Anti‐corruption and bribery Policy
FSCS recognizes that our reputation for conducting business in an ethical and honest way is a core company value that must be valued and protected.
The purpose of this policy is to establish controls to ensure compliance with all applicable anti‐bribery and corruption regulations and to ensure that FSCS conducts business in a socially responsible manner.
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust.
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
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. We 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.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.
We remain bound by the Egyptian anti‐corruption laws and where relevant take due note of our obligations and responsibilities under other legislative jurisdictions including the British arbitration Bribery Act 2010, and the United States Foreign Corrupt Practices Act (FCPA) in respect of our conduct both at home and abroad. FSCS has a “zero tolerance” approach to acts of bribery and corruption by any of our employees or contractors. As well as being morally wrong, bribery and corruption are criminal offences that expose FSCS and individuals to the risk of prosecution, fines and imprisonment.
Any breach of this policy may result in disciplinary action, including termination of employment or contract. If the matter involves a breach of law or other regulation, the matter may also be referred to an appropriate law enforcement authority.
This policy covers FSCS Logistics Limited and controlled entities.
This policy applies to all individuals working for or on behalf of FSCS at all levels and grades, including directors, managers, employees (whether permanent, part‐time or casual), contractors, sub‐contractors, labor‐hire personnel, consultants or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). This policy applies to your interactions with any individual or organization you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy covers :
- Bribery and corruption;
- Receiving gifts, entertainment and favors;
- Giving gifts, entertainment and favors;
- Political contributions.
Your responsibilities :
You must ensure that you read, understand and comply with this policy.The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for FSCS or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager or a member of FSCS executive committee as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.
Record Keeping :
FSCS must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. You must declare and keep a written record of all hospitality or gifts accepted or offered, which may be subject to management review.
You must ensure all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses procedures and specifically record the reason for the expenditure.
How to Raise a Concern
Raising a concern about business conduct ultimately protects FSCS, its employees and other stakeholders. If you think a decision, action or practice is unethical, or in breach of this Policy, the FSCS Code of Conduct, other FSCS policies, or a breach of the law, you have the right and an obligation to raise that concern. You should immediately raise this with either your supervisor, manager, or a member of FSCS executive committee who will help you create a report.
Action by Fancy Speed Cargo Systems:
FSCS will fully investigate any instances of alleged or suspected bribery and take action as appropriate if it finds that an act of bribery has been committed.
FSCS will invoke its disciplinary procedure where any employee is suspected of bribery,and proven allegations may result in a finding of gross misconduct and immediate dismissal. FSCS may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, the Company who are found to have breached this policy.
We may also report any matter to the relevant authorities, including the Financial Services Authority, , Serious Fraud Office, Revenue and Customs Prosecutions Office and the Police. We will provide all necessary assistance to the relevant authorities in any subsequent prosecution.
Fancy Speed reviews all policies and procedures periodically to reflect changes in legislation, good practice etc.