Anti-Bribery Policy

The purpose of this policy is to ensure that our staff, suppliers and other interested parties complies with domestic and foreign anti-bribery and corruption laws, prohibiting improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector. 

Antitrust Policy

Policy Review and Monitoring

 

Creseada reviews the extents to which employees are complying with policies and following procedures, particular through accurate record-keeping and effective audits.

 

Sanctions

Breach of any policy by employees shall not be tolerated and can lead to disciplinary and other actions up to and including termination of employment.

Breach of this policy by our contractors, suppliers, vendors, consultants or other business partners may lead to the termination of such business relationships. 

 

Creseada is commitment to:

(a)        conducting its business fairly, honestly, accountably and transparently; 

(b)        complying with the provisions of the United States Foreign Corrupt Practices Act

            of 1977, as amended (“FCPA”), the U.K. Bribery Act of 2010 (“UKBA”), Independent Corruption

            Practices and Other Related Offences Act of 2000 (“ICPC’’), Economic Financial Crimes Commission

            Act of 2004 (‘’EFCC’’) and all other equivalent anti-corruption and/or anti-bribery

            legislation applicable to the Company;

(c)        not making, offering or accepting inducements or bribes, whether directly or

            indirectly, to gain business advantages or for any other purposes;

(d)        communicating the requirements through different channels to all personnel,

             suppliers, contractors and other interested parties.

 

Anti-Bribery Program

We seek to ensure that bribery and corruption prevention are effectively communicated

to employees and our interested parties by conducting annual training on Anti-bribery

and Corruption to raise overall awareness and successful practices across our system.

The purpose of this policy is to ensure that Creseada commitment to the highest standards of business conduct and ethics are upheld by every employee and that staff adequately comply with the principles of Antitrust Laws for fulfilling our business needs, accountability, and legal responsibility.

Antitrust

Antitrust laws are designed to protect the competitive process by prohibiting illegal agreements and collusion among competitors.

Creseada recognises that certain kinds of agreements and behaviour among competitors are generally prohibited and will ensure that employees avoid activities that may result in liability under the Antitrust laws including: Collusion with competitors; Competitive Intelligence; Bid Rigging and Collective Boycott.

Fair Dealing

Creseada prohibits unethical or illegal business practices to gain an advantage over our competitors, including acquiring proprietary information from others through improper means, possessing trade secret information that was improperly obtained, or inducing improper disclosure of confidential information from past or present employees of other companies.

If proprietary information or information that may constitute a trade secret belonging to another organisation is obtained mistakenly, or if you have any questions about the legality of proposed information gathering, you should consult the Audit and Compliance Manager.

All employees are expected to deal fairly with their customers, suppliers, employees and anyone else with whom they have contact in the course of performing their jobs.

 

Employees involved in procurement have a special responsibility to follow principles of fair competition and understand this Antitrust when they purchase products and services by selecting suppliers based exclusively on normal commercial considerations, such as quality, cost, availability, service and reputation.