1. Introduction
1.1 The Uniformus (The Company) is committed to ethical business practices and in particular, to compliance at all
times with applicable anti-bribery and anti-corruption laws in all countries where Uniformus carries on business
(Collectively, the Anti-Corruption Laws).
1.2 The principles in this anti-bribery and corruption policy document (the Policy) apply to the full range of the
Company’s business activities around the world. In addition to legal requirements, Uniformus believes that long-term,
successful business relationships are built on honesty, fairness, and the strength of Uniformus’s products
and services, and not on unethical business practices. This Policy provides clear rules for Company personnel and
third parties engaged in Company business, to ensure compliance with the Anti-Corruption Laws and Uniformus’s
ethical standards and expectations.
2. Responsibility for compliance with this Policy
2.1 This Policy applies to all Company Personnel and all of Uniformus’s Business Partners. For these purposes:
Authorities Manual means the authorities manual for the time being of Uniformus;
Chairman means the chairman of Uniformus;
Company means collectively any branch, business or division operated by or under the control of any of Uniformus
Company Internal Audit means the internal audit department serving Uniformus;
Company Personnel includes all employees, officers, and directors of Uniformus and any of them;
Business Partners includes all third parties who are specifically appointed to engage in business for or on behalf
of Uniformus, including, without limitation, representatives, agents, and joint venture partners and excludes third
parties who supply goods or services to Uniformus.
Anti-Bribery and Corruption Policy
3. Prohibition against bribes and improper payments
3.1 Company Personnel and Business Partners are prohibited from:
(a) making or receiving bribes in connection with Company business; and
(b) offering or receiving any financial or other advantage to or from another party with the intention to
influence or reward the improper performance of an activity.
3.2 Bribes can take on many shapes and forms but typically they involve corrupt intent. There will usually be a
quid pro quo – both parties will benefit.
• A bribe could be direct or indirect promise, offering or authorization of anything of value or the offer or
receipt of any kickback fee, reward or other advantage.
• Bribery is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an
action which is illegal or unethical.
• Corruption is the misuse of public office or power for private gain, or misuse of private power in relation
to business outside the realm of government.
• Acts of bribery or corruption are designed to influence the individual in the performance of their duty and
induce them to act dishonestly.
3.3 If any Company Personnel breaches paragraph 3.1, disciplinary action may be taken against such individual up to
and including termination.
3.4 The use of intermediaries (including agents) for the payment of bribes or other improper payments
is prohibited.
3.5 There are no exceptions to the prohibition contained in this Policy against bribes or improper payment activity.
The fact that Company Personnel, for example, may be pursuing business in a country where that individual
believes corruption is widespread, is part of the culture or way of doing business, or where legal standards
governing bribery are unclear, or in a transaction where a Company employee has been solicited for a bribe,
will not serve as excuses for engaging in improper payment activity. Nor will evidence that Uniformus’s
competitors may be engaged in improper conduct. No Company employee or Business Partner will suffer adverse
consequences for refusing to engage in improper payment activity, even if this results in loss of business.
4. Extortion and requests to carry out improper payment activity
4.1 Uniformus will actively resist extortion and all other demands for improper payments made under duress.
In exceptional circumstances if payments must be made in order to secure personal health or safety, such
payments must be accounted for by local senior management and will be subject to audit. All such payments
must be reported to Chairman for further investigation.
4.2 Company Personnel should never engage in improper payment activity because instructed to do so by a manager
or co-worker. If this situation ever arises such individual must report this in accordance with relevant
procedures. For employees whose employment is governed by Uniformus Employee Regulations.
