Anti-corruption policy

Our overall policy

As employees and contractors at E Co. we:

• • Behave honestly, are trustworthy and set a good example

  • Make sure that our behaviour complies with the policies and rules of E Co.

  • Use the resources of our company in the best interest of the company, and do not misuse these resources

  • Do not pay or accept bribes

  • Make a clear distinction between the interests of our company and our private interests, and avoid possible conflicts of interest; we do not accept gifts, invitations or other advantages which could contradict this principle

  • Ensure that we comply with national legislation

  • Report incidents, risks and issues which deviates from our policies

  • Are continuously conscious about and aim to maintain our integrity

As directors of E Co. we:

• • Commit ourselves to this policy, and to an ongoing effort to maintain our integrity

  • Make sure that Eco complies with national regulation and commit Eco to an open and transparent management approach

  • Expect our partners and other business associates to respect this policy

Definition of Corruption and Bribery

• • Corruption is the misuse of entrusted power for private gains.

  • Bribery is to offer, receive, promise or give any undue pecuniary or other advantage, whether directly or through intermediaries, to a foreign public official, for that official or for a third party, in order that the official act or refrain from acting in relation to the performance of official duties, in order to obtain or retain business or other improper advantage. (Definition from the OECD-Convention on Combating Bribery of Foreign Public Officials in International Business Transactions)

Political and Charitable Contributions and Sponsorships

• • Eco does not grant financial or other support to political parties or political campaign efforts, as this can be perceived as an attempt to gain an improper business advantage. We encourage our employees to use their personal right to participate in political and democratic processes.

  • Community support and donations are acceptable, be it in-kind services, knowledge, services exchange, or direct financial contributions. However, managers and employees must be careful to ensure that charitable contributions and sponsorships are not used as a subterfuge for and do not constitute bribery. In relation to donations and community support, Eco should consult local stakeholders to unveil relevant needs.

Facilitation Payments

• • Facilitation payments are a form of bribery made with the purpose of expediting or facilitating the performance by a public official for a routine governmental action and not to obtain or retain business or any other improper advantage. The facilitation payment is typically demanded by low level and low income officials to obtain levels of service, one under normal conditions would be entitled to. Facilitation payments are prohibited in most countries.

  • Eco has a zero tolerance policy regarding facilitation payment.

  • Faced with a demand for a facilitation payment, the following steps must be taken by the person faced with the demand:

1. Ask to see the enabling legislation

2. Refuse if enabling legislation is not showed.

3. Say no again and refer to the prohibition for facilitation payments in anti-bribery legislation and your company policy

4. Inform your manager before making any payment or a soon as possible

5. Keep the amount to a minimum and ask for a receipt

6. Record the payment in the bookkeeping system and identify it as a 'facilitation payment'

7. Report to the Director

• • E Co. has established a procedure for record keeping of the payments as part of a quarterly specification of facilitation payments. This specification is used for an ongoing evaluation of potential business risk or damage to E Co’s image and is used to develop a strategy and setting achievable targets in order to achieve the zero tolerance policy.

Gifts, Hospitality and Expenses

• • You must not give or receive courtesies which could be evaluated as illegal or improper exchanges. You must refrain from offering courtesies which violates the recipients standards. In addition government or public servants may be under strict guidelines preventing them from receiving courtesies. Offering courtesies to government or public servants may be considered as a legal offence in certain countries.

  • You are not allowed to accept or give courtesies which involves cash or cash equivalents. You may offer or receive gifts, hospitality and expenses provided they will not motivate favouritism and or create any obligation. All courtesies must be reasonable and may not be frequent suggesting a pattern.

  • Courtesies in the form of travel, meals, receptions, sightseeing, gifts or other expenses may only be offered or given to persons with a professional interest in the relationship but not to any spouses and relatives.

  • To avoid that gifts, hospitality and entertainment have undue influence on business decisions, the maximum amount for gifts, hospitality and entertainment must be defined by management in accordance with local professional and industry standards prior to doing business in the specific country.

  • Courtesies whenever accepted or given and must documented and recorded. The recorded entry must expressly state the nature and purpose of the expenditure, and records must be preserved.

Protection money

• • In some instances protection money may be solicited. This is a kind of extortion which might involve physical threats. We will not engage in such affairs. It is our obligation to protect any employee or partner, and such incidents should be reported to the management immediately. In certain situations such threats might lead to a cessation of business.

Implementation

Roles and Responsibilities

• • This code of conduct has been developed to secure and detect actions which does not comply with guidelines herein. It is every employee’s responsibility to prevent bribery and corruption in E Co. and to comply with the code of conduct , hereunder any other relevant provisions within our field of business.

  • Every manager and employee has an independent obligation to secure that any interaction with public officials comply with all relevant laws and regulations, as well as this code.

  • It is the responsibility of every manager to communicate this code and ensure that all relevant employees and external parties working on behalf of Eco, within their area of responsibility, understand and comply with the procedure.

  • The responsibility for the implementation, monitoring and questions regarding policy and principles rests with Management.

  • In sections 2 to 5 of this code minimum requirements in relation to political contributions, charitable contributions and sponsorships, facilitation payments, gifts, hospitality and expenses, have been established. They do not supersede national law and it is imperative at any time always to comply with relevant laws and regulations.

Business Relationships

• • We act with due care before engaging with a business partner and ensure that subsidiaries and business partners know and respect our code of conduct.

Distributors and Agents

• • Compensation paid to distributors and agents must be appropriate and justifiable remuneration for legitimate services rendered. The relationship must be documented and the agent or distributor must contractually agree to comply with our code of conduct. We will follow the conduct of our agents and distributors and reserve the right to termination in the event that they pay or solicit bribes or in any other ways violate this code of conduct.

Contractors and Suppliers

• • We conduct our procurement practices in a fair and transparent manner and we act with due care when evaluating major prospective contractors and suppliers. We will make our anti-bribery policies known to our contractors and suppliers. We will follow the conduct of major contractors and suppliers and have a right of termination in the event that they pay or solicit bribes. We will avoid dealing with prospective contractors and suppliers known to be paying bribes.

Communication and Training

• • E Co. is responsible to secure that all employees and contractors are informed about and understand this code of conduct. Each employee will receive relevant training and new employees will be briefed as a part of the welcome orientation. As minimum key employees will receive yearly mandatory training including compliance with laws, regulations, or standard conducts relevant for our field of business. [for an online e-learning introductory course to the main issues, see here: Training demo ]

Procedures

• • E Co. may develop procedures that underpins this code of conduct. This may include procedures for Risk Assessment, Due Diligence of Third Parties and Communication.

Sanctions

• • No employee or contractors will be penalised or be subject to other adverse consequences for refusing to pay bribes even if it may result in E Co. losing business.

Failure to observe this code is a cause for disciplinary action, which by default involve dismissal.