Accu-Clinic Anti-Corruption Policy
I. Introduction Accu-Clinic team believes that bribery and corruption have negative effect upon business deals and companies involved in such acts. This can affect the company’s reputation and lead to a company ceasing to operate. II. Statement of Policy At Accu-Clinic, we are committed to conduct our business with integrity, honesty, and transparency. Accu-Clinic has no tolerance policy towards the giving and receipt of bribes. We are committed to conducting our business without any form of corruption. This extends to all our operations and business dealing wherever we operate. This policy applies to employees at all levels as well as board representatives who all carry the responsibility of implementing and following the values and rules of this policy in their day-to-day business dealings. III.
Policy in relation to specific risk areas
a. Gifts and Hospitality The exchange of gifts and hospitality when dealing with business partners or even public officials is recognized as an important part of doing business. However, shareholders, employees and company agents shall not give or receive, directly or indirectly, any hospitality or favors with the purpose of Influencing one’s decision making, official duties or even his judgment. To ensure that gifts and hospitality are not affecting the decision-making process, this requires top management approval and to be publicly announced. As special case of above Accu-Clinic employees prohibited to accept, ask for any type of gifts, discounts or commissions from our dealers for placing orders. b. Conflicts of Interest Given Accu-Clinic’s scope of work, employees have the opportunity to work with a wide range of clients, vendors and even governmental officials. We prohibit any interactions that could risk the company’s reputation and we ask that employees be committed to maintaining the highest levels of integrity and ethical standards. We must not participate in activities that create conflict between staff’s personal interests and the interest of the company. It is important that our employees channel actual and potential conflicts of interest to the Ethics and compliance Manager so that they can be resolved or avoided. We prohibit participating in or attempting to influence decisions relating to the company business dealings with relatives or based on personal relationship.
c. Facilitation Payments Accu-Clinic prohibits all facilitation payments of any kind, this is to include any payment or gift that affects other parties’ decision or push for an advantage or function other than the payment of a lawful and official fee for business purposes.; payment should be proved with invoice or an official receipt. It is prohibited for employees to make a facilitation payment and any payment shall be reported to the Ethics and Compliance Manager for a record shall be maintained and periodically monitored.
d. Subcontracting commitment All Accu-clinic business partners and stakeholders must be aware of the company’s anti-corruption polices and value system programme. Stakeholders and service providers should accept and sign our anti-corruption policy to provide services to Accu-Clinic.
IV.
Measures for better implementing the policy
a. Communication This policy shall be communicated with all the company employees (existing and new) and other relevant shareholders. Its procedures will be publicly available and published on our website. It will be made clear that employees understand and adhere to the policy and the anti-corruption program. b. Training All employees shall receive appropriate training relating to this policy and how to identify and deal with potential incidents of bribery. Attendance is mandatory and shall be recorded and documented. c. Monitoring and Evaluation The Ethics and Compliance Manager shall regularly (every year/two years) review and update the anticorruption program and policy ensure that it reflects our risks and requirements. It commits to implementing the necessary procedures to ensure this policy is applied in practice. . This can include risk assessments, sanctions, incentives, internal controls, reporting line, trainings.
This policy has the full support of Accu-Clinic’s senior management to ensure a culture of integrity is established at all levels of the company and that this policy is enforced in practice.
General Manager Mohammed Saber