I. INTRODUCTION
This Anti-Bribery and Corruption Policy (the “Policy”) establishes the framework and requirements for conducting MCS IT Distribution Ltd.’s (the “Company”) business in an ethical, honest, and transparent manner. The Company has a zero-tolerance approach to bribery and corruption and is dedicated to acting professionally, fairly, and with integrity in all business dealings and relationships wherever it operates.
II. PURPOSE
The purpose of this
Policy is to:
- Set out the responsibilities of the Company and its employees in observing and upholding the Company‘s position on bribery and corruption;
- Provide information and guidance on how to recognize and deal with bribery and corruption issues.
III. SCOPE
This Policy applies to all employees (whether permanent, temporary, or part-time), directors, officers, contractors, consultants, agents, intermediaries, and any other third parties acting on behalf of the Company, regardless of location.
IV. DEFINITIONS
- “Bribery” means offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust.
- “Corruption” means the abuse of entrusted power for private gain.
V. PROHIBITED CONDUCT
Any of the persons stipulated in Clause III (Scope) must not:
- offer, give, solicit, or accept any bribe, whether in cash or any other form, to or from any person or company;
- offer or accept gifts, hospitality, or entertainment that could be perceived as intending to improperly influence a business decision;
- use charitable donations or sponsorships as a means to conceal bribery;
- facilitate or engage in “facilitation payments” (i.e., unofficial payments made to secure or speed up routine governmental actions).
VI. GIFTS AND HOSPITALITY
VI.1 Gifts and hospitality are allowed only if they:
- are of reasonable value and not lavish or excessive;
- are given or received in good faith and for legitimate business purposes;
- are not intended to improperly influence a decision or gain unfair advantage.
VI.2 All gifts and hospitality above a certain threshold (as defined by internal guidelines) must be recorded in the Gift and Hospitality Register and approved by management.
VII. RESPONSIBILITIES
VII.1 Employees: must read, understand, and comply with this Policy. Employees are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
VII.2 Management: must ensure that all employees are trained and informed of this Policy. Management is responsible for the enforcement of this Policy within their departments.
VII.3 Third Parties: must comply with the principles of this Policy as a condition of their relationship with the Company.
VIII. REPORTING CONCERNS
Employees are encouraged to report any suspected bribery or corruption activity via the Company whistleblowing procedure or directly to their manager, the compliance officer, or HR. Reports will be treated confidentially and investigated promptly.
IX. RECORD-KEEPING
The Company must keep accurate and complete financial records and have appropriate internal controls in place to prevent bribery and corruption.
X. TRAINING AND COMMUNICATION
All employees will receive appropriate training on this Policy and relevant anti-bribery laws. The Policy will also be communicated to third parties, suppliers, and business partners.
XI. BREACH OF THIS POLICY
Any employee who breaches this Policy will face disciplinary action, which may include dismissal. The Company may also terminate its relationship with other individuals and organizations working on its behalf if they breach this Policy.
XII. REVIEW OF POLICY
This Policy will be reviewed annually and updated as necessary to ensure its continued effectiveness and compliance with applicable laws and regulations.