Memories Group Limited (“MGL”) and its subsidiaries (together, “the Group”) have implemented its policy on ‘Anti Bribery’ in support of a Group wide Corporate Governance framework in preventing bribery and corruption.
The Group’s ‘Code of Conduct’ and ‘Conflicts of Interest’ Policies commit the Group not to engage in bribery, any form of unethical inducement or payment including facilitation payments and ‘kickbacks’.
For the purposes of this Anti Bribery Policy, bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, or to induce or reward improper conduct.
Bribery and corruption, whether involving government officials, or commercial entities, including joint ventures, can be direct or indirect through third parties such as agents, brokers and joint venture partners including facilitation of payments.
The Group is committed to put in place procedures to prevent bribery by any individual or organisation that performs services for or on behalf of the Group. Consequently, this Anti Bribery Policy applies to every employee, director and officer in every wholly-owned Group company and in every joint venture company which is subject to the control of the Group.
Contractors, consultants or suppliers who are our agents or who are working on our behalf or in our name, through outsourcing of services, processes or any business activity, will be required to act consistently with this policy when acting on our behalf. Independent contractors, consultants or suppliers will be made aware of this policy as it applies to our people in their dealings with them. Joint venture companies not under the Group control and joint venture partners are encouraged by the Group to adopt a similar policy, and adequate procedures, to prevent bribery.
The Group does not tolerate any form of bribery or corruption.
You must not offer, pay, make, seek or accept a personal payment, gift or favour in return for favourable treatment or to gain any business advantage. You must follow the anti-bribery and corruption laws to which you and the Group are subject, remembering that Singapore anti-bribery and corruption laws apply wherever you are operating.
You are liable to disciplinary action, dismissal, legal proceedings and possibly imprisonment if you are involved in bribery and corruption.
You must ensure people who work for and with you understand bribery and corruption is unacceptable.
You must comply with the Group procedures for the prevention of bribery and corruption.
This policy will be disseminated and published to all employees, contractors, suppliers and business partners.