Code of Conduct and Anti-Bribery & Corruption Policy
Why do we have this policy?
This policy covers the principles and requirements on Anti-Bribery and Corruption (ABAC), and maintenance of business documentation and financial records. This policy aligns with relevant international and domestic ABAC laws. In case of conflict between our controls and laws, the stricter rule applies.
Who needs to follow it?
Document Audience Scope
This policy applies to all Europe Business Assembly staff and third parties acting on our behalf.
Roles and Responsibilities
This policy has specific responsibilities for:
Mr Ivan Savvov (Business Owner) is responsible for making sure that any relevant controls in this document are complied with by all Europe Business Assembly Staff and third parties as required.
We have a zero tolerance towards all forms of corruption. Corruption includes, but is not limited to:
- 1. Bribery
- - We do not, directly or through a third party, promise, offer, make, authorise, solicit or accept any financial or other advantage, to or from anyone to obtain or retain business, or secure an improper advantage in the conduct of
- - Financial or other advantage covers anything of value, including cash, gifts, services, job offers, loans, travel expenses, entertainment or hospitality. Personal funds cannot be used to circumvent this
- - We prohibit all facilitation payments as they are bribes. Facilitation payments are unofficial, improper, small transfers of value offered or made to secure or expedite a routine or necessary action to which we are legally
- 2. Money laundering
- - We do not conduct transactions that involve a benefit, property or proceeds resulting from crime including bribery, fraud and tax avoidance. Conducting those transactions may result in a breach of anti-money laundering laws and may require external reporting.
- 3. Tax evasion
- - We do not facilitate the evasion of
- 4. Fraud
This applies to our interactions with government officials and persons in the private sector.
If you breach this policy you may also be breaking the law and there may be consequences for you and/or Europe Business Assembly (EBA). You could face disciplinary action that could lead to you losing your job, being fined and/or sentenced to prison.
We are committed to maintaining accurate and transparent financial records.
Our ABAC Principles and Governance
Our four ABAC Foundational Principles are in line with our corporate values and expectations. They help us analyse if corruption is a risk:
- 1. Legitimacy of intent: our activities, interactions and transactions have a valid purpose and are conducted in line with our values and expectations. Ask yourself:
- - Is what I am doing legal and in line with EBA values, expectations and standards?
- - Am I suspicious about the transaction, the parties and/or the assets involved?
- - Would my or the company's reputation be impacted if what I am doing was made public?
- 2. Transparency: everything we do is open, transparent and properly documented. Ask yourself:
- - Will there be enough documentation to show why my actions were appropriate?
- - Have the details of the transaction been accurately recorded?
- - Could my actions be seen as trying to attain a hidden objective?
- 3. Proportionality: transfers of value made and resources invested meet but do not exceed the needs of the interaction or transaction. Ask yourself:
- - Do we need this service?
- - Can we use EBA resources?
- - Is the payment at fair market value (FMV)?
- - Is the amount of product requested for donation proportionate to the need?
- - Is the transaction in line with our previous transactions with the third party?
- 3. No conflict of interest or undue influence: we do not exercise undue influence over those who interact with us. We avoid situations that create or appear to create conflicts of interest. Ask yourself:
- - Could any activity be seen as an attempt to improperly influence our business?
- - Am I showing favouritism with a third party because of the relationship that I have with them?
- - Have I taken the right steps to manage any actual or perceived conflicts of interest?
The questions above are not exhaustive and are only suggested as examples.
Our ABAC Policy follows risk assessment rules supported by our leadership:
- - Our leadership lead by example, making us aware of the ethical importance and critical role of our ABAC
- - We perform a risk assessment to determine the company’s we work with exposure to bribery and corruption risk.
- - To assess and mitigate risks we use internet search to find out about a particular level of bribery of a particular country or involvement of a particular company in any illegal activities involving bribery or money-laundering. We also may consult local Chamber of Commerce, UK diplomatic missions or UK Trade and Invest for advice or search on Government-sponsored Business Anti-Corruption Portals.
- - Our websites ebaoxford.co.uk provide awareness about our ABAC Policy across the organization and for third parties including customers and suppliers.
We take proportionate approach based on the perceived level of risk as per rules stated above:
- If we assess the risk as low then we just need to satisfy ourselves that the people perform services for us or become our clients are genuine and someone we can trust to do business without bribing. We may make enquiries with business contacts, local chamber of commerce or business associations or via the internet.
- If we assess the risk as higher, we ask our clients for their passport, CVs, financial statements, and other relevant references.
The aim of the above is to satisfy ourselves that organisations we deal with can be trusted not to be involved in any kind of bribery activities or money laundering.