Integrity • Accountability • Trust
M&C Logistics and Trading Ltd is committed to maintaining high standards of integrity and accountability in conducting our business. Compliance with applicable laws is a fundamental principle that guides our corporate culture and how we conduct our business. This Anti-Bribery and Corruption policy embodies this commitment and provides a framework of guidelines and principles to encourage ethical behavior in our business.
Compliance with applicable anti-bribery and anti-corruption laws is critical to preserving the company’s corporate integrity, reputation, and operational flexibility. As such, this Policy clearly states that bribery and other corrupt behavior is strictly prohibited.
This Policy applies to all of the Company’s directors, officers, and employees, as well as to all third-party intermediaries, business partners, contractors, consultants, agents, or representatives that are authorized to do work for the Company. In this Policy, these individuals are sometimes referred to as “you” or “your.” Reference to the Company in this Policy includes its subsidiaries, affiliates, and joint ventures, wherever located.
The Company conducts its business in compliance with all applicable laws prohibiting bribery of public officials and commercial bribery. The value of the Company’s reputation as a lawful and ethical actor far outweighs the value of potential business lost by refusing to make an improper payment. Accordingly, you must not directly or indirectly (including through an agent) offer, promise, provide, or authorize any form of bribe or improper incentive to any person, whether a customer, supplier, business partner, Government Official, or anyone else, on the Company’s behalf. You must also not directly or indirectly demand, solicit, or accept any improper payment or give or receive kickbacks in any form or participate in any other improper or hidden compensation scheme.
You are prohibited from offering, promising, providing, or authorizing the payment or giving of anything of value to any Government Official (whether directly or indirectly through third parties) to get or keep business or otherwise to secure any improper advantage for the Company. The belief that “that’s the way business is done” in some part of the world will not protect you or the Company from severe legal penalties that can apply to such conduct, nor will it protect you from disciplinary measures resulting from violations of this Policy.
Gift-giving, meals, entertainment, and sponsored travel can pose special challenges in dealing with Government Officials. While you cannot give anything of value to a Government Official to get or keep business or to otherwise gain an improper advantage, upon prior written approval of your General Manager, you may provide reasonable gifts, meals, entertainment, and sponsored travel to Government Officials where there is a legitimate business purpose and the thing of value is not being provided in exchange for any action or inaction by the official.
Requests for approval of any proposed gifts, meals, entertainment, or sponsored travel should be submitted in writing to your General Manager or Country Manager with sufficient time for such individual to review the request and consult with the Compliance Officer if necessary. The Company may also put in place additional guidelines and procedures for review and approval of donations and gifts. If you have any questions about whether a proposed gift, meal, entertainment, or sponsored travel is appropriate, you should consult your General Manager.
Although significant portions of this Policy are focused on improper payments to Government Officials, it is important to understand that commercial or private sector bribery is also illegal in many jurisdictions. Commercial bribery means providing a financial or other advantage to an individual (including a representative of a current or future business partner) to induce, obligate, reward, or cause that person to behave improperly. It can include providing direct financial benefits such as payments and kickbacks as well as entertainment or trips to individuals in order to win business.
Engaging in commercial bribery is prohibited under this Policy. Business decisions must be based on objective criteria. You may not request, agree to accept, or accept a bribe or kickback from a current or prospective business partner. If you have any questions about whether a proposed gift or business entertainment event is appropriate, you should consult your General Manager, Country Manager, or the Compliance Officer.
Any donations made by or on behalf of the Company must be based on legitimate philanthropic objectives. While donations generally to a community organization or a particular cause can be appropriate, donating to a Government Official’s favored charity in exchange for favorable action by that official can constitute a bribe. For any donations made by or on behalf of the Company, you must obtain prior written approval from your General Manager, Country Manager, or the Compliance Officer.
The Company shall maintain at all times accurate books and records to fulfill the Company’s obligations and to ensure accurate and effective reporting in accordance with applicable laws and regulations. As with receipts and expenditures generally, any expenditure that the Company funds or other use of the Company’s resources must be accurately described in supporting documents and accurately reflected in the Company’s books and records.
All known or suspected violations of this Policy, whether by the Company personnel or by third parties acting on the Company’s behalf, must be promptly reported. Any violation of this Policy can subject both you and the Company to severe criminal and civil penalties. Any violation of this Policy will be taken seriously and will lead to appropriate disciplinary measures up to and including termination of the employment or business relationship.
Upon commencement of your employment or association with the Company, you must sign an acknowledgement form confirming that you have read and understand this Policy and agree to comply with it. Requests to make similar acknowledgements may be made on an annual basis.