Anti-Bribery Policy
Anti-Bribery & Corruption Policy Introduction
- One of CS-International's core values is to uphold sound, responsible and fair business operations. The Company is committed to promoting and maintaining the highest possible ethical standards in relation to all of its business activities. CS-International's reputation for maintaining ethical and lawful business practices is of utmost importance and this policy is designed to preserve these values. CS-International therefore has a zero-tolerance policy towards any form of corruption, including but not limited to making, receiving, or accepting any bribe, corrupt payment, kickback, or facilitation payment, to or from anyone, anywhere in the world.
- All employees and associated persons are expected to adhere to the principles set out in this policy.
Definitions
- Bribery: usually involves giving or offering money, a gift or something else of value to obtain or retain a commercial advantage or to induce or reward the recipient for acting improperly or where it would be improper for the recipient to accept the benefit. Bribery can also take place where the offer or giving of a bribe is made by or through a third party, i.e., an agent, representative or intermediary. Both the giving and receiving of bribes are prohibited.
- Anything of Value: “Anything of value” includes cash and cash equivalents, personal and business benefits, such as gifts, meals and entertainment, travel, offers of employment, forgiveness of debt, directing business to a company, solicitation or providing charitable contributions, or any other transfer of goods, services, tangibles or intangibles that accrues to the benefit of the ultimate recipient or promotes their interests.
- Corruption: is any activity that involves misusing position or power for an improper personal or business advantage, whether in the public or private sectors.
Obligations
- This policy is designed to avoid violations of applicable anti-bribery and corruption laws and prohibits any:
- Offer, promise or give a financial advantage or anything of value to another person (i.e. bribe a person) including but not limited to any employee, agent or representative of a government, political party, and party official or candidate (“Covered Person”) and employees of private and non-governmental entities. A Covered Person generally includes royalty, legislators, representatives of state-owned business enterprises, and employees of public international organisations, regardless of rank or position whether within Germany or abroad, for the purposes of inducing or rewarding improper conduct.
- Request, agreement to receive or accept a financial or other advantage (i.e. a bribe) for or in relation to improper conduct.
- The maintenance of inaccurate or the falsification of books and records detailing transactions and failing to establish and maintain a system of internal controls to reasonably assure all transactions are accurately recorded.
- It is an offence to bribe another person in the course of doing business, for the purposes of obtaining or retaining business, or obtaining or retaining an advantage in the conduct of business, for CS-International. Any employee or associated person, as well as CS-International itself, may be held liable for this offence. CS-International may also suffer substantial reputational damage in connection with this offence.
Policy
- All employees and associated persons are required to:
- Comply with the Bribery Act, FCPA and any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business.
- Act honestly, responsibly and with integrity.
- Safeguard and uphold CS-International's core values by operating in an ethical, professional and lawful manner at all times.
