Scope and Purpose
The purpose of this Anti-Bribery & Anti-Corruption Policy is not only prevent bribery and corruption but also safeguard the integrity and reputation of Offshore Global Logistics. While this policy is comprehensive, it should be noted that stricter local laws or regulations will take precedence.To whom does this Policy extend?
This policy is applicable to all individuals within Offshore Global Logistics, including employees, officers, and directors. It encompasses not only those directly employed by Offshore Global Logistics or its affiliates but also includes temporary workers who are assigned by a staffing agency to work on behalf of Offshore Global Logistics.Where does this Policy Apply??
We are committed to conducting all our operations and activities in compliance with applicable laws and regulations. As a result, this policy is applicable to all Offshore Global Logistics activities worldwide.What is Bribery and Corruption?
Corruption is the improper exploitation of entrusted power for personal gain or for the benefit of one's family, friends, or acquaintances. This can manifest in forms such as bribery, kickbacks, and conflicts of interest.Bribery refers to the inappropriate act of offering, giving, promising, receiving, accepting, authorizing, or soliciting something valuable to or from a person or entity in order to gain or maintain a business or other advantages. The term "something valuable" encompasses both tangible and intangible goods, as well as other items or benefits that hold economic value.
Bribery encompasses a wide range of actions, including, but not limited to:
- Public bribery involving individuals within the government sector.
- Private bribery involving the commercial sector.
- Both direct and indirect bribery, which may involve the use of intermediaries, agents, subcontractors, or other third parties to facilitate the exchange of bribes.
- Kicking back a portion of a contract payment or any other form of benefit to another party, or receiving a kickback.
- Facilitation payments, which refer to unofficial payments made to expedite actions that the payer is already entitled to, or other unofficial payments made to government officials in order to secure certain favours or advantages.
Offshore Global Logistics has a strict policy against bribery and corruption, which means that employees, officers, and directors are prohibited from engaging in the following activities:
- Any form of bribery or corruption, whether active or passive, direct or indirect. Enabling such actions is also strictly forbidden.
- Arranging, giving, offering, or approving bribes or any improper transfers of value, even if they are intended to benefit Offshore Global Logistics.
- Involvement in facilitation payments, whether making, receiving, or participating in such transactions.
- Soliciting or accepting bribes, kickbacks, or any improper transfers of value for personal gain or on behalf of family, friends, acquaintances, or co-workers.
- Receiving, approving, or offering gifts or entertainment that are deemed unreasonable, inappropriate, or disproportionate. This applies regardless of whether the recipients are government officials or other business partners, as it should not unduly influence business decisions.
- Holding external positions or engaging in activities outside of Offshore Global Logistics that could potentially create conflicts of interest or be perceived as such.
- Engaging in actions that provide unwarranted preferential treatment, whether utilizing company resources or not, for the benefit of family, friends, acquaintances, or creating an appearance thereof.
- Entering into agreements on behalf of Offshore Global Logistics that could be seen as conflicts of interest or give rise to such perceptions.
- Making monetary or in-kind contributions, on behalf of Offshore Global Logistics, to government officials, political parties, organizations, or individuals involved in politics or charities closely associated with government officials
ORGANIZATIONAL MEASURES
Offshore Global Logistics has implemented a comprehensive set of controls to address potential issues related to bribery and corruption. These controls include:- Conducting regular risk assessments to identify areas of vulnerability and potential risks.
- Establishing robust policies and guidelines that outline the expected behaviour and standards regarding bribery and corruption.
- Providing training programs and effective communication channels to educate employees about their responsibilities and the company's zero-tolerance policy towards bribery and corruption.
- Conducting audits and implementing monitoring systems to ensure compliance with the established policies and guidelines
- Establishing clear reporting channels that allow employees, business partners, and other stakeholders to report any concerns or suspected violations related to bribery and corruption.
- Initiating thorough investigations to assess reported concerns and allegations, and implementing appropriate disciplinary processes to address confirmed cases of bribery and corruption.
By implementing these measures, Offshore Global Logistics aims to prevent, detect, mitigate, and resolve potential bribery and corruption issues effectively. Violation of this policy is considered a significant breach of Offshore Global Logistics' Code of Conduct, and appropriate disciplinary actions will be taken, which may include the termination of employment. In certain circumstances, Offshore Global Logistics may also report the violation to enforcement authorities.
Conflicts of interest
Offshore Global Logistics requires its employees to proactively avoid any conflicts of interest and to disclose any situations where such conflicts may arise or be perceived. Ancillary activities or outside financial interests should not compromise an employee's integrity, objectivity, or pose a risk to Offshore Global Logistics. It is important for employees to disclose potential conflicts of interest and to seek prior written permission from Offshore Global Logistics, in accordance with the Conflict-of-Interest Guidelines and relevant policies and procedures, before engaging in any ancillary activities.Furthermore, Offshore Global Logistics strictly prohibits employees from making or receiving facilitation payments.
