Sustainability

No Facilitation & No Revolving Door

Definitions
           1. Facilitation Payments     Refers to informal payments made to government officials solely to ensure that they perform a routine process or to expedite such a process — where the process requires no discretion on the part of the official and falls within their lawful duties — and where the legal entity is already entitled to the service or right by law. Examples include applications for licenses, certificates, and public services.
           2. Government Officials / State Employees    Refers to individuals who are or were government officials, politicians, or advisors to government agencies, and who subsequently join the Company — and may leverage their connections or insider knowledge to benefit the Company or create conflicts of interest in the performance of duties within government agencies or organizations. Such conduct is intended to gain an unfair business advantage or to influence policy in favour of the Company for which the former official works.

Guidelines
           1. The Company has a strict policy of making no facilitation payments of any kind, whether directly or indirectly. The Company shall neither take any action nor accept any arrangement in exchange for facilitation of its business operations.
           2. The Company has a policy against hiring currently serving government officials to work within the organization, as this may give rise to conflicts of interest and abuse of authority.
           3. The Company does not second or assign its employees, executives, directors, or advisors to work with any government agency in a manner that may create conflicts of interest or abuse of authority.