Policy Summary:
The Company is committed to conducting business in accordance with the highest ethical standards and prohibits all forms of bribery and corruption.
This Anti-Bribery Policy (Global) (“Policy”) prohibits bribery of government officials (both U.S. and non-U.S.) as well as private sector (commercial) bribery, including the offering, promising, authorizing or providing anything of value to any customer, business partner, vendor or other third party in order to induce or reward the improper performance of an activity connected with our business.
Either a violation of this Policy or the Company’s Code of Business Conduct (“COBC”) could result in disciplinary actions including, but not limited to, termination of employment.
It is therefore vital that you not only understand and appreciate the importance of this Policy, but also comply with it in your daily work.
If you have any questions about this Policy or applicable Anti-Bribery laws generally, contact Company Legal Counsel (the legal department in your regional or local operation) or the Ethics & Compliance Legal Counsel (“E&C”) at Info@TWCTMT.com.
In conjunction with this Policy, please refer to the Anti-Bribery (“AB”) Process Documents for additional information and details.
For answers to specific anti-corruption-related questions, please review the Frequently Asked Questions (“FAQ”) document.
Purpose and Goals of Policy:
This Policy is intended to outline the Company’s risks related to bribery and corruption, to highlight your responsibilities under both the relevant anti-corruption laws and Company policies, and to provide you with the tools and support necessary to identify and combat those anti-corruption risks.
Risks and/or Consequences of Non-Compliance:
A violation of relevant anti-corruption laws can lead to severe civil and criminal penalties and reputational harm to our Company.
Company employees that violate these laws can also face severe civil and criminal penalties, including jail time.
The prohibition against bribery is incorporated into our COBC; thus, a violation of this Policy could also result in disciplinary actions pursuant to our COBC including, but not limited to, termination of employment.
Scope and Range of Application:
Our company expects all employees, officers, directors, and third parties working on its behalf to refrain from engaging in any form of bribery or corruption, irrespective of citizenship, domicile, or location.
In addition to this general prohibition on bribery and corruption, this Policy and the AB Process Documents set forth several policy and procedural requirements that apply to all employees of TW Consulting & Trade Ltd and its world-wide majority-owned or controlled subsidiaries.
4. Policy Details
4.1 Applicable Laws
Employees of the Company must abide by all applicable Anti-Bribery laws, including the FCPA, the UKBA, and the local laws in every country in which we do business.
Virtually every country in which we operate prohibits bribery.
These laws generally prohibit both bribery of government officials and private sector (commercial) bribery.
In addition to the prohibition of bribery, the FCPA mandates that companies establish and maintain accurate books and records and adequate internal controls.
4.2 Prohibition of Bribery
Government Bribery
The Company and its employees are prohibited from giving, promising, offering, or authorizing payment of anything of value to any government official (both U.S. and non-U.S. officials) to obtain or retain business, to secure some other improper advantage, or to improperly influence a government official’s actions.
Additionally, Company associates must also avoid the appearance of improper interactions with government officials.
Refer to the AB Process Documents for more information on the broad definition of “government official”.
Commercial Bribery
The Company prohibits employees from offering or providing corrupt payments and other advantages to or accepting the same from private (non-government) persons and entities.
Such payments constitute commercial bribery and are often called “kickbacks.”
Facilitation Payments
The Company’s prohibition on bribery applies to all improper payments regardless of size or purpose, including “facilitating” or “expediting” payments.
Facilitating payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services.
Generally, facilitation payments are prohibited by this Policy, except for a very limited set of circumstances for which prior written approval must be obtained from both Company Legal Counsel and E&C.
4.3 Providing Items of Value to Government Officials
Government Dealings Approval Tool (GDAT)
Before providing an item of value to any government official or entity, employees must first obtain prior written approval from Company Legal Counsel via GDAT.
Items of value provided to government officials must also be accounted for in accordance with Standard Practice and Procedure (SPP) 2.8.
Gifts, Meals, Travel and Entertainment (GME)
It is never permissible to provide gifts, meals, travel, or entertainment in exchange for any improper favor or benefit.
Gifts of cash or cash equivalents, such as gift cards, are never permissible.
Prior approval via GDAT is required before providing GME to a government official or entity.
Donations
It is never permissible to provide a donation to improperly influence a government official.
Prior approval via GDAT is required before making such a donation.
Promoting, Demonstrating, or Explaining Products
Company associates must seek prior approval via GDAT before directing promotional activities to a government official or entity.
Hiring or Engaging Government Officials
Before hiring a government official or relative thereof, Company associates must first receive legal approval via GDAT.
Political Contributions
Political contributions must follow the Request for Approval (RFA) process and Company policy.
Employees should contact Company Legal Counsel and Public Affairs and Communication (PAC) personnel for guidance.
Limited Exceptions
Limited exceptions include blanket approvals, personal safety concerns, or rare cases where GDAT approval cannot be obtained.
Refer to AB Process Documents for details.
4.4 Third-Party Management
Third parties acting on behalf of the Company are prohibited from making corrupt payments.
All payments must be reasonable, documented, and not made in cash without prior approval.
Due Diligence
Third parties interacting with government officials must complete due diligence before engagement.
Red flags must be resolved before entering relationships.
Due diligence must be renewed every three years.
Certification
Applicable employees must certify compliance quarterly as part of SEC processes.
Training
Anti-Bribery training is required every other year for designated employees including managers and relevant staff.
Auditing
Internal audits will be conducted periodically to ensure compliance.
Employees must cooperate fully with audits and investigations.
Reporting Violations
Employees must report suspected violations to Company Legal Counsel.
Reports will be treated confidentially where permitted by law.
Retaliation is strictly prohibited. Failure to report violations may result in disciplinary action.
Contact Us
If you have any questions about Our Cookie Policy, You can contact us:
By email: support@twctmt.com