Introduction:
PowerTech Industries Ltd. values honesty, transparency, integrity, and professionalism in dealings with clients, suppliers, competitors, and all other parties PowerTech is involved in business dealings with. PowerTech Industries does not use subcontractors to perform any of its work.
The goal is to inform personnel of their anti-corruption obligations and to ensure compliance by personnel with the PowerTech Industries Ltd.’s Policy. It provides information on how to identify potential risks, deal with challenging situations, and report when those situations violate or may lead to a violation of this policy.
Policy:
PowerTech Industries Ltd.’s Policy is to engage in full compliance with the Criminal Code in Canada and all other anti-corruption and anti-bribery laws and regulations applicable to PowerTech Industries Ltd.’s business (“Anti-Corruption Laws”).
PowerTech Industries has zero tolerance for any corruption in business activities. Bribes or other improper or unauthorized payments that directly or indirectly make, offer, or promise to make, kickbacks, benefits, or advantages to any person, individual, organization, or entity, are prohibited by this policy.
Personnel are expected to adhere to both the spirit and the letter of this policy concerning all aspects of PowerTech Industries Ltd.’s business. It is the responsibility of personnel to be aware of how each situation may violate or lead to a violation of this policy and anti-corruption laws.
Ethical Operating Statement:
PowerTech Industries Ltd. makes independent pricing and marketing decisions and does not improperly cooperate or coordinate activities with our competitors. PowerTech Industries Ltd. does not offer or solicit improper payments or gratuities, nor engage or assist in unlawful boycotts of particular customers.
This policy will be reviewed tri-annually.
Gifts:
Gifts are commonly offered as gestures of gratitude or tokens of appreciation, but in some situations, they can be construed as bribes. PowerTech Industries Ltd. does allow gifts made in good faith, but they must comply with this policy.
Personnel must ensure that any gifts are of value in proportion to the situation at hand, and any gifts should be infrequent to avoid being perceived as an attempt to influence an act or a decision. When offering or accepting a gift, personnel should specifically consider the following:
•The intended outcome: Gifts can have many purposes, such as expressing appreciation and building a relationship, but they can also be viewed as an attempt to influence a direct result,
e.g., to win a bid or affect the negotiation process.
•The company’s reputation: The gift may be a private act, but if it were to come to the public’s attention, personnel should consider how it would affect the reputation of the company.
•Competition: A general rule of thumb is to think about how the company would perceive a similar gift made by a competitor.
Disciplinary Action:
If personnel should fail to comply with this policy or Anti-Corruption Laws, they will be subject to disciplinary action up to and including termination of employment or other relationship with the company. Restitution could also be required, and civil or criminal action against individual personnel could be warranted.
If personal are involved in or aware of a situation they believe may violate or lead to a violation of this policy, they must ask for guidance from management.
