppliers and, in many countries, may be an accepted and appropriate business protocol and custom. However, if conducted inappropriately, gifts, travel, entertainment, and other offerings, may violate applicable laws or Gunship Group or third-party policies or principles.
As a rule, all gifts and other offerings must be done transparently and according to Policy to avoid even a perception of impropriety. The giving or receiving of gifts and other offerings must be appropriate (not cash, gift cards, or other prohibited types, not an attempt to unduly influence a business outcome, and otherwise in compliance with all laws, regulations, and policies), reasonable value and may need to be disclosed and pre-approved.
How we build trust:
- We refuse to offer or pay bribes or kickbacks to anyone.
- We prohibit corrupt payments of all kinds, including payments to secure permits or approvals, and small payments to speed up a routine government process (often known as a “facilitating payment”).
- In any deal, we avoid hidden terms or arrangements and reduce complexity wherever possible, because transparent transactions reduce the risk of a bribe or kickback.
- We use partners that have a reputation for integrity, and we report signs that a representative is unethical or could be paying a bribe.
- We hire candidates based on their merits, and do not make hiring decisions to benefit a customer or government official.
- If we make charitable donations, we do so to support a legitimate charitable cause,
not as part of an exchange of favours.
GENERAL GUIDELINES
Personal integrity is an essential ingredient of each employee’s job. Gunship Group employees must maintain a reputation of honesty and integrity to keep the trust and confidence of the public and the customers of Gunship Group.
All employees must conduct themselves according to the highest ethical standards of honesty and integrity. The overriding principles that employees must adhere to are:
- Do not participate in dishonest, destructive, or illegal acts of any kind, including those against Gunship Group property or property entrusted to Gunship Group, revenue, customers, or other employees.
- Do not use employment with Gunship Group or Gunship Group name to further personal interests.
- Do not use Gunship Group facilities provided to you for business – like IT equipment, stationery, internet access, telephone lines, business travel etc. – for any personal purpose in an unreasonable or improper manner.
- Do not attempt to justify an illegal or dishonest act by claiming a superior directed it, and do not direct fellow Gunship Group employees to commit such acts in performing their duties.
- Observe all laws and regulations that apply to Gunship Group business.
- Do Not deviate from company policies, rules or procedures, even if doing so might appear to be in Gunship Group advantage. Promptly alert the HR team whenever any dishonest, destructive, or illegal act is observed, learned of, or even suspected.
- Cooperate with HR Team when alleged misconduct is being investigated. Comply with company rules involving the use of visible identification cards, package inspection, personal property registration, and other rules for protecting employees, information, and assets.
Violations of ‘Gunship Group Code of Business Conduct’ or commission of dishonest or illegal activities on Gunship Group premises or while conducting Gunship Group business, may result in disciplinary action up to and including immediate dismissal and legal measures. The fact that an illegal or dishonest act or prohibited act may be considered minor in nature will not be a justification for the mitigation of any disciplinary or legal action taken by the company. Employees reporting COBC violations in good faith will be protected by the company from any retaliation.