It aims to improve mutual understanding and to set high-ethical standard between IGE Group and employees, and externally. (between IGE Group & relationships with suppliers, customers, partners, the different levels of Government and the community in general)
This policy applies to all levels of employees (whether permanent, contract or temporary), consultants, contractors, third parties or any other person associated with IGE Group, or any subsidiaries or their employees, wherever located.
- Corruption: An act done with the intent to give some advantage that is inconsistent with official duty and the rights of others. Corruption includes situations where officials use their position of authority to wrongfully or unlawfully obtain a benefit for themselves or others.
- Bribery Involves giving or offering money, a gift, something else of value (for example, plane tickets, accommodation, gift cards, scholarships for children of government officials, political or charitable contributions, loans, favours, business or employment opportunities) to someone in business or government in order to obtain or retain an improper commercial advantage or to induce or reward the recipient to act, or refrain from acting, improperly.
- Facilitation Payments: Small payments made to government officials intended to expedite or secure the performance of routine governmental actions.
- Secret commissions typically arise where a person or entity such as an employee offers or gives a commission to an agent or representative of another person, who customer of IGE that is not disclosed by that agent or representative to their principal.
- Money laundering is the process by which a person or entity conceals the existence of an illegal source of income and then disguises that income to make it appear legitimate.
- Third Party includes actual or potential agents, distributors, suppliers, purchasers or contractors.
- All employees must ensure that to read, understand and comply with this policy.
- Do not approve any offers, or make, accept or request an irregular payment or other thing of value, to win business or influence a business decision in favour of the IGE Group.
- Do not give, offer, accept or request bribes, facilitation payments, secret commissions or engage in money laundering or cause any of them to be given, offered, accepted or requested.
- Do not offer or receive cash, any gifts, entertainment or hospitality to or from public or government officials or politicians.
- Declare must be made to Management Committee transparently according to the existing company rules and regulations if accepting gifts unavoidably.
- If accepting gifts that exceeds the limitations that mentioned in Code of Conduct (COC) unavoidably, it must declare transparently according to the existing company rules and regulations.
- IGE Group prohibits the offering or acceptance of gifts, entertainment or hospitality of any value that do not accordance with Myanmar legislation local business practice in Myanmar.
- Group CEO or Head of Business Unit may set a financial limit which complies with the expenditure is made on gifts, entertainment or hospitality that may be accepted or offered, or may ban.
- It is not allowed offering or acceptance of gifts, entertainment or hospitality are provided to a single individual or single organization on multiple occasions
- Do not allow Anonymous donations and donations to individuals instead of organizations.
- Do not allow to make donations to any political party on behalf of the IGE Group.
- IGE Group may make charitable donations that are legal and ethical under local laws and practices.
- A charitable donation may only be offered or made with the prior approval of Group CEO/Business Unit Head.
- Strongly discourage the behaviors that can be interpreted as clientelism, nepotism or favoritism
- Employees must avoid being engage things that may lead to beneficial conflicts in accordance with COC.
- IGE Group have to communicate and perform anti-corruption due diligence before to enter into a relationship with a new business partner whether Acquisition/ Joint Ventures (JVs) that IGE are not dealing with counterparties which are engaged in bribery or corruption.
- IGE must obtain a declaration from the business partner that they are not engaged and will not engage in such activity. IGE will then monitor to business partners on an ongoing basis regarding their anti-corruption compliance.
- All Employees are encouraged to raise concerns about any issue or suspicion of anti-corruption activities at the earliest possible stage.
- All employees must notify their Head of Department and/or the Authorized appointed person as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
- If employees are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these will be raised with Head of Department (HoD) and Authorized appointed person to seek advice and discuss.
- IGE Group encourages openness and will support any employee who raises genuine concerns in good faith under this policy.
- IGE Group is committed to ensuring no one suffers any treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.
- HoDs must report to Authorized appointed person to discuss to settle the issue immediately.
- New employee will be conducted to undertake training on this policy as a part of induction process.
- Existing employees will be conducted regular updates on this policy as a part of their ongoing internal training programs.
Monitoring, Reporting and Review
- The Audit Committee will use the information provided through the reports for ensuring that the measures/activities are being undertaken, and for evaluating the progress towards indicators.
- The Audit Committee will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.
- Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
- Internal control systems and procedures adopted to comply with this policy will be the subject of regular internal audits by the Audit Committee to provide assurance that they are effective in mitigating the risk of non-compliance.
- The Audit Committee will report regularly on compliance with this policy to the Management/ BoDs.
- All Committee members are responsible for the success of this policy and must ensure they use it to disclose any suspected danger or wrongdoing.
- Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries must be addressed to the Committee.
- This policy will be reviewed periodically by the Company and may be amended at any time.
- All level of Employees will be fully informed of any material revisions to this policy.
Maintain Accurate Records
- The Company must keep financial records and have appropriate internal controls in place which will evidence the business reason for any payments made to Third Parties.
- All expenditure by employees, including gifts, entertainment and hospitality, must be included in expense reports and approved in accordance with the relevant expense policy development by Head of Finance & approved by the Board.
- Employees must ensure that all expense claims relating to gifts, entertainment, hospitality or expenses incurred are submitted in accordance with the Company’s expense policy and specifically record the reason for the expenditure.
- Each employee must submit declaration to HoD for all gifts that exceeds the limitations from any third party. HoD must report to Management Committee and the declaration form must keep and record in HR and Finance Departments. Gifts will be decided by Management Committee’s decision.
- All accounts, invoices, and other similar documents and records relating to dealings with Third Parties will be prepared and maintained with strict accuracy and completeness.
Consequences of a breach
- Any employe who breach of this policy may be regarded as serious misconduct, leading to disciplinary action, which may include dismissal and also expose an individual to criminal and civil liability and could result in imprisonment or in the imposition of a significant financial penalty on the person.