ANTI-BRIBERY AND CORRUPTION POLICY STATEMENT FOR DANG CONSULT LTD.
DANAG conducts its business professionally, with integrity and in compliance with the laws of those jurisdictions in which it operates. Our reputation for acting fairly is built on our values as a company and the values of our employees. As part of our commitment to ethical business practices, we will not tolerate acts of bribery or corruption.
They are intended to ensure that DANAG personnel, and those acting on our behalf, behave in a manner that is consistent with anti-bribery and corruption laws in all countries in which DANAG does business.
1.1 DANAG CONSULT LTD. is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on DANAG CONSULT LTD. behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.
1.2 We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
1.3 The purpose of this policy statement is to:
- set out our responsibilities,and of those working or providing services for us,(which for the purpose of the Bribery Act includes service providers of DANAG CONSULT LTD.), in observing and upholding our position on bribery and corruption;
- provide information and guidanceas to how we expect those working for us to conduct themselves and how to recognize and deal with bribery and corruption issues; and
- how to raise concerns with us including any breaches of this policy statement
1.4 DANAG CONSULT LTD’s Board and Executive Committee are committed to implementing and enforcing effective system.
A bribe, broadly, is an inducement or reward offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. This can be in the context of giving or receiving. An offence is committed when the bribe is coupled with an intention of inducing, a reward for or in anticipation for a person to improperly perform their function or if the request, agreement to accept or acceptance of the bribe itself constitutes or is believed to constitute the improper performance of an activity. In addition, offering a bribe to a foreign public official to induce that public official to obtain or retain
business or an advantage in the conduct of business (and that is not permitted by local laws), will also be an offence.
The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for us, or supplying services to us, or under our control.
4.1 DANAG CONSULT LTD. permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure (given and received) to or from third parties that is undertaken:
a. for the purpose of establishing and maintaining good-business relationships
b. to improve the image and reputation of DANAG CONSULT LTD.
c. to present DANAG CONSULT‘s goods/services effectively
Provided that it is:
a) in good faith
b) not offered, promised or accepted to secure an advantage for its employees or associated persons or to influence the impartiality of the recipient
4.2 The giving of gifts by DANAG CONSULT employees with an approximate value of £50 or higher (or the local equivalent in Ghana) is prohibited unless they have been given prior approval by their Head of Department. With regard to our employees receiving gifts, unless approval has been provided by the appropriate Head of Department, gifts that exceed a £50 threshold must be declined and will be recorded. Gifts in the form of cash must never be accepted by our employees or service providers and therefore must not be offered and any offers of cash must be immediately reported to the relevant DANAG CONSULT Executive Committee member. The giving or receiving of promotional material is not considered a gift.
a) give, promise to give, or offer, a payment, gift or hospitality to a third party with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
c) give, offer or promise to a foreign public official to induce that public official to obtain or retain business or an advantage in the conduct of business (and that is
not permitted by local laws), request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them;
d) request, agrees to receive or accept payment from a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for theme) accept a gift or hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by DANAG CONSULT in
e) accept a gift or hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by DANAG CONSULT in return ;
f) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; and
g) engage in any activity that might lead to a breach of this policy
We and our service providers are expected to keep financial records and have appropriate internal controls in place which will evidence the business reason for giving and/or receiving payments from/to third parties.
If you believe this policy has been breached, or suspect it may have been breached, in any way please contact DANAG CONSULT Director or Economic and Organized Crime Office in Ghana.