Introduction

Bribery and corruption offences present a very serious risk for all businesses. These risks can lead to unlimited fines for companies, imprisonment of individuals and loss of reputation. The enforcement of bribery and corruption laws in many countries is increasingly stringent and also encompasses activities undertaken by a company through its employees or third parties acting on its behalf across various international jurisdictions.

Bribery or corruption can be defined as the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust.

The most prevalent forms of bribery and corruption stem from:

Payments to a company’s employees or their relatives, or to a third party, to secure advantage in business transactions.
Political contributions made to secure advantage in business transactions.
Charitable sponsorships used to secure advantage in business transactions.
Facilitation payments or kickbacks made to secure or accelerate routine or necessary business actions.
Gifts, hospitality and expenses payments made to secure advantage in business transactions.
NH Consulting corporate conduct is based on acting responsibly, honestly, with integrity and the Company does not tolerate any form of bribery and corruption.

Purpose

The purpose of this policy is to set out NH Consulting position on bribery and corruption and detail how responsibility for observing and upholding same is established across the Company’s operations.

Scope

This policy applies to all NH Consulting employees, related personnel, and third parties acting on behalf of the Company and extends to all business dealings in all jurisdictions where NH Consulting operates. For the purposes of this policy, ‘related personnel’ includes family members (spouse, children, step children, parents and etc.).

This policy is implemented in conjunction with the Company’s Code of Business Ethics, Conflict of Interests Policy and Gifts and Entertainment Policy.

Policy

NH Consulting does not engage in bribery or corruption. It is contrary to the Company’s policy for any employee or third party acting on behalf of NH Consulting to request, offer, solicit, make or receive any payments or inducements which are illegal, unethical or represent a breach of trust.

NH Consulting Code of Business Ethics details the Company’s commitment to ensuring that its business is conducted in all respects according to rigorous ethical, professional and legal standards.

NH Consulting Conflict of Interests policy reflects the Company’s commitment to ensuring its employees avoid any activities that may lead to, or could suggest a conflict of interest with the Company’s business.

NH Consulting Gifts and Entertainment policy reflects the Company’s commitment to ensuring that the acceptance or offering of hospitality and gifts is reasonable and appropriate and subject to managerial review.

NH Consulting prohibits the use of contracts or consulting agreements to channel improper payments through agents or intermediaries or to public or government officials.

NH Consulting does not make direct or indirect contributions to political parties.

NH Consulting respects all laws relevant to countering bribery and corruption in all the jurisdictions in which the Company operates, particularly laws that are directly relevant to specific or local business practices. Appropriate legal advice is sought as necessary.

Responsibilities

The Compliance Committee is responsible for establishing this policy within NH Consulting , supported by an appropriate corporate culture which prohibits bribery and corruption involving either NH Consulting employees or any third parties acting on behalf of the Company.

The President & CEO, General Managers and Branch Managers of NH Consulting are responsible for establishing appropriate responsibilities, policies and objectives, procedures, training and internal controls within their respective operations to ensure the consistent implementation of this policy across all jurisdictions.

It is the responsibility of the Management of each Business Division to ensure that all NH Consulting employees and all third parties acting on behalf of NH Consulting are made aware of this policy and that appropriate due diligence is undertaken in relation to the appointment of all such parties and the monitoring of their activities.

It is the responsibility of each NH Consulting employee to ensure compliance with the terms of this policy. If any employee believes that the terms of this policy are not being correctly adhered to, they should bring this to the attention of their immediate Supervisor at once so that necessary actions can be taken.
As part of this policy as well as Company’s Corporate Policy, our Employees are encouraged, without fear of retaliation, to raise a red flag if they observe any violation of Company policy, rule, regulation, etc. Any concerns raised are then thoroughly investigated and handled.

Compliance

Compliance with this policy is mandatory for all NH Consulting Employees and Vendors and same is regularly reviewed and audited to ensure its continuous suitability, effective and proportionate with regards to Company’s operations and the jurisdictions within which it operates.

The Quality and Compliance Audit Manager is to submit an annual report to the Compliance Committee on the implementation of and compliance with this policy.

Any concerns raised by any person relating to any alleged non-compliance with the terms of this policy will be immediately investigated and appropriate actions taken. The Quality and Compliance Audit Manager will report to the Compliance Committee any such concerns and the outcome of any investigations conducted into such issues.

Failure to observe the terms of this policy may constitute a disciplinary offence, dismissal from employment and may expose individuals to civil or criminal proceedings.