ANTI-BRIBERY & ANTI-CORRUPTION POLICY
(For Project Site Operations)
1. Purpose
The purpose of this policy is to establish a zero-tolerance approach toward bribery, corruption, unethical payments, and improper business advantages at project sites.
The Company is committed to conducting business with integrity, transparency, and compliance with applicable laws.
2. Scope
This policy applies to:
-
All employees at project sites
-
Contract workers and temporary staff
-
Vendors, subcontractors, and consultants
-
Agents and representatives acting on behalf of the Company
-
Anyone interacting with government officials, clients, or third parties
This policy covers all project site locations.
3. Policy Statement
The Company strictly prohibits :
-
Offering, giving, promising, or authorizing bribes
-
Accepting bribes or kickbacks
-
Facilitating payments (speed money)
-
Improper gifts, hospitality, or benefits intended to influence decisions
-
Any activity that creates an unfair business advantage
The Company maintains zero tolerance for bribery in any form.
4. Definitions
Bribery – Offering, giving, receiving, or soliciting anything of value to improperly influence a decision.
Corruption – Abuse of entrusted power for private gain.
Facilitation Payment – Small unofficial payments made to expedite routine actions.
Government Official – Any officer or employee of a government department, public agency, or regulatory body.
5. Prohibited Conduct
At project sites, the following are strictly prohibited :
-
Offering money, gifts, favors, or benefits to secure work approvals.
-
Providing cash or gifts to inspectors, government officials, or client representatives to influence inspection results.
-
Accepting kickbacks from vendors or subcontractors.
-
Inflating invoices to create funds for unauthorized payments.
-
Approving payments without proper documentation .
-
Making unofficial payments to obtain permits or licenses.
-
Misrepresenting expenses in accounts or records.
6. Gifts & Hospitality Guidelines
-
Modest and reasonable hospitality may be allowed if it is lawful and transparent.
-
Gifts must not influence or appear to influence decision-making.
-
Cash or cash equivalents are strictly prohibited .
-
Any gift above approved value must be reported to management.
-
All gifts must be recorded in a Gift Register (if applicable).
7. Vendor & Subcontractor Compliance
-
All vendors must comply with this policy.
-
Contracts shall include anti-bribery clauses.
-
Due diligence must be conducted before vendor engagement.
-
Payments shall only be made against valid invoices and approved work completion .
-
No cash payments without documented approval.
8. Responsibilities
Project Manager / Site In-Charge:
-
Ensure compliance with this policy at site .
-
Communicate policy to employees and contractors.
-
Monitor financial and procurement transactions.
Employees:
-
Refuse any bribe or unethical request.
-
Immediately report suspicious activities.
-
Maintain transparent documentation.
Accounts Personnel:
-
Ensure accurate and complete financial records.
-
Reject undocumented or suspicious payments.
9. Reporting Mechanism
Any suspected bribery or corruption must be reported immediately to:
-
Reporting Manager
-
Head Office Compliance Officer
-
HR Department
-
Company Whistleblower Channel (if available)
Reports may be made confidentially. Retaliation against whistleblowers is strictly prohibited .
10. Record Keeping
-
All transactions must be accurately recorded.
-
False accounting entries are prohibited.
-
Supporting documents must be maintained for audit review.
-
Periodic internal audits shall be conducted.
11. Investigation Procedure
-
All reported concerns will be investigated promptly.
-
Confidentiality will be maintained .
-
Appropriate corrective and disciplinary actions will be taken.
12. Disciplinary Action
Violation of this policy may result in:
-
Written warning
-
Suspension
-
Termination of employment
-
Blacklisting of vendors
-
Legal action under applicable laws
13. Training & Awareness
-
Anti-bribery awareness shall be included in site induction.
-
Periodic toolbox talks or refresher training shall be conducted.
-
Policy copy shall be displayed at project site office.
14. Policy Review
This policy shall be reviewed periodically to ensure compliance with applicable laws and best practices.