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ANTI-CORRUPTION POLICY

DICKINSON GROUP OF COMPANIES (DGC) is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure all forms of bribery, corruption, and fraud are prevented. DGC has zero tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, we build with our employees. DGC will constantly uphold all laws relating to anti-bribery and corruption and adhere to the United Nations Global Compact requirements in combating any form hereof.

 

This policy applies to all employees, managers, and owners of DGC including temporary or contract employees. Employees must ensure that they do not become involved in any way in the payment of bribes. This policy sets out the minimum standards, conventions and recommendations, or any other relevant legislation that might be applicable, and is in compliance with the United Nations Global Compact and the UN Guide for Anti-Corruption Policies, to which all employees of DGC must adhere at all times.

DEFINITIONS

Bribery can be described as giving or receiving anything from any person (usually money, a gift, loan, reward, favour, commission, or entertainment), as an improper inducement or reward for obtaining business, employment, or any other benefit. Bribes can therefore include, but are not limited to:

  • gifts and excessive or inappropriate entertainment, hospitality, travel, and accommodation expenses;

  • payments, whether by employees or business partners such as recruiters, labour service providers, or consultants; and

  • other 'favours' provided to supervisors, such as making unwanted advances, payments, or promises.

COMPANY COMMITMENT

All employees of DGC must adhere to the company ethos of bribery and corruption. No employee or manager will be allowed to take part or become involved in any form of bribery, corrupt behaviour, or fraud, including the following:

  • Offer, pay, or give anything of value to any person through which one will unethically gain something in return that is not provided for in terms of their employment contract.

  • Attempt to mislead or induce any person to do something illegal or which goes against the company policy.

  • Mislead or intentionally lie to any person to gain an advantage above and beyond their employment agreement.

  • Violate any rules by shifting blame or responsibility onto another employee/person.

  • Fraudulent practices against the company ethos or legislation.

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DGC is committed to removing and combatting any inappropriate behaviour immediately and will not tolerate such behaviour from employees, managers, or customers/clients in any way or form. This policy hereby binds the company to its commitment to regularly discuss and mitigate factors related to any form of bribery, corruption, or fraudulent behaviour.

Trevor Dickinson

Chairman, Dickinson Group of Companies

THE UNITED NATIONS GUIDE FOR ANTI-CORRUPTION POLICIES
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