The following anti-corruption Policy (“Policy”) was adopted by GlobGlo.
GlobGlo including its affiliates and its subsidiaries (collectively, the “GlobGlo”), value honesty, transparency, integrity, and professionalism in dealings with suppliers, competitors, clients, government officials, and all other parties GlobGlo is involved in business dealings with.
This Policy applies to all employees, officers, directors, and independent contractors of the Company worldwide (“Personnel”). This document gives specific details on GlobGlo’s Policy prohibiting corruption in the performance of GlobGlo’s business operations and individual employee responsibilities for ensuring adherence to the Policy.
The goal is to inform Personnel of their anti-corruption obligations and to ensure compliance by Personnel with the GlobGlo’s Policy. It also provides information on how to identify potential risks, deal with challenging situations, and report when those situations violate or may lead to a violation of this Policy.
Questions about the Policy or its applicability to particular circumstances should be directed to GlobGlo.
The Company’s Policy is to engage in business practices in full compliance with (state the specific country laws or provisions that your company complies with, e.g., the Foreign Corrupt Practices Act of 1977 (FCPA) in the United States, the Corruption of Foreign Public Officials Act (CFPOA) and the Criminal Code in Canada, or the Anti-Bribery Act, 2010 in the United Kingdom) together with all other anti-corruption and anti-bribery laws and regulations applicable to the Company’s business anywhere in the world (“Anti-Corruption Laws”).
The Company has zero tolerance for any corruption in business activities. Bribes or other improper or unauthorized payments that directly or indirectly make, offer or promise to make, kickbacks, benefits, or advantages to any person, individual, organization, or entity, are prohibited by this Policy. A violation of this Policy can occur even if a bribe or other corrupt practice fails to achieve the desired outcome.
Personnel is expected to adhere to both the spirit and the letter of this Policy concerning all aspects of the Company’s business anywhere in the world. It is the responsibility of Personnel to be aware of how each situation may violate or lead to a violation of this Policy and Anti-Corruption Laws.
Gifts are commonly offered as gestures of gratitude or tokens of appreciation, but in some situations, they can also be construed as bribes. The Company does allow gifts made in good faith, but they must comply with this Policy.
Personnel must ensure that any gifts are of value in proportion to the situation at hand, and any gifts should be infrequent to avoid being perceived as an attempt to influence an act or a decision. When offering or accepting a gift, Personnel should specifically consider the following:
- The intended outcome: Gifts can have many purposes, such as expressing appreciation and building a relationship, but they can also be viewed as an attempt to influence a direct result, e.g., to win a bid or affect the negotiation process.
The Company’s reputation: The gift may be a private act, but if it were to come to the public’s attention, Personnel should consider how it would affect the reputation of the Company.
Competition: A general rule of thumb is to think about how the Company would perceive a similar gift made by a competitor.
If Personnel should fail to comply with this Policy or Anti-Corruption Laws, they will be subject to disciplinary action up to and including termination of employment or other relationship with the Company. Restitution could also be required, and civil or criminal action against individual Personnel could be warranted.
If Personnel is involved in or aware of a situation they believe may violate or lead to a violation of this Policy, they must ask for guidance from their manager or other personnel in a superior position.