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Anti-Bribery and Corruption Policy

POLICY STATEMENT

It is our policy to conduct our business in an honest and ethical manner. 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 by implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all business operations.

SCOPE

This policy applies to all employees of Hamik Energy Limited and shall be communicated to them at the outset of our business relationship and as appropriate thereafter.

GIFTS, INVITATIONS & HOSPITALITY

Employees are prohibited from accepting a gift or giving a gift to a third party in the following situations:

  • It is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
  • It is given in your name and not in the name of the Company;
  • It includes cash or a cash equivalent (such as gift certificates or vouchers);
  • It is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process); and
  • It is given secretly and not openly.

FACILITATION PAYMENTS & KICKBACKS

In many areas, making Facilitation Payments is illegal. We do not make, and will not accept, Facilitation Payments or Kickbacks of any kind anywhere in the world.

YOUR RESPONSIBILITIES

It is not acceptable for you (or someone on your behalf) to:

  • Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  • Give, promise to give, or offer, a payment, gift or hospitality to a Public Official or Third Party to ‘facilitate’ or expedite a routine procedure;
  • Accept payment from a Third Party that you know, or suspect is offered with the expectation that it will obtain a business advantage for them;
  • Accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
  • Threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
  • Engage in any activity that might lead to a breach of this policy or perceived breach of this policy.

OTHER RESPONSIBILITIES

  • It is your responsibility to ensure that all accounts, invoices and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off-book’.
  • You must ensure all expense claims relating to Gifts, Invitations & Hospitality or expenses incurred to Third Parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.
  • All Employees have the responsibility to read, understand and comply with this policy. You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.
  • Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
  • This policy should be read in conjunction with the Company’s Code of Ethics.
  • Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their line manager or other available reporting mechanisms.

PROTECTION

Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future will be protected from detrimental treatment/retaliation. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.

GOVERNANCE

Management has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Administrative Manager, HSE Manager and Operations Manager have primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness.  Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it, and any changes made to it.