Anti-Corruption Policy


We embrace a transparent zero-tolerance strategy in the event of bribery or corruption. Hence, GISED has set up an Anti-Corruption Policy, which covers bribery, gifts and business courtesies, events and arrangements, facilitation payment, utilisation of middlemen, utilisation of lobbyists and gifts and arrangements for public authorities.

The policy is conveyed and published to our employees for their reference and direction on proper business conduct. Candidates, workers and different partners are urged to raise any occurrences of non-compliance to GISED.


11. Purpose
This policy was created to establish controls to ensure consistency with all appropriate anti-bribery and corruption guidelines, and to ensure that the Company's business is conducted in a socially responsible way.
22. Policy statement
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an incentive or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner.
GISED employs a zero- tolerance approach to bribery and corruption. We commit to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, in addition to implementing and enforcing effective systems to counter bribery. We will uphold all relevant laws that are countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws in Europe in respect of our conduct both at home and abroad. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. Therefore, we take our legal responsibilities very seriously.
33. Scope
3.1 Who is covered by the policy? In this policy, third party is defined by any individual or organisation you come into contact with during the course of your work for us, 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. This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). This policy covers: • Bribes; • Gifts and hospitality; • Facilitation payments; • Political contributions; • Charitable contributions.
3.2 Bribes Employees are not to engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees are not to bribe a foreign public official anywhere in the world.
3.3 Gifts and hospitality Employees must not offer or give any gift or hospitality: • which could be regarded as illegal or improper, or which violates the recipient’s policies; • to any public employee or government officials or representatives, or politicians or political parties; • which exceeds $100 in value for each individual gift or $500 in value for each hospitality event (not to exceed a total value of $1000 in any financial year), unless approved in writing by the manager of said employee(s). Employees may not accept any gift or hospitality from our business partners if: • it exceeds $100 in value for each individual gift or $500 in value for each hospitality event (not to exceed a total of $1000 in any financial year), unless approved in writing by the employee’s manager; or • it is in cash; or • there is any suggestion that a return favour will be expected or implied. Where a manager’s approval is required above, if the manager is below Director level then approval must be sought from an appropriate Director. If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity. 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 implemented is whether in all the circumstances the gift or hospitality is reasonable and justifiable, as the intention behind the gift should always be considered. Within these parameters, local management may define particular guidelines and policies to reflect local professional and industry standards. If this policy requires written consent, GISED shall put in place a process to maintain a register of all such approvals.
3.4 Facilitation payments and kickbacks Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to. Our strict policy is that facilitation payments must not be paid. We acknowledge, however, that our employees could face situations where there is a risk to their personal security or their family and where a facilitation payment cannot be avoided, in which case the following steps must be taken: • Keep any amount to the minimum; • Create a record concerning the payment; and • Report it to your line manager. In order to achieve our goal of not making any facilitation payments, each business of GISED will keep a record of all payments made, which must be reported to us, in order to evaluate the business risk and to develop a strategy to minimise such payments in the future.
3.5 Political Contributions We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.
3.6 Charitable contributions Charitable support and donations are acceptable and are encouraged, whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must ensure that charitable contributions are not a scheme to conceal bribery. We only make charitable donations that are legal and ethical subject to local laws and practices. No donation must be made without the prior approval of the compliance manager. All charitable contributions should be publicly disclosed.
44. Your Responsibilities
You must ensure that you read, understand and adhere to this policy. The prevention, detection and reporting of bribery as well as other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify GISED as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future. Employees who breach this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.
55. Record-keeping
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 declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. 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 must be kept "off-book" to facilitate or conceal improper payments.
66. Raising a concern
You are encouraged to raise concerns about any issue or suspicion of malpractice as quickly as possible. If you are not sure if a particular act counts as bribery or corruption, or if you have any other queries or concerns, you may raise them with your line manager.
77. What to do if you are a victim of bribery or corruption
It is imperative that you inform the GISED 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.
88. Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, may worry about possible repercussions. We aim to encourage transparency and will support anyone who raises authentic concerns in good faith under this policy, even if they may turn out to be mistaken. GISED commits to ensuring no one experiences any detrimental treatment as a consequence of refusing to take part in bribery or corruption, or due to reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or could take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have experienced such treatment, you should inform GISED immediately. If the matter is not resolved, and you are an employee, you may formally raise it using the company’s Grievance Procedure.
99. Training and communication
Training on this policy forms part of the initiation process for all new employees. All existing employees will receive regular, relevant training on how to implement and comply with this policy. In addition, all employees will be asked to formally accept conformity to this policy on an annual basis. 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.
1010. Who is responsible for the policy?
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control adhere to it. GISED has primary and day-to-day responsibility for implementing this policy, and for monitoring its use as well as effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and comprehend this policy and are given enough and regular training on it.
1111. Monitoring and review
GISED will monitor its effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be amended 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 employees bear responsibility for the success of this policy and should ensure they use it to reveal any suspected threats or misconducts. Employees are encouraged to comment on this policy and suggest ways in which it might be improved. Concerns, suggestions and queries should be addressed to GISED. This policy is not part of any employee's contract of employment and it may be amended at any time, at GISED’s discretion.