1. THE PURPOSE OF THIS POLICY
Seven Insurance Brokers LLC (The Company) is committed to managing and conducting all aspects of its business in an ethical, honest and transparent manner.
The fundamental standards of integrity under which The Company operates, prohibits bribery, corruption or any other improper payments in any part of its business.
This policy, therefore, reflects The Company’s efforts and stated goal to implement and enforce an effective policy to counter bribery and corruption activities.
The policy is designed to reduce the risk of bribery and corruption activities occurring as well as their criminal and reputational impact on The Company and its stakeholders.
2. THE SCOPE OF THIS POLICY
This policy applies to all staff, full-time or part-time, trainees, agents, consultants, vendors, representatives and all relevant stakeholders.
All of the above have a personal and professional obligation to conduct the business activities of The Company ethically and in compliance with this policy as well as related policies, inter alia The Code of Conduct, The Staff Hand Book, The Corporate Governance Policy. Failure to do so will result in disciplinary action, including possible dismissal and criminal liability.
All affected individuals will be required to confirm that they have read and understood the contents of this policy and that they subscribe to its terms and conditions as part of their relationship, in whatever format, with The Company.
Any person, natural or juristic, mentioned in this section of the policy, who is in breach of the terms of this policy, shall
indemnify and hold harmless, The Company, and its directors, shareholders, employees and stakeholders, against any liabilities, actions, suits, losses and costs of whatsoever nature arising out of a breach of the terms of this policy.
3. THE POLICY STATEMENT
a. BRIBES AND KICKBACKS: Bribery involves the offering, giving or promise of a financial or other advantage to any stakeholder with an intention to reward them to perform their duties and responsibilities improperly.
Bribery also involves the requesting and/or accepting of a financial or other advantage by another person with the intention to reward them to perform their duties and responsibilities improperly.
Bribes may take the form of cash (or cash equivalent), unreasonable gifts, entertainment or hospitality.
Kickbacks occur when e.g. service providers pay part of their fees/commissions to the individual/s who award them a
contract or some other business advantage.
It is immaterial whether the bribe/kickback is offered or requested directly or through a third party.
As a matter of this policy, The Company prohibits its employees from engaging in acts of corruption and from paying bribes or kickbacks to public officials and/or private individuals, or conversely to accept bribes or kickbacks from public officials and/or private individuals.
b. PUBLIC OFFICIALS: Bribing or corrupting a public official is a serious offence, carries severe criminal penalties and
can cause significant reputational damage.
Any employee found guilty of this will face severe reprimand and, most likely, dismissal.
c. GIFTS AND HOSPITALITY: Employees of The Company may not offer to, or accept from, third parties, any gifts, hospitality, rewards, benefits or other incentives that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty.
Similarly, employees may not offer or accept cash donations.
Employees may, however, offer and accept reasonable and proportionate gifts and entertainment like dinner reservations, theatre tickets or sporting event attendance.
Employees must, at all times, consider the following guidelines and must ensure that the gift or benefit:
- Is being given as an expression of goodwill and not in expectation of a return favour;
- Is being provided openly and transparently, and is of a nature that will not cause The Company embarrassment, if publicly reported;
- Complies with local laws and regulations, including the recipient’s own rules;
- Meets the value limits set by The Company and has all required approvals.
In cases of uncertainty, employees must seek advice from their line managers beforehand.
Employees must seek prior approval from their line managers for all gifts or benefits received or offered with a value of more than AED 500.00 (Five Hundred Dirhams) or equivalent prior to final acceptance.
Approval must be given in writing and records of gifts received or given must be recorded in a specific log for such a purpose and being overseen by HR/Compliance.
d. CONFLICT OF INTEREST: Employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of The Company.
This includes acting on any client information gained through their employment with The Company or personal gain; passing such information to a third party.
Conflict of interest may arise if employees have a personal business interest in business dealings involving The Company. Such personal interest can be direct or indirect. If there is a potential for conflict or perceived conflict, this must be disclosed to The Company whose interests must take priority.
e. CHARITABLE DONATIONS: As part of its corporate citizenship activities, The Company may support local charities or provide sponsorship for example to sporting or cultural events.
Such sponsorships must be transparent and properly documented.
The Company will only provide sponsorship to organizations that serve a legitimate public purpose and who are themselves subject to high standards of transparency and accountability.
Appropriate due diligence must be conducted on any proposed recipient charity and its bona fides.
f. POLITICAL ACTIVITIES: The Company has a policy of strict political neutrality – as such it does not make donations to any political parties, organizations or individuals engaged in politics.
The Company will cooperate with governments and other official bodies regarding policy and legislation that may affect its legitimate business interests or where it has specialist expertise.
Employees are entitled to their own political views, but they may not use The Company’s premises or resources to promote such views, or associate their views with those of The Company.
The Company will make this policy available to all its employees. It will also form part of the Induction Training Programme for new employees.
All employees must ensure that they have full knowledge of the content and scope of this policy.
a. The Company’s failure to ensure compliance with this policy could lead to the following consequences:
- Criminal or civil liabilities for The Company, including fines and imprisonment;
- Serious reputational damage could lead to decline in business and growth.
b. Employees’ failure to ensure compliance with this policy could lead to the following consequences:
Personal criminal liability, including fines and imprisonment;
- Disciplinary action instituted by The Company, including the prospect of dismissal;
- Personal reputational damage.
6. MONITOR AND REVIEW
Human Resources and Compliance will review the implementation and ongoing management of this policy regularly considering its suitability, adequacy and effectiveness.
Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.