Anti-Bribery & Anti-Corruption Policy
This Anti-Bribery & Anti-Corruption Policy (the “Policy”) is applicable to all employees, officers, directors, contractors, consultants, agents, and any other party representing or acting for or on behalf of UNIVERSAL FINANCIAL ASSOCIATES, INC. (the “Company”). This Policy sets forth the Company’s zero-tolerance stance towards bribery and corruption in all its forms.
Purpose
The purpose of this Policy is to:
• Ensure compliance with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA).
• Protect the Company and its employees from involvement in bribery or corrupt practices.
• Promote a culture of honesty and integrity within the Company.
• Ensure compliance with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA).
• Protect the Company and its employees from involvement in bribery or corrupt practices.
• Promote a culture of honesty and integrity within the Company.
Purpose
This Policy applies to:
• All Company operations, regardless of location.
• All Company personnel, including employees, officers, directors, contractors, consultants, agents, and representatives.
• All third parties acting on behalf of the Company.
Definitions
• Bribery: Offering, promising, giving, accepting, or soliciting anything of value as a means to influence the actions of an individual in a position of authority.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Small payments made to expedite or secure the performance of a routine government action.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payments: Small payments made to expedite or secure the performance of a routine government action.
Prohibited Practices
Bribery
• The Company strictly prohibits offering, giving, soliciting, or receiving any form of bribe, whether directly or indirectly.
• Employees must not engage in any activity that could be perceived as bribery.
• The Company strictly prohibits offering, giving, soliciting, or receiving any form of bribe, whether directly or indirectly.
• Employees must not engage in any activity that could be perceived as bribery.
Facilitation Payments
• The Company prohibits facilitation payments.
• Exceptions may be made only in cases where there is a threat to personal safety, and such incidents must be reported immediately to the Compliance Officer.
• The Company prohibits facilitation payments.
• Exceptions may be made only in cases where there is a threat to personal safety, and such incidents must be reported immediately to the Compliance Officer.
Gifts and Hospitality
• Gifts and hospitality must be reasonable, transparent, and infrequent, and must not be intended to influence the recipient improperly.
• All gifts and hospitality given or received must be recorded in the Company’s Gifts and Hospitality Register.
• Gifts and hospitality must be reasonable, transparent, and infrequent, and must not be intended to influence the recipient improperly.
• All gifts and hospitality given or received must be recorded in the Company’s Gifts and Hospitality Register.
Third Parties
• The Company will conduct due diligence on third parties to ensure they adhere to anti-bribery and anti-corruption standards.
• All contracts with third parties must include anti-bribery and anti-corruption clauses.
• All contracts with third parties must include anti-bribery and anti-corruption clauses.
Record-Keeping
• Accurate and detailed records must be kept of all transactions.
• The Company will maintain a system of internal controls to ensure transparency and accountability in financial reporting.
• The Company will maintain a system of internal controls to ensure transparency and accountability in financial reporting.
Training and Communication
• The Company will provide regular anti-bribery and anti-corruption training to all employees.
• This Policy will be communicated to all employees, third parties, and relevant stakeholders.
• This Policy will be communicated to all employees, third parties, and relevant stakeholders.
Reporting and Whistleblowing
• Employees are required to report any suspected bribery or corruption.
• The Company provides a confidential whistleblowing mechanism for employees to report concerns without fear of retaliation.
• The Company provides a confidential whistleblowing mechanism for employees to report concerns without fear of retaliation.
Consequences of Non-Compliance
• Violation of this Policy will result in disciplinary action, which may include termination of employment.
• The Company will cooperate with law enforcement authorities in the investigation of any alleged bribery or corruption.
• The Company will cooperate with law enforcement authorities in the investigation of any alleged bribery or corruption.
Monitoring and Review
• The Company will regularly review and update this Policy to ensure its effectiveness.
• The Compliance Officer will monitor compliance with this Policy and report findings to the Board of Directors.
• The Compliance Officer will monitor compliance with this Policy and report findings to the Board of Directors.
The Company is committed to maintaining the highest standards of integrity and transparency.
Adherence to this Policy is mandatory for all employees and associated parties. By fostering an environment of ethical behavior, the Company
aims to safeguard its reputation and ensure sustainable business success.
Appendix A: Examples of Prohibited Conduct
• Offering a government official a gift in exchange for expedited permits.
• Paying a third party to secure a contract through improper influence.
• Accepting an expensive gift from a supplier during contract negotiations.
• Paying a third party to secure a contract through improper influence.
• Accepting an expensive gift from a supplier during contract negotiations.
Appendix B: Compliance Officer Contact Information
For any questions or concerns regarding this Policy, please contact:
Universal Financial Associates Compliance Team