Anti-Bribery and Corruption Policy
1. Policy statement
Eskan Electronics Limited complies, and expects everyone acting for or on its behalf to comply, with the Bribery Act 2010 and all other applicable anti-bribery and anti-corruption laws.
Eskan conducts business honestly, fairly and with integrity. We have zero tolerance for bribery and corruption and maintain proportionate, risk-based procedures designed to prevent them. Commercial pressure, local custom, competitive disadvantage or an instruction from another person never justifies bribery.
2. Purpose
This policy explains the standards required to prevent, identify and report bribery and corruption. It supports Eskan's legal duty to prevent bribery by persons associated with the company and should be read with applicable contracts, financial controls, procurement procedures, gifts and hospitality records, and whistleblowing or disciplinary arrangements.
3. Scope
This policy applies worldwide to all directors, officers, employees, workers and temporary staff of Eskan. It also applies, to the extent relevant to their work for Eskan, to agents, consultants, contractors, distributors, representatives, intermediaries, suppliers, joint-venture partners and any other person or organisation performing services for or on behalf of Eskan (together, Associated Persons).
Associated Persons must comply with applicable anti-bribery law and equivalent contractual requirements. Where local law is stricter than this policy, the stricter requirement applies.
4. What bribery and corruption mean
A bribe is a financial or other advantage offered, promised, given, requested, agreed to, received or accepted to induce or reward improper performance, influence a decision improperly, or obtain an improper business or personal advantage. It may include money, gifts, hospitality, travel, employment, discounts, commissions, donations, favours, confidential information or anything else of value.
Corruption is the abuse of entrusted power for private gain. A bribe can be direct or indirect and can pass through a third party. It need not be paid or succeed: an offer, promise, request or agreement may itself be an offence.
The Bribery Act 2010 includes offences of bribing another person, receiving a bribe, bribing a foreign public official, and failure by a commercial organisation to prevent bribery by an associated person.
5. Prohibited conduct
You must never, directly or indirectly:
- offer, promise, authorise or give a bribe;
- request, agree to receive or accept a bribe;
- bribe a public official to influence that person in their official capacity or obtain business or an advantage;
- make or permit a facilitation payment or kickback;
- use an agent, distributor, supplier, family member or other third party to do anything prohibited by this policy;
- create a false, misleading, incomplete or off-book record, or disguise an improper payment; or
- threaten or retaliate against someone who refuses to pay a bribe or raises a concern in good faith.
6. Facilitation payments, extortion and personal safety
Facilitation payments—small or unofficial payments intended to secure or speed up a routine governmental action—are prohibited, even where customary. Kickbacks are also prohibited.
If a payment is demanded and you are unsure whether it is legitimate, refuse it where safe, request an official written explanation and receipt, and seek guidance. If you reasonably believe that your or another person's immediate health or safety is at risk, do not put anyone in danger. Any payment made under duress must be reported to a director as soon as safely possible and recorded accurately.
7. Gifts, hospitality, travel and expenses
Reasonable, proportionate and bona fide hospitality or promotional expenditure may be permitted when it has a legitimate business purpose, is transparent, is allowed by the recipient's rules and local law, and cannot reasonably be understood as an attempt to influence improperly.
Gifts or hospitality must never:
- be cash or a cash equivalent;
- be offered or accepted in return for a favour or advantage;
- be lavish, secret, frequent or timed to influence a tender, licence, inspection or decision;
- compromise, or appear to compromise, independent judgement; or
- involve a public official without prior approval from a director and any approval required by the official's organisation.
Gifts, hospitality, travel and expenses must be approved and entered in the applicable register where required by Eskan's internal thresholds. If in doubt, obtain written approval before proceeding.
8. Political and charitable contributions and sponsorship
Eskan does not make political contributions as a way of obtaining a business advantage. Charitable donations, community support and sponsorship must be lawful, transparent, properly authorised, made to a genuine organisation, and never used to conceal bribery. Appropriate due diligence and accurate records are required.
9. Public officials
Dealings with public officials present heightened risk. The term includes elected and appointed officials, civil servants, military and law-enforcement personnel, employees of state-owned or state-controlled organisations, officials of international public organisations, political candidates and persons acting in an official capacity. Extra care, prior approval and documented due diligence are required before providing anything of value connected with a public official.
10. Third parties and due diligence
Eskan applies proportionate, risk-based due diligence before appointing and while working with Associated Persons. The level of review depends on matters such as country, service, customer, government interaction, compensation, ownership, reputation and use of intermediaries.
Engagements must have a legitimate business rationale, appropriately documented scope and commercially reasonable payment terms. Higher-risk engagements should include written anti-bribery commitments, audit or information rights where proportionate, and termination rights. No payment may be made to an unexplained third party, personal account, unusual jurisdiction or in a manner inconsistent with the contract without documented review and approval.
11. Conflicts of interest
Actual, potential or perceived conflicts of interest must be disclosed promptly. This includes personal, family or financial relationships involving customers, suppliers, intermediaries, competitors or public officials. A conflict must be managed and recorded; disclosure does not by itself authorise a transaction.
12. Books, records and controls
All transactions, expenses, commissions, discounts, gifts, hospitality, donations and sponsorships must be recorded completely, accurately and promptly. Supporting documents must describe the true purpose and recipient. Secret accounts, false descriptions and unrecorded funds are prohibited. Everyone must cooperate with internal controls, audits and reasonable information requests.
13. Risk assessment, training and communication
Eskan periodically assesses bribery risks and adapts controls to the nature, scale and locations of its activities. Relevant personnel receive proportionate communication or training. Managers must promote this policy, model ethical conduct and ensure that team members know how to seek advice and report concerns. Relevant Associated Persons will be informed of Eskan's standards.
14. Responsibilities
The Board of Directors has overall responsibility for this policy and for top-level commitment to preventing bribery. Management is responsible for implementation, risk assessment and monitoring. Every person within scope must read, understand and follow the policy, complete required training, keep accurate records, remain alert to warning signs, and report concerns promptly.
15. Seeking advice and reporting concerns
Raise questions, requests for approval, suspected breaches, attempted bribery or warning signs as early as possible with your manager or an Eskan director. Concerns may also be sent to info@eskan.com or delivered confidentially to the registered office for the attention of the Board of Directors.
Reports should be made in good faith and may be confidential where practicable. Eskan prohibits retaliation against anyone who refuses to participate in bribery or raises a genuine concern, even if the concern is not substantiated. Knowingly false or malicious allegations may be dealt with under applicable procedures.
16. Investigation and response
Eskan will assess and, where appropriate, investigate concerns fairly and proportionately. Personnel and Associated Persons must preserve relevant records and cooperate. Eskan may suspend a transaction, payment or relationship while a concern is reviewed and may seek legal advice, notify an authority or cooperate with law enforcement where appropriate or required.
17. Breaches
A breach may result in disciplinary action up to and including dismissal, subject to applicable employment law. Eskan may terminate a contract or business relationship, recover losses, and refer suspected criminal conduct to the relevant authorities. Individuals and organisations may also face criminal penalties independently of action taken by Eskan.
18. Monitoring and review
The Board will review this policy at least annually and following a material legal, organisational or risk change, significant incident, control failure or relevant audit finding. Controls will be tested and improved where needed. This policy is a practical compliance requirement and not a substitute for risk-based implementation.
19. Document control and approval
This is the current public version. The Board should record its formal approval, retain the controlled signed or approved copy, assign internal approval thresholds and registers, and communicate those operational details to relevant personnel. Printed or downloaded copies may become out of date; the current Website version should be checked.