Anti-Bribery Policy and Statement
Prepared: Iman Bayat Acting CEO GVC
Policy date: 2/05/2024
Review Date: Board meeting second Quarter 2024
Approved by Board: [6/05/2024 special meeting]
Next Review Date: [17th April 2025]
Introduction
Global Vascular Companionship (GVC) is committed to conducting its affairs with integrity, transparency, and in compliance with all applicable laws and regulations in particular as outlined by the Australian Department of Foreign Affairs and Trade policy on anti-corruption and Bribery for Australian Companies working overseas. These policies are found in this link: https://www.dfat.gov.au/international-relations/themes/corruption
Bribery and corruption are detrimental to our mission of promoting global vascular health equity and are wholly inconsistent with our values. This Anti-Bribery Policy outlines our stance against bribery and provides guidelines for preventing and addressing bribery-related issues.
Policy Statement
GVC prohibits all forms of bribery, whether direct or indirect, in any aspect of its operations. This includes offering, promising, giving, requesting, or accepting bribes, kickbacks, or facilitation payments, whether to or from individuals, businesses, government officials, or any other entity.
Applicability
This policy applies to all individuals and entities associated with GVC, including but not limited to employees, volunteers, board members, consultants, contractors, partners, and representatives acting on behalf of GVC.
Key Principles
Zero Tolerance: GVC maintains a zero-tolerance approach to bribery and corruption in all its activities.
Compliance with Laws: All individuals and entities associated with GVC must comply with anti-bribery laws and regulations applicable in their respective jurisdictions, including the DFAT policy on Anti Bribery and Corruption: https://www.dfat.gov.au/international-relations/themes/corruption
Transparency: GVC promotes transparency in all business dealings and expects its stakeholders to maintain accurate and honest records of all transactions.
Due Diligence: Before engaging in any business relationship or partnership, GVC conducts due diligence to assess the bribery and corruption risks associated with the potential partner or third party.
Reporting Obligations: Individuals must promptly report any suspected or actual incidents of bribery or corruption to the designated compliance officer or through the organization’s whistleblower mechanisms.
Non-Retaliation: GVC prohibits retaliation against individuals who report suspected violations of this policy in good faith.
Consequences of Non-Compliance
Violations of this policy may result in disciplinary action, including termination of employment/involvement as volunteer, contract termination, legal action, and reputational damage to individuals and GVC.
GVC reserves the right to report suspected violations of anti-bribery laws and regulations to the appropriate authorities.
Policy on Giving Gifts
It is acknowledged that in certain situations, small gestures of appreciation may be permissible as long as they are consistent with local customs and laws, do not violate the principles of fairness and transparency, and are not intended to result in unlawful activity or influence business. I practice small gifts such as Chocolate or tea from the mentors home country are appropriate.