Anti-Bribery & Corruption Policy
At Faisal Fabrics Ltd. (FFL), the way we do things is just as important as what we do. We want to create a workplace where each employee achieves the highest business and personal standards, and where everyone feels proud of our company and the job which he or she does.
FFL is a team with core values: Accountable, Customer Focused and Team Driven. These values guide how we work every day. We bring these values to life in the way we perform, giving our best effort every day, being accountable for what we do, delivering on our commitments to each other and to our customers, setting objectives, meeting our goals, and working together to achieve business results. A core objective of our Company is creating a winning and inclusive culture that drives results.
By working as an employee at FFL, you are representing the Company to our customers and everyone else you come into contact with. As laid out in Code of Business you are expected to adopt the highest standards of professional and personal behavior and demonstrate Respect, Integrity, Good judgment, Honesty and Trust, the RIGHT Way, in all your actions, no matter what the circumstances.
One of the guiding principles is 'complying with Anti-Bribery & Corruptions laws'. The Anti-Bribery & Corruption Policy extends on this principle, and is applicable to all employees and everyone we do business with, including agents, representatives, consultants, independent contractors and anyone acting on behalf of FFL.
Purpose of the Anti-Bribery & Corruption Policy
This policy outlines acceptable and non-acceptable behaviors to ensure compliance with anti-bribery & corruption laws, such The Punjab Anti-Corruption Establishment Ordinance 1961, The Prevention of Corruption Act 1947. This includes compliance with all laws, domestic and foreign, prohibiting improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector, customers and suppliers.
Definitions
Bribe: Anything of value given in an attempt to affect a person's actions or decisions in order or to gain or retain a business advantage. Anything of value includes cash, entertainment or other gifts or courtesies.
Corruption: The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.
Facilitation payments: Small sums paid to government officials to facilitate or expedite routing. Non-discretionary government actions are considered facilitation payment.
Kickbacks: The return of a sum already paid or due as a reward for awarding of furthering business.
'Anti-Bribery & Corruption' Means
Bribery & Corruption can take place in many types of activities. It usually is designed to obtain financial benefits or other personal gain. For example, bribes are intended to influence behavior - they could be in the form of money, a privilege, an object of value, an advantage, or merely a promise to influence a person in an official or public capacity. Usually, two people are involved and both will benefit. Examples of a bribe include:
. Offer or receipt of cash in the form of a kickback, loan, fee or reward
. Giving of aid, donations or voting designed to exert improper influence
The areas of business where corruption, including bribery, can most often occur include:
1. Gifts, Entertainment and Hospitality
2. Facilitation Payments
3. Procurement Process
4. Political, Community and Charitable Contributions
1. Gifts, Entertainment and Hospitality
Gifts, entertainment and hospitality are acceptable if they are reasonable, proportionate and made in good faith and in compliance with our company policies. Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, 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.
What to do when you doubt if you can accept? If you are unsure if you should accept something of value - Ask your manager. If your manager is participating, seek a higher-level manager. If you prefer, contact the Manager Anti-Bribery & Corruption.
2. Facilitation Payments
Facilitation payments are not allowed. If you are unsure whether certain payments represent facilitation payments, please contact Compliance Office.
3. Procurement Process
Follow the FFL processes and adhere to the system of internal controls around supplier selection. Supplier selection should never be based on receipt of a gift, hospitality or payment. When supplier selection is a formal, structured invitation for the supply of products or services, it is most important we maintain documentation supporting our internal controls.
A comparison report process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the comparison report, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality.
4. Political Community and Charitable Contributions
No body is allowed to make political contributions from Company funds without authorization.
Contributions made by FFL to community projects or charities need to be made in good faith and in compliance with our Business, this Anti-Bribery & Corruption Policy and all relevant FFL's policies and procedures.
Books, Records and Internal Control Requirements
Expenses must never be hidden or purposefully misclassified. All business units must maintain an effective system of internal control and monitoring of our transactions. Certain monitoring controls are identified in our policies, specifically regarding approval of travel and entertainment expenses. It is your responsibility to be knowledgeable of control procedures and ensure compliance.
Responsibility
FFL takes corruption and bribery very seriously. Any violation of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with local law.
Bribery & Corruption is a criminal offense. As an employee you will be accountable whether you pay a bribe yourself or whether you authorize, assist, or conspire with someone else to violate an anti-corruption or anti-bribery law. Punishment for violating the law is against you as an individual and may include imprisonment, probation, and significant monetary fines which will not be paid by FFL.
Questions or How to Raise a Concern
If you want to ask a question about the requirements in this policy or are concerned that an anti-bribery 7 corruption violation is occurring or has occurred, report it immediately to one of the following:
. Director
. Executive Director
. Manager Anti-Bribery & Corruption/Manager Admin
. Relevant Department Manager
The policies on this site apply to all employees of Faisal Fabrics Ltd., unless otherwise specified or as required by Federal, Provincial or Local law.
DIRECTOR
FAISAL FABRICS LTD.