AntiCorruption Policy
AntiCorruption policy
The Anti-Bribery and Anti-Corruption emphasizes GEESYS’s zero tolerance approach to bribery and corruption.
1. Purpose
- It establishes the principles with respect to applicable Anti-Bribery and Anti-Corruption laws.
- The policy provides information and guidance on how to recognise and deal with bribery and corruption issues.
- It guides us to act professionally, fairly and with utmost integrity in all our business dealings and relationships, wherever we operate.
2. Governance
- TOP management shall undertake periodic review and update this policy to reflect applicable law(s) and /or latest notifications released by the regulating authorities from time to time.
- Any changes to this Policy shall be tracked and documented for future reference.
- Top management shall monitor the effectiveness and review the implementation of the compliance principles set forth in this Policy, regularly considering its suitability, adequacy and effectiveness.
- Associates and business partners are responsible for the successful implementation of the principles set forth in this policy and should ensure they use it to disclose any suspected concern or wrongdoing.
- Any violation of this policy may have significant consequences, including potential prosecution, fines and other penalties for improper conduct, as well as imprisonment and/or disciplinary action up to and including termination of the concerned.
3.Policy Framework
Bribe or Facilitation Payments
- GEESYS prohibits all forms of bribery and corruption whether involving, but not limited to, Government Official or a private sector person or company and whether directly or indirectly.
- GEESYS conducts its business lawfully and ethically and expects everyone associated with it to conduct its business with integrity regardless of the existence of any local customs or traditions that may question integrity.
- No Associate shall ever: ◦ Directly or indirectly offer or pay, or authorize an offer or payment, of money or anything of value to a government officias, Healthcare Professionals, or any other person or entity (including in the private sector), which is: ◦ Intended to influence the judgment of the recipient in exercising his or her job responsibilities, or ◦ Intended to secure preferential treatment or an improper advantage for GEESYS, or ◦ Intended as gratification for the recipient having made a decision or acted in a way that benefited GEESYS. ◦ Directly or indirectly request or accept any money or item of value, which is: ◦ Intended to influence the judgment or conduct of an Associate in his or her job responsibilities.
Gifts, Hospitality and Entertainment
- GEESYS acknowledges that exchange of nominal gifts and sharing of entertainment is customary in many parts of the world during national, cultural and religious occasions.
- The giving or receipt of gifts by Associates is not prohibited, if following requirements are met: (a) No quid pro quo – There must always be a legitimate business purpose to support gifts related expenses. Customary gifts, meals, entertainment, travel or lodging may never be given or received in return for a favour/ favourable treatment or to refrain from doing something disadvantaging GEESYS. (b) It complies with all applicable Anti-bribery and Anti-corruption laws; (c) It is given under the brand name of GEESYS, and not in the name of any Associate; (d) It does not include cash or a cash equivalent (such as gift certificates or vouchers); (e) Considering, the reason and nature of the gift, it is of an appropriate type and value and given at an appropriate time; (f) It is given openly, not secretly.
- Associates cannot accept any gifts in cash or kind, except owing to the customary or religious practices followed by any third party
Donations
Business Partners
- We understand that various applicable anti-corruption and anti-bribery laws make GEESYS Entities responsible for the acts of our Business Partners and others acting on our behalf. Therefore, no Business Partner, acting on behalf of GEESYS may engage in any act that could be construed as bribery or corruption – whether using Geesys funds or their own personal funds or whether acting directly or through a middleman. Geesys expects all those acting on our behalf to abide by our standards of ethics and integrity and, where necessary and appropriate, to follow our procedures.
- While engaging with Business Partners, Associates should ensure that they comply with GEESYS’s Anti-Bribery and Anti-Corruption Policy.
4.Books, Records and Internal Controls
- GEESYS is required to keep accurate books and records and to maintain internal controls to prevent and detect potential violations of our policies or of applicable laws. Internal controls are processes that monitor compliance with the company’s policies. GEESYS has appropriate controls to ensure that diligence is conducted, transactions properly approved, documentation received to support expenses, and interactions handled as required by our policies. GEESYS shall also use proactive reviews, audits and internal investigations to further monitor compliance and to identify any potential areas to enhance.
- All Associates must ensure that all payments and transactions of the GEESYS Entities, regardless of value, are recorded accurately with appropriate documentation. For example, in connection with every transaction, you must ensure that all required pre-approval forms, questionnaires, self- assessments, agreements with Business Partners and expense reports, with supporting documents, are maintained and recorded properly. These requirements also apply to every expense regulated by this policy, such as Gifts, meals, travel or other permitted expense.
- If any Associate realizes that he/she mistakenly failed to provide complete information about a transaction or expense, he/she must escalate it to his/her Supervisor immediately. Trying to hide this mistake or falsifying of records should be avoided by Associates.
- Records and documents generated in connection with the principles set forth in this policy, including, but not limited to, any diligence files and contracting documents, must be maintained and stored for the period specified in the Data retention policy.
5.Raising a concern and Protection
- All GEESYS Associates are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If they are unsure whether a particular act constitutes bribery or corruption, or if they have any other queries, these should be raised with the Managing Director OR Top management.
6.Exception(s)
- Any exceptions to this policy must be approved by TOP MANAGEMENT.