5. Guidelines on specified activities
The following “Guidelines” explain how the Policy applies to certain types of activities:
A. Facilitating Payments
There are limited circumstances in which the member of Uniformus concerned may be permitted to make a payment
to a government official without violating the applicable Anti-Corruption Laws. Some Anti-Corruption Laws have a
narrow exception for what is known as “facilitating payments” –payments to government employees to expedite or
secure the performance of a routine governmental action (Facilitating Payments). Under this exception, for example,
it may be permissible to make a Facilitating Payment to obtain permits, licenses or other documents to allow the
member of Uniformus concerned to do business in a certain country; to process governmental papers such as visas
and work orders; to provide police protection, mail pick-up and delivery or scheduling inspections; or to provide
phone service, power and water supplies, or loading and unloading of cargo.
It is Uniformus’s policy not to make or permit Facilitating Payments of any kind, except in certain limited situations in
which a Facilitating Payment is lawful and unavoidable. All Facilitating Payments must be approved by the Chairman
or either President. In addition, all Facilitating Payments must be fairly and accurately recorded and accounted for.
B. Gifts
1. You may not give or offer a gift to, or accept a gift from, anyone with whom Uniformus conducts business
where the gift would exceed customary courtesies associated with accepted ethical airline and general
commercial practice. The purpose of this requirement is to ensure that the offer or acceptance of a gift
does not create an obligation, or be construed by others to allege favoritism, discrimination or other
unacceptable practice.
2. Receiving or giving gifts of cash is strictly prohibited.
3. If you are requested to offer gifts that exceed the customary courtesies or that could give the appearance
of impropriety, you must immediately consult your supervisor and/or the head of your business unit. A gift
should not be accepted when to do so is either prohibited under local law or could be viewed as done for
the purpose of influencing a business decision or appears to create a conflict of interest for those involved.
C. Business entertainment and hospitality
1. Hospitality includes meals, invitations to events, functions or other social gatherings in connection with
matters related to the business of Uniformus. These activities are acceptable provided they fall within
reasonable bounds.
2. Reasonable and proportionate hospitality which seeks to improve the image of Uniformus, better to present
its services and products, or establish cordial relationships is recognized as an established and important
part of doing business. In order to amount to a bribe, hospitality must be intended to induce a person to
perform a function improperly.
3. Determining the acceptability of a particular form of business entertainment or hospitality requires the
exercise of individual judgement. In arriving at this judgement, ask yourself the following:
• What is the intent – is it to build a relationship or is it something else?
• Apply the ‘newspaper test’ – would a newspaper be likely to report the business entertainment or
hospitality, and if it did, what would the public’s perception be? For example, an all-expenses paid
overseas golfing weekend prior to a tender evaluation would almost certainly give rise to an adverse
impression if reported.
• Would you be comfortable in justifying the entertainment/hospitality to Company management?
If you find it difficult to answer one of these questions, there may be a risk involved which could potentially damage
Uniformus’s reputation and business.
Circumstances that are usually acceptable include:
• modest/occasional meals with someone with whom Uniformus does business;
• occasional attendance at sporting, theatre and other cultural events or social gatherings.
Circumstances which are not acceptable include:
• hospitality or entertainment which is offered for something in return – a ‘quid pro quo’; and
• entertainment of an inappropriate nature.
4. The form and cost of acceptable business entertainment or hospitality will depend on a number of factors,
including the nature of the relationship with the host or guest, the cost and standard of living in the region
and the acceptable forms of business entertainment or hospitality in the region. Should you have any doubt
as to what is acceptable in any particular situation you should consult your supervisor and/or the head of your
business unit.
5. Particular caution must be used in providing entertainment to government officials.
6. Business entertainment or hospitality expenses must be properly recorded in Uniformus member’s books
and records.
D. Sponsored travel
In appropriate circumstances, Uniformus may sponsor reasonable and bona fide travel expenses of customers,
potential customers and others that are directly related:
• to promoting or demonstrating Uniformus’s products and services; or
• to performing a contract between Uniformus and the customer; or
• to a fact-finding mission to understand relevant foreign markets and regulatory environments.
These expenses must have a legitimate business purpose and must be limited to those necessary to carry out
such purpose.