Keeping Accurate Books and Records
Offshore Global Logistics emphasizes the need for employees to maintain accurate books and records of business transactions. This includes ensuring proper registration and documentation of various activities, such as expenses claimed by Offshore Global Logistics employees and exchanges of gifts and entertainment with third parties. By upholding these practices, Offshore Global Logistics promotes transparency, integrity, and compliance with financial and regulatory standards. Accurate record-keeping is essential for maintaining the trust of stakeholders and ensuring the company's adherence to applicable laws and regulations.Offshore Global Logistics places a strong emphasis on the reporting and resolution of any issues, violations, or concerns related to its policies, particularly those pertaining to bribery and corruption. Employees, business partners, and third parties are encouraged to promptly report such matters to the relevant offices of the company.
Offshore Global Logistics fully supports individuals who refuse to participate in bribery or corruption and will not tolerate any form of retaliation against them or those who report concerns in good faith. If you believe that your report may have led or is leading to negative consequences, it is important to contact Offshore Global Logistics.
Any violation of this policy is considered a significant breach of Offshore Global Logistics' Code of Conduct and will be met with proportionate disciplinary actions, including the potential termination of employment. In certain circumstances, Offshore Global Logistics may also report the violation to relevant enforcement authorities.
Reporting and Resolving an Issue, Violation or Complaint
Offshore Global Logistics is committed to fostering a culture of integrity, transparency, and accountability, and encourages everyone to contribute to the prevention and detection of bribery and corruption through the reporting and resolution processes outlined in its policies.RESPONSIBILITIES AND CONSEQUENCES
Employees, Officers, and DirectorsEmployees, officers, and directors of Offshore Global Logistics are required to take immediate action if they suspect any instances of bribery or corruption by reporting their suspicions to the Authorities and Offshore Global Logistics. Additionally, if they feel comfortable, they should inform their department manager or relevant representative about any suspected cases of bribery or corruption.
By promptly reporting suspicions and cooperating with relevant departments, Offshore Global Logistics aims to ensure the prevention and effective handling of bribery and corruption cases, maintaining a culture of integrity and ethical conduct.
Managers
Managers play a critical role in preventing, detecting, and reporting suspicions of bribery or corruption within Offshore Global Logistics. They are responsible for overseeing the development and maintenance of effective controls in this regard.
If managers have any suspicions of bribery or corruption, they are required to promptly report them to the Ethics Office. If necessary, they should escalate the matter to higher-level (line) management for appropriate action. By fulfilling these responsibilities, managers contribute to maintaining a culture of integrity and compliance with anti-bribery and anti-corruption standards at Offshore Global Logistics.
CONSEQUENCES
Any act performed by an employee that goes against the provisions stated in this policy will be deemed a significant violation of Offshore Global Logistics' Code of Conduct and this policy. In the event of a violation, appropriate disciplinary measures will be implemented, including the potential termination of the employee's employment, proportionate to the severity of the breach.It is crucial to acknowledge that engaging in acts of bribery or corruption may result in external ramifications. Individuals involved, including the employees and business partners, may face legal consequences, including personal, civil, administrative, and criminal sanctions or liabilities. Furthermore, such actions can inflict damage upon the reputation of the individuals involved as well as that of Offshore Global Logistics.
REPORTING TO AUTHORITIES
In the event that a violation of law or external regulations is substantiated, Offshore Global Logistics may have an obligation to report or inform the appropriate enforcement authorities, such as the police or regulatory bodies. This action is taken to ensure compliance with applicable laws and regulations. Offshore Global Logistics further retains the right to initiate separate legal proceedings against the individuals or entities involved in the violation.Questions
Offshore Global Logistics holds the expectation that all employees and business partners will consistently uphold the standards set forth in the Code of Conduct and this policy. It is crucial to exercise good judgment and, if necessary, seek guidance or support when faced with uncertainties. In case there are any inquiries regarding this policy or the relevant laws and regulations, individuals are advised to reach out to their department manager or the relevant offices. These avenues are in place to help and address any questions that may arise.Exceptions
In the event that an exceptional circumstance arises which necessitates a departure from the minimum requirements outlined in this policy or other Offshore Global Logistics policies referenced herein, the responsible manager is required to seek written authorization from the policy owner through a waiver request. Local Offshore Global Logistics entities or departments may establish more stringent regulations based on local laws, regulations, or risk assessments. However, these rules must align with the requirements of this policy, and the policy owner must always be kept informed. Any deviation from this policy must receive written approval from the policy owner.NOTE:
Please be aware that this policy is supplementary in nature, and any relevant local laws or regulations take precedence. This policy must not contradict any local laws or regulations, and in the event of a conflict, the law or regulation will prevail. If the terms of this policy are more stringent than the applicable legislation or offer additional protections, rights, or remedies, the terms of this policy will take precedence. In cases where there are differences in interpretation due to various translations, the English version of the policy will be considered authoritative.
You can report suspect violations of this Policy to Offshore Global Logistics at:
P.O. BOX 50610-00100 NAIROBI KENYA
PH: +254 (0) 111 052251
E-mail : info@offshorelogistics.co.ke
Offshore Global Logistics will keep the reported information confidential, provided it does not hinder any investigation that may follow thereafter.
P.O. BOX 50610-00100 NAIROBI KENYA
PH: +254 (0) 111 052251
E-mail : info@offshorelogistics.co.ke
Offshore Global Logistics will keep the reported information confidential, provided it does not hinder any investigation that may follow thereafter.