Victor Ek Moving - Anti-Bribery & Anti-Corruption Policy 2016
This Anti-Corruption and Bribery policy complements Victor Ek’s Code of Ethics. The Victor Ek Code of Ethics emphasizes that the values promoted in the Code must underlie all actions at work. These values are honesty, integrity, respect for others and building strong and sustainable relationships in an appropriate way. Victor Ek's policy is to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. The purpose of this policy is to set out the responsibilities of all Victor Ek employees in observing and upholding our position on bribery and corruption; and to provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues. Bribery and corruption are punishable for individuals in many countries of the world and if we are found to have taken part in corruption we could face fines, be excluded from tendering for public contracts and face damage to our reputation. We therefore must take our legal responsibilities very seriously. In this policy, third party means any individual or organization you contact or cooperate with during the course of your work for Victor Ek, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
TO WHOM THE POLICY APPLIES
This policy applies to all individuals working at all levels within Victor Ek, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers and agency staff, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).
WHAT IS BRIBERY
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
GIFTS AND HOSPITALITY This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. The giving or receipt of gifts is not prohibited, if the following requirements are met:
- it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits
- it complies with local law
- it is given in our name, not in your name
- it does not include cash or a cash equivalent (such as gift certificates or vouchers)
- it is given openly, not secretly
Gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
WHAT IS NOT ACCEPTABLE
It is not acceptable for you (or someone on your behalf):
- give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
- give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure
- accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them
- accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return
- threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy - Engage in any activity that might lead to a breach of this policy.
FACILITATION PAYMENTS AND KICKBACKS
We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your manager. Kickbacks are typically payments made in return for a business favor or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
We do not contribute to political parties. Any charitable donations must be legal and ethical under local laws and practices. No donation may be offered or made without the prior approval of your manager.
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption are set out in the Schedule. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
We must keep financial records and have appropriate internal controls in place, which will evidence the business reason for making payments to third parties. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts may be kept "off-book" to facilitate or conceal improper payments.
HOW TO RAISE A CONCERN
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, inform your manager. In the event you consider your manager will not deal with any issue appropriately, the issue should be reported to Victor Ek Quality Control Team, in the first instance by email to firstname.lastname@example.org
WHAT TO DO IF YOU ARE A VICTIM OF BRIBERY OR CORRUPTION
It is important that you tell your manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.
TRAINING AND COMMUNICATION
Training on this policy forms part of the introduction process for all staff members. All existing workers will receive regular, relevant training on how to implement and adhere to this policy. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
WHO IS RESPONSIBLE FOR THE POLICY
Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training.
MONITORING AND REVIEW
Victor Ek’s Quality team will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Victor Ek’s Quality team.
Victor Ek collects your personal information to provide services, to inform of changes and/or notify of the process. Victor Ek may provide collected information to third party in the supply chain, related in providing local moving services, international, warehousing, packing, which includes administrative, operational and commercial activities resulting from such services.
PERSONAL DATA SECURITY
Victor Ek collects the following information:
- Name, occupation, address, telephone number and email address.
- Volume and weight of the shipment, inventories, address of collection and destination, dates and places of storage
- Copies of passport and visas, customs documentation procedures, insurance policies
- Other information if needed to comply with the local regulations
We collect data personally and confidentially by mail with a disclaimer notice or by phone or during pre-move survey. We also may collect some personal data from the information you give when complete a quote request form on our website.
Information that customers give to Victor Ek is collected, used, retained, and disclosed confidentially in all our supply chain including subcontractors, suppliers, freight forwarders and other people working on behalf of Victor Ek. Your personal information will be held confidentially, not alienated, disclosed, not shared with a third party (no part of supply chain), except when the personal information is requested by legal authorities or to comply with the local regulations.
Victor Ek agrees not to use or disclose personal information for any purpose other than the purpose for which it provides services, to store all information in a secure environment and to make all reasonable efforts to maintain the security of confidential information, based on the company values.
Victor Ek stores all personal information collected on a server with an up-to-date protection from any unauthorized access. Any information you provide through our forms available on the website is protected with absolute confidentiality.
ACCESS TO PERSONAL DATA
Any individual who shares their personal information with Victor Ek to use our services has the right to access, change, remove or add any details for the purpose given by e-mail or phone call. We will ensure the proper identity of the applicant.
Victor Ek keeps every staff member aware of code of ethics through regular internal trainings to update their knowledge about protection of the personal data.