Sponsored travel expenses require prior written approval in accordance with the provisions of the Authorities Manual.
E. Political contributions
You may not make contributions to any political party or public international organization, without the prior written
approval of the Chairman or either President.
F. Business Partners
1. No Business Partners may be retained except in the manner and following the requirements for evaluating,
selecting and retaining such Business Partners as set out below.
2. All written agreements with Business Partners will include as a minimum standard contract provisions as follows
relating to compliance with Anti-Corruption Laws and this Policy:
(A) For the purposes of this clause, “Business Partner” means [insert name of Business Partner] and “Company
Company” means [insert name of Company].
(B) The Business Partner acknowledges that it has received a copy of the Uniformus Anti-Bribery and
Corruption Policy (the Policy) and agrees to comply with the provisions of the Policy at all times during
the term of this Agreement. The Business Partner shall indemnify Uniformus Company and each of its
directors, officers and employees from and against any liability, fine, loss or damage arising out of or in
connection with any breach of the Policy by the Business Partner. In the event of any breach of the Policy by
the Business Partner, Company may immediately terminate this Agreement by written notice to the
Business Partner. The indemnity provided by the Business Partner in this clause shall survive any termination
of this Agreement.
3. Business Partners may be paid by cheque or wire transfer only, and never in cash. All payments will be made
pursuant to invoices, receipts or other documentation documenting services rendered in detail. All agreements
with Business Partners will contain standard contract language setting out these requirements.
4. Business Partners may be hired only after the completion of an appropriate level of due diligence. Such
due diligence may include: ownership, background checks, reviews of letters of recommendation, reviews
of credentials, reviews of financial statements, contact with local Chambers of Commerce, independent
confirmation of the candidate’s history of government employment and evaluation of the candidate’s other
connections to government officials, including family relations.
5. Business Partners may be engaged only in accordance with the provisions of the Authorities Manual. The
concerned business manager will have the responsibility of ensuring that any and all “red flags” have been
investigated and ruled out.
6. Doing business with the government
Company Personnel must be especially vigilant in dealing with all government officials. Activities that may be permissible
when working with private sector partners may be improper or illegal when working with a government official.
Company Personnel who have any questions regarding whether interactions with government officials are appropriate
should immediately contact CAHIRMAN
7. Compliance
It is the responsibility of all Company Personnel to understand and comply with this Policy.
8. Implementation
Local management is responsible for implementation of this Policy and ensuring their employees are aware of
the Policy. Any Company Personnel who has any question in respect of the Policy should address this to his local
management. Company Internal Audit will monitor the implementation of this Policy through the internal audit process.
9. Record keeping
All of the books and records of the members of Uniformus must fully and fairly reflect all expenditures of the
member’s funds. Attempts to create false or misleading records are forbidden. These requirements apply to all books
and records of the members of Uniformus. No payment on behalf of any member of Uniformus may be approved
without adequate supporting documentation or made with the understanding that all or part of such payment is
or has been used for purposes other than those identified in supporting documents. No undisclosed or unrecorded
funds of any member of Uniformus, such as “off the books” accounts, shall be established for any purpose. No
payments can be made, directly or indirectly, to undisclosed or unknown recipients, or any other individuals with
whom Uniformus employee responsible for maintaining the relationship is unable to vouch for his or her bona fides.
10. Breaches and reporting
1. Breach of this Policy may result in disciplinary action for Company employees up to and including termination and/
or referral to national law enforcement authorities. Breaches of the Anti-Corruption Laws could also subject the
individual who committed the violation to civil or criminal penalties, including substantial fines and potentially
lengthy imprisonment. For Business Partners, breach of this policy will lead to termination of the relationship
with Uniformus.
2. All persons subject to this Policy are required promptly to report any instances of non-compliance with this
Policy to the Charman . Failure to do so will be treated as a violation of this Policy, and may result in disciplinary action up to and including termination.