In this Policy, “Third Party(ies)” means any individual or organization, who / which come into contact with Vintedge or transact with Vintedge.
A bribe may be anything of value and not just money -- gifts, inside information, sexual or other favors, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function --and can pass directly or through a third party.
Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.
Loans from any persons or companies having or seeking business with Vintedge, except recognized financial institutions, should not be accepted. All relationships with those who Vintedge deals with should be cordial, but must be on an arm’s length basis. Nothing should be accepted, nor should the employee have any outside involvement, that could impair, or give the appearance of impairing, an employee's ability to perform his/her duties or to exercise business judgment in a fair and unbiased manner.
This Policy does not prohibit normal and appropriate gifts, hospitality, entertainment and promotional or other similar business expenditure to or from Third Parties. However, the key determining factor for appropriateness of the gift or hospitality and/or its value would be based on facts and circumstances under which such gift or hospitality is provided.
The practice of giving gifts and hospitality is recognized as an established and important part of doing business. However, it is prohibited when they are used as bribes. Giving gifts and hospitality varies between countries and sectors and what may be normal and acceptable in one country may not be so in another. To avoid committing a bribery offence, the gift or hospitality must be:
• Reasonable and justifiable in all the circumstances
Intended to improve the image of Vintedge , better present its products and services or establish cordial relations
• Intended to improve the image of Vintedge , better present its products and services or establish cordial relations
The giving or receiving gifts or hospitality is acceptable under this Policy if all the following requirements are met:
• It is not made with the intention of influencing a Third Party to obtain/ retain business or a business advantage or to reward the provision or retention of business or a business advantage or in explicit or implicit exchange for favors/ benefits or for any other corrupt purpose
• It complies with local laws and customs
• It is appropriate in the circumstances. For example, in Singapore it is customary for hampers to be given during Christmas or Chinese New Year
• Taking into account the reason for the gift or hospitality, it is of an appropriate type and value and given at an appropriate time
• It is given openly, not secretly and in a manner that avoids the appearance of impropriety
If you have any question or doubt about whether a gift, meal or entertainment or is appropriate, seek guidance from your supervisor.
a. Accept an offer of a gift of any size from any Third Party which is in negotiation with, or is submitting a proposal with Vintedge
b.Give, promise to give or offer, any payment, gift, hospitality or advantage with the expectation or hope that a business advantage will be given or received or to reward a business advantage already given
c. Accept or solicit any payment, advantage, gift or hospitality from a Third Party that you know or suspect is being offered with the expectation that it will obtain a business advantage for them
d. Threaten or retaliate against, another employee who has refused to commit a bribery offence or who has raised concerns under this Policy
e. Engage in any activity that might lead to a breach of this Policy
his / her department and/or around him / her, it will also be taken against the employee.
Although such conduct may be “passive”, i.e. the employee may not have directly participated in or may not have directly benefited from the corruption or bribery concerned, the wilful blindness to the same can, depending upon the circumstances, carry the same disciplinary action as an intentional act.
We are committed to succeed in business by virtue of excellence service quality and value, and not by creating unfair disadvantage for its competitors.
We believe in competing fairly and strictly on the merits of services quality and make no attempts to restrain or limit trade.
You should not make any political contribution on behalf of Vintedge, use any Vintedge resources to assist a candidate or elected official in any campaign or coerce or direct another employee to vote a certain way. You should never attempt to offer any incentives to public officials in the hopes of influencing the decision of that individual.
Singapore: The Prevention of Corruption Act
The management shall strive to provide a workplace free of bribery and corruption by complying with all applicable laws relating to bribery, money laundering and/or corruption as well as prohibiting the exchange of money or anything else of value to or from anyone, including government officials, to influence actions or obtain an improper advantage.
Staff in supervisory role is responsible to uphold the same standard concerning bribery, corruption and unethical business practices, and are authorized to take corrective action to stop such activities
Reporting of Corruption/Bribery cases can be made by email to Sophia@vintedge.com