Anti-bribery and corruption policy

Ethical Business Commitment ECW-COR–00007 Rev 0 (E) Effective: 28th May 2013

ECW Logistics BV Anti‐Bribery and Corruption Policy Statement

 

ECW Logistics BV in its almost 20 year history has and continues to be committed to applying the highest standards of ethical conduct and integrity in its business activities wherever it does business. Every employee and individual or organisation acting on ECW’s behalf is responsible for conducting ECW’s business honestly and professionally.

ECW Logistics considers that bribery and corruption has a detrimental impact on business. We aim to carry out business in a transparent and ethical way and by helping to ensure that there is honest, open and fair competition in the sectors where we do business.

ECW Logistics does not tolerate any form of bribery by, or of, its employees or any persons or companies acting for it or on its behalf. The Shareholders, Board and senior management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, in accordance with the UK Bribery Act (2010) and the United States Foreign Corrupt Practices Act (1977) amongst others.

ECW Logistics has issued its Values and Code of Conduct which sets down the ethical behaviour expected of every employee and individuals or organisations acting on ECW’s behalf. All employees and those individual or organisation acting on ECW’s behalf are required to familiarise themselves and comply with this Values and Code of Conduct statement.

Bribery is defined as offering, paying, promising or giving, directly or indirectly, anything of value to another company’s agent, representative, intermediary or employee, with the intent to influence the recipient’s action in relation to that company’s affairs or business. This includes facilitation or grease payments or any other unofficial payments for routine governmental action.

Employees and others acting for or on behalf of ECW are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of our anti‐bribery policies, ECW Logistics is committed to only offer and receive transparent, proportionate, reasonable and legitimate hospitality, gifts and promotional expenditure or charitable giving.
A breach of this ethical behaviour policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.

Employees and other individuals acting for ECW Logistics should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for ECW Logistics.

ECW will not conduct business with service providers, agents or sub-contractors or representatives that do not support and commit to follow ECW’s anti‐bribery and corruption objectives.

The success of ECW’s anti‐bribery measures depends on everyone playing their part in helping to detect and eradicate bribery.
Therefore, all employees and others acting for, or on behalf of, ECW are encouraged to report any suspicious activity by calling the ECW Compliance Helpline on: +31 6 4222 3453 All concerns raised in good faith will be taken seriously and handled in line with ECW’s investigations procedure.

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