Recann Ltd. is a strategic global recruitment company (“we, us, our, Recann”). This Anti-Bribery Policy (Global) (“Policy”) prohibits the act of bribery towards both government officials and private sector individuals. It forbids offering, promising, authorizing, or providing any sort of benefit in exchange for improper behaviour in connection to the business. This AntiBribery Policy applies to Recann’s personnel, government officials, as well as customers, business partners, vendors, and other third parties
2 PURPOSE OF THIS POLICY
Violating this Anti-Bribery Policy may result in disciplinary actions such as termination of employment or other contracts you may have entered into with us. It is important for you to understand and follow both of these policies in your daily work to avoid any consequences. The purpose of this Anti-Bribery Policy is to identify the risks associated with bribery and corruption, emphasize your responsibilities under anti-corruption laws and company policies, and provide you with the necessary resources to recognize and prevent corruption risks.
3 CONSEQUENCES OF NON-COMPLIANCE
Breaking anti-corruption laws can result in severe legal consequences and damage our reputation. Individuals or entities who violate these laws may also face serious legal penalties, including imprisonment. The violation of this Anti-Bribery Policy may result in disciplinary actions, such as termination of employment, or termination of other agreements you may be a party to with Recann in accordance with our Terms.
4 SCOPE OF THE POLICY
Recann places high importance on ethical and lawful business practices and expects all individuals associated with the company to act in accordance with these principles. This includes refraining from any form of bribery or Page 2 of 5 corruption, no matter where they are located or their citizenship. Recann takes a zero-tolerance approach to bribery and corruption, and expects all individuals working on its behalf to uphold these values and adhere to the provisions outlined in the Anti-Bribery Policy.
5 APPLICABLE LAWS
You are required to comply with all applicable anti-bribery laws, including the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), and the local laws in each country where the company operates. Practically every country prohibits bribery, which includes both bribery of government officials and private sector individuals. In addition to prohibiting bribery, the FCPA requires companies to keep accurate records and have proper internal controls in place.
6 PROHIBITION OF BRIBERY
6.1 Government Bribery: Recann and its personnel are not allowed to provide, promise, offer, or authorize the payment of anything of value to any government official for the purpose of obtaining or retaining business, gaining an improper advantage, or improperly influencing a government official's actions. Additionally, it is important for personnel of Recann to avoid creating the appearance of inappropriate interactions with government officials.
6.2 Commercial Bribery: In addition to the ban on bribing government officials, Recann also prohibits its personnel from offering or accepting corrupt payments or benefits from private individuals or entities. These types of payments, also known as "kickbacks," are considered commercial bribery.
6.3 Facilitation Payments: Recann’s ban on bribery covers all forms of improper payments, including "facilitating" payments, regardless of the size or purpose. Facilitating payments refer to small payments made to government officials to quickly complete routine actions or services, suchas obtaining a license or permit, processing government documents, or providing utilities.
7 PROVIDING ITEMS OF VALUE TO GOVERNMENT OFFICIALS
7.1 Giving gifts, meals, travel, or entertainment to anyone, whether they be government officials or commercial partners, in exchange for an improper advantage or benefit is never acceptable. Also, giving or receiving gifts in the form of cash or cash equivalents, such as gift cards, is strictly forbidden.
7.2 Giving a donation with the intention of improperly influencing a government official or in exchange for an improper advantage or benefit is not allowed under any circumstances
7.3 Directing promotional expenses or activities towards a government official with the aim of improperly influencing them or in exchange for an improper advantage or benefit is not allowed.
7.4 It is not allowed to hire or engage a government official, or their immediate family members, with the intention of improperly influencing the official or in exchange for an improper advantage or benefit.
7.5 It is never permissible to provide a political contribution to improperly influence a government official, or in exchange for any improper favour or benefit.
8 APPLICABILITY TO THIRD PARTIES
Third-party agents, consultants, distributors, and any other representatives working for Recann are prohibited from making bribes on behalf of Recann. This rule also applies to subcontractors hired by these third parties for work done for Recann.
Recann expects all personnel to conduct due diligence on any third party before engaging in business with them and to periodically review such third parties’ ongoing compliance with applicable anti-corruption laws and our policies. Personnel must also report any suspected or actual violations of anti-corruption laws or the Recann’s policies to us.
Recann may conduct periodic reviews of third-party relationships to assess the ongoing compliance with the Anti-Bribery Policy and to ensure that third-party representatives are not engaging in any prohibited conduct. Recann may also terminate its relationship with any third party found to be in violation of the Anti-Bribery Policy or any applicable anti-corruption law. In addition to the due diligence process, Recann may require all third parties to sign an agreement that they will comply with all applicable laws, including anti-corruption laws, and to certify their compliance with these laws on an ongoing basis. The agreement should also provide that any violations of these laws by the third party will be considered a material breach of the agreement, allowing Recann to terminate the relationship with the third party.
All agreements with third parties must include provisions requiring the third party to comply with all applicable Anti-Bribery laws and to act in accordance with the Recann’s Anti-Bribery Policy and all other Company policies. These provisions should also require the third party to maintain accurate books and records related to its work for the Recann and to allow for audits and inspections by Recann or its agents. Failure by a third party to comply with these requirements may result in the termination of the agreement and other legal and contractual remedies.
In addition to periodic internal audits, Recann may also conduct investigations into any actual or suspected violations of this Policy and applicable Anti-Bribery laws. All employees, officers, directors, and third parties working on behalf of Recann must cooperate fully and truthfully with any such investigation and are required to disclose any information they have regarding actual or suspected violations of this Policy. Interference or obstruction of an investigation is a serious violation of this Policy and could result in disciplinary action, up to and including termination of employment or contractual relationship.
10 REPORTING VIOLATIONS
Additionally, if you are aware of or suspects a violation of Anti-Bribery laws or this Policy, you must immediately report the suspected violation to Recann or its authorised personnel. The reporting party should provide all relevant details, including the names of individuals involved and the nature of the suspected violation. Recann will take appropriate and prompt action to investigate any reports of suspected violations, including any potential violations of Anti-Bribery laws. Recann takes all reports of potential violations seriously and will take all necessary steps to ensure compliance with Anti-Bribery laws and to enforce this Policy.
Please report any violations using the contact details provided below: