Anti-Corruption Policy

 

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption, and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

This Code of Ethics is mandatory for all business partners of Sophie Bille Brahe that supply goods and/or services, act on behalf of or have other kind of collaborations with Sophie Bille Brahe such as e.g. suppliers, vendors, consultants, landlords, agents, service providers and organisations.

This policy applies in all countries or territories where the Company operates. Where local customs, standards, laws or other local policies apply that are stricter than the provision of this policy, the stricter rules must be complied with. However, if this policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this policy shall apply.

Definition of Bribery/Corruption: Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favor, or a financial or other advantage from another to influence a business outcome improperly, to induce or reward improper conduct or to gain any commercial, contractual, regulatory or personal advantage. It can be direct or indirect.

Facilitation payments are typically unofficial payments made with the purpose of securing a routine or necessary action e.g. by a government official. If you are faced with a demand for a facilitation payment, you must declare the matter to your manager and comply with his/her instruction, as well as register it for internal record keeping. Facilitation payments are not permitted when acting for or on behalf of Sophie Bille Brahe.

External guidelines:

It is not acceptable for any business partners for Sophie Bille Brahe (or someone on behalf of) to:

(a)                  give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

(b)                  give, promise to give, or offer, a payment, gift or hospitality to a Public Official or Third Party to ‘facilitate’ or expedite a routine procedure;

(c)                  accept payment from a Third Party that you know, or suspect, is offered with the expectation that it will obtain a business advantage for them;

(d)                  accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

(e)                  threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this policy; or

(f)                   engage in any activity that might lead to a breach of this policy or perceived breach of this policy.

 

Internal guidelines:

This policy does not prohibit normal and appropriate hospitality (given and received) to or from Third Parties.

Employees working for Sophie Bille Brahe are prohibited from accepting a gift or giving a gift to a third party in the following situations:

(a)                  it is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

(b)        it is given in your name and not in the name of the Company;

(c)        it includes cash or a cash equivalent (such as gift certificates or vouchers);

(d)                  it is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process)

(e)        it is given secretly and not openly.

 

We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another.  The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and proportionate.  The intention behind the gift should always be considered.

All Employees and business partners have the responsibility to read, understand and comply with this policy.  Both parties should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their manager or the HR department.

Suppliers and other business partners are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through info@sophiebillebrahe.com.