Moran Anti-bribery Policy


MORAN ANTI-BRIBERY POLICY

INTRODUCTION

It is our policy to conduct business in an honest way, and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. We must bring integrity to all our dealings. Bribery and corruption harms the societies in which these acts are committed and prevents economic growth and development. It is not just a cultural commitment on the part of the organisation; it is a moral issue and a legal requirement. Bribery is a criminal offence and corrupt acts expose the company and its employees to the risk of prosecution, fines and imprisonment, as well as endangering the company’s reputation. Any breach of this policy will be regarded as a serious matter by the company and is likely to result in disciplinary action.

WHAT IS BRIBERY AND CORRUPTION?

Bribery is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. Corruption is the misuse of public office or power for private gain; or misuse of private power in relation to business outside the realm of government. For the purpose of this policy, in Moran Publishers, whether the payee or recipient of the act of bribery or corruption works in the public or private sector is irrelevant. Acts of bribery or corruption are designed to influence the individual in the performance of their duty and incline them to act dishonestly. The person being bribed is generally someone who will be able to obtain, retain or direct business. This may involve sales initiatives, such as tendering and contracting. It does not matter whether the act of bribery is committed before or after the tendering of a contract or the completion of administrative tasks.

WHAT IS A BRIBE?

A briber involves corrupt intent and situations where both parties will benefit also known as ‘quid pro quo’. A bribe could be:

  • the direct or indirect promise, offering, or authorization, of anything of value
  • the offer or receipt of any kickback, loan, fee, reward or other advantage
  • the giving of aid, donations or voting designed to exert improper influence.

WHO CAN ENGAGE IN BRIBERY?

Bribery and corrupt behaviour can be committed by:

  • an employee, officer or director
  • any person acting on behalf of the company (third-party representative)
  • individuals and organizations where they authorize someone else to carry out these acts

WHAT STEPS CAN WE TAKE TO PREVENT BRIBERY AND CORRUPTION?

We can take the following steps to assist in the prevention of bribery and corruption:

(a) Risk assessment Identifying the risk will allow us to pinpoint specific areas in which we face bribery and corruption risks enabling us to better evaluate and mitigate these risks and thereby protect ourselves. Management must assess the vulnerability of each business unit to these risks on an ongoing basis.

(b) Accurate books and record–keeping Many bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. We must ensure that we maintain accurate books, records and financial reporting within all our business units and for all third-party representatives working on behalf of Moran Publishers. Our books, records and overall financial reporting must also be transparent and as such, must accurately reflect each of the underlying transactions. False, misleading or inaccurate records of any kind could potentially damage Moran Publishers.

(c) Effective monitoring and internal control We must maintain an effective system of internal control and monitoring of our transactions. Once bribery and corruption risks have been identified and highlighted via the risk assessment process, procedures can be developed within a comprehensive control and monitoring programme in order to help mitigate these risks on an ongoing basis.

WHERE DO THE BRIBERY AND CORRUPTION RISKS TYPICALLY TAKE PLACE?

Bribery and corruption risks typically fall within the following categories:

1. Use of third–party representatives

Third parties could include agents, distributors, consultants and joint venture partners. Where as the use of third–parties can help us reach our goals, we need to be aware at these arrangements can potentially present Moran Publishers with significant risks. Risk can be identified where a third-party conducts business activities on Moran Publishers’ behalf. All third-parties acting on our behalf must operate at all times in accordance with this policy. Management is responsible for the evaluation of each third-party relationship and determine whether or not it falls into this category.

Where third party arrangement has been identified. Management must:

  • evaluate the background, experience, and reputation of the third party
  • understand the services to be provided, and methods of compensation and payment
  • evaluate the business rationale for engaging the third-party
  • take reasonable steps to monitor the transactions of third-parties appropriately
  • ensure there is a written agreement in place which acknowledges the third-party’s understanding and compliance with this policy.

We are ultimately responsible for ensuring that third-parties who pose significant risks are compliant with this policy. Ignorance or ‘turning a blind eye’ is not an excuse.

2. Gifts, entertainment and hospitality

Gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and occurrence. To evaluate what is acceptable within Moran Publishers, ask yourself the following:

  • What is the intent or motive – is it to build a relationship or is there a hidden agenda?
  • How would this look if the details were covered by the media (newspapers, radio or television)
  • What if the situation were to be reversed – would there be a double standard?

If you find it difficult to answer one of the above questions, there may be a risk involved which could potentially damage your reputation, Moran Publishers’ reputation and business. The action could well be unlawful.

HOW TO RAISE CONCERN (WHISTLE BLOWING)

As individuals who work on behalf of Moran Publishers, we all have a responsibility to help detect, prevent and report instances not only of bribery, but also of any other suspicious activity or wrongdoing. We are absolutely committed to ensuring that all of us have a safe, reliable and confidential way of reporting any suspicious activity. If you have a concern regarding a suspected instance of bribery or corruption, please speak up – your information and assistance can only help. The sooner you act the better for you and the company.

If you are concerned that a corrupt act of some kind is being considered or carried out – either within Moran Publishers, by any of our third-parties or by any of our competitors, you must report this concern to your Line Manager in the first instance. In the event that an incident of bribery, corruption, or wrong doing is reported, we will act as soon as possible to evaluate the situation.

 


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