CORRUPTION & BRIBERY POLICY 1. INTRODUCTION 1.1 Background Corruption and bribery are recognised as barriers to free trade and sustainable development. Anti-corruption laws criminalise any such action which pays, offers, or gives anything of value to organisations or individuals such as government officials, political candidates, or business partners with the purpose of influencing their decisions in order to obtain undue advantages. The consequences can be fines and/or imprisonment, which would undermine the business and cause great financial, regulatory, and reputational risks for ECCO. Laws like the UK Bribery Act reaching beyond the countries in question have changed the previous principle of laws being isolated to national legislation. As a matter of policy, as in Commitment 10 of the ECCO Code of Conduct, ECCO wishes to comply with the laws and regulations in the countries in which it operates. These include internationally applicable anti-corruption laws, and we expect our business partners to do the same. 1.2 Purpose The purpose of the Corruption & Bribery Policy is to ensure that all employees of ECCO comply with the relevant laws of countries where ECCO conducts, or plans to do, business. The policy defines ECCO’s position on: - Corruption and bribery - Money laundering - Facilitation payment - Charitable contributions and sponsorships - Gifts, entertainment, and favours 1.3 Scope The Policy applies to all ECCO Group entities, employees, and business partners. 2. POLICY STATEMENT 2.1 Corruption and Bribery Corruption and bribery are common terms for giving or obtaining an undue advantage through means which are illegal. ECCO does not approve of any form of corruption or bribery, whether direct or indirect, or through third parties such as business partners and agents. Employees are prohibited from soliciting, arranging, or accepting bribes intended for the employee’s benefit, or that of the employee’s family, friends, associates, or acquaintances. Employees will not suffer demotion, penalty, or other adverse consequences from his or her refusal to pay bribes, even if such refusals may result in delay or loss of business. Employees are strictly prohibited from directly or indirectly offering or giving anything of value to government officials, political candidates, business partners, or anyone else to obtain an undue advantage for ECCO. Participating in corruption in any form, such as offering or accepting bribes, will lead to disciplinary actions, and in extreme situations, dismissal of the employee. The only exception that will be considered is if it is 34
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