Panaleco Freight & Trade Ltd (“the Company”) is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations and other requirements which govern the conduct of our operations.
The Company is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“the Act”) and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.
Anyone or any organisation found guilty of bribery under the Act may face fines and/or prison terms. In addition, high legal costs and adverse publicity are likely to result from any breach of the Act.
For employees of the Company, failure to comply with this Policy and/or with the Act may result in:
For the Company, any breach of this Policy by any employee or business associate may result in:
This Policy applies to all employees, agents, contractors, subcontractors, consultants, business
partners and any other parties (including individuals, partnerships and bodies corporate)
associated with the Company or any of its subsidiaries.
It is the responsibility of all of the abovementioned parties to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with the Company’s Policy or as otherwise stated in this Policy, as appropriate.
Νone of the parties mentioned above may:
The above parties must:
A facilitation payment is defined as a small payment made to officials in order to ensure or speed
up the performance of routine or necessary functions.
Facilitation payments constitute bribes and may not be made at any time irrespective of prevailing business customs in certain territories.
Facilitation or similar payments may be made in limited circumstances where your life is in danger but under no other circumstances. Any payment so made must be reported to the Managing Director as soon as is reasonably possible and practicable.
Gifts and hospitality remain a legitimate part of conducting business and should be provided only in compliance with the Policy οr after approval from the Managing Director.
Gifts and hospitality can, when excessive, constitute a bribe and/or a conflict of interest. Care and due diligence should be exercised at all times when giving or receiving any form of gift or hospitality on behalf of the Company.
The following general principles apply:
1. Gifts and hospitality may neither be given nor received as rewards, inducements or
encouragement for preferential treatment or inappropriate or dishonest conduct.
2. Neither gifts nor hospitality should be actively sought or encouraged from any party, nor should the impression be given that the award of any business, custom, contract or similar will be in any way conditional on gifts or hospitality.
3. Cash should be neither given nor received as a gift under any circumstances.
4. Gifts and hospitality to or from relevant parties should be generally avoided at the time of contracts being tendered or awarded.
5. The value of all gifts and hospitality, whether given or received, should be proportionate to the matter to which they relate and should not be unusually high or generous when compared to prevailing practices in our industry or sector.
6. Certain gifts which would otherwise be in breach of this policy in the ignorance of the Managing Director may be accepted if refusal would cause significant and/or cultural offence, however the company will donate any gifts accepted for such reasons to a charity of managements choosing.
7. All gifts and hospitality, whether given or received, must be recorded.
Charitable donations are permitted only to registered (non-profit) charities. No charitable donations may be given to any organisation which is not a registered charity.
The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.
Employees and other associated parties are free to make personal donations provided such payments are not purported to be made on behalf of the Company and are not made to obtain any form of advantage in any business transaction.
The following issues should be considered with care in any and all transactions, dealings with officials, and other business matters concerning third parties: