Anti-Corruption and Business Code of Ethics Policy
I. Introduction.
The purpose of this policy is to set forth the Cinchio Solutions’ commitment to complying with all applicable anti-corruption laws and promoting ethical business practices the design of which will assist its employees, officers, directors and agents avoid corruption, conflicts of interest, and unethical behavior while conducting business activities on behalf of the company. This policy applies to all employees, officers, directors, contractors, agents, and representatives of Cinchio Solutions.
II. Compliance with this policy, local laws and regulations.
Complying with laws, regulations, and accepted business practices involves not just following the law but also conducting business in a manner that upholds your ethical responsibilities. If local laws are less stringent than this policy, you must still adhere to the policy, even if your actions would otherwise be legal. Conversely, if local laws are stricter than this policy, you must always, at a minimum, comply with those laws.
III. Anti-Corruption Compliance.
Cinchio Solutions is committed to conducting business with the highest standards of integrity and in full compliance with anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and other applicable local laws in the jurisdictions where we operate. Employees, officers, and agents are expected to comply with all applicable anti-corruption laws.
IV. Bribery Prohibition.
Cinchio Solutions prohibits the offer or payment of bribes. Employees, officers, and agents must not offer, promise, or give anything of value (including cash, gifts, or entertainment) to any individual or organization, including government officials, political parties or candidates for office, public sector employees, customers, or business partners, with the intention of improperly influencing a business decision or securing an improper advantage for Cinchio Solutions, its partners, others or yourself.
V. Money Laundering.
Cinchio Solutions prohibits all forms of money laundering, which includes concealing, transferring, or converting illegally obtained funds into legitimate money.
VI. Economic Boycotts.
Participating in any economic boycott not sanctioned by the United States Government and/or providing information that could be construed to support any such unsanctioned boycotts is strictly prohibited.
VII. No Facilitation Payments.
Employees, officers, and agents must not make or accept facilitation payments (small bribes made to expedite routine government actions such as issuing permits, licenses, etc.) for bribes or other improper purposes.
VIII. Government Entities.
Cinchio Solutions prohibits the unlawful offer or giving of anything of value to government and public sector employees. Employees, officers, and agents may only offer, promise, or give something of value (including cash, gifts, or entertainment) where permitted by law and as allowed by Company policy.
IX. Governmental Dealings.
There is a more stringent standard for dealings with government and public sector employees. Actions that might be acceptable when dealing with nongovernmental customers can be inappropriate and even illegal when engaging with government entities. Employees, officers, and agents that deal with any governmental or public entities are expected to know and comply with the applicable rules and regulations that concern government contracting and interactions. This includes, but is not limited to, (1) seeking or obtaining procurement-sensitive, confidential, or proprietary information, including government or competitor data, unless it is publicly available or authorized for disclosure; (2) ensuring all invoices submitted are accurate and in compliance with applicable law; (3) giving anything of value to government or public employees and officials except where permitted by law; (4) providing, offering or soliciting kickbacks for favorable treatment. It is also prohibited to pay or receive contingent fees, directly or indirectly, to obtain a government contract or influence government actions.
X. Gifts, Hospitality, Entertainment and Business Courtesies.
Cinchio Solutions expects its employees, officers, and agents to use their best judgment and discretion to ensure that any expenditures are proper and could not reasonably be construed as a bribe or improper attempt to secure advantage. Similarly, Cinchio Solutions’ employees, officers, and agents must use their best judgment and discretion to ensure any expenditure, gift or business courtesy accepted is proper and could not reasonably be construed as an improper attempt to secure advantage or favorable treatment from Cinchio Solutions or its agents. Employees, officers, and agents may only give and accept gifts in a manner that is ethical, transparent, and complies with applicable laws. Gifts should not be given or received if they create a sense of obligation or improperly influence business decisions. Any gifts offered or received must be aligned with industry practices. Cinchio Solutions expects all employees to avoid situations where gifts could compromise their objectivity or create conflicts of interest.
XI. Insider Trading.
Cinchio Solutions expects its employees, officers, and agents to comply with all insider trading and securities laws. It is strictly prohibited from using inside information, whether obtained from Cinchio Solutions, its partners, vendors, contractors or any other third party, for personal advantage or to disseminate the information to third parties before it is publicly available. Violation of this policy exposes yourself and Cinchio Solutions to civil and criminal liability.
XII. Conflicts of Interest.
A conflict of interest occurs when personal interests or external relationships interfere with making unbiased decisions for the company. At Cinchio Solutions, employees, officers, and agents must avoid conflicts of interest that could interfere with their ability to act in the company’s best interests. Conflicts may arise from personal financial interests in competitors, suppliers, or customers, outside business activities, personal relationships influencing decisions, or accepting gifts or benefits that could affect objectivity. Employees are required to disclose potential conflicts immediately through the appropriate channels. Retaliation against those who report conflicts in good faith is not tolerated. These conflicts will be reviewed and managed, which may involve reassignment or recusal from certain decisions and as otherwise deemed necessary to prevent any conflict in interest. Engaging in activities that prioritize personal interests over the company’s, or using confidential information for personal gain, is prohibited.
XIII. Honest and Ethical Competition for Business.
Cinchio Solutions is committed to competing for business opportunities fairly, ethically, and honestly. As part of this commitment, Cinchio Solutions strives to maintain integrity in all its business practices by adhering to applicable laws, regulations, and industry standards, and by refraining from deceptive, unfair, or unethical conduct. There is no tolerance for false representations, misleading competitors or clients, or other deceptive business practices. Our approach to competition is based on providing high-quality products and services, fostering transparent relationships, and respecting the rights and interests of all stakeholders.
XIV. Commissions.
Cinchio Solutions recognizes that commissions can be an important part of business operations and that it is paramount to ensure commissions are paid in a transparent and ethical manner. Commissions must be reasonable, transparent, and directly linked to legitimate services or business transactions. Payments must be made to legitimate business entities for specific services rendered and not for any improper or illegal purposes. No commissions may be paid to third parties unless there is a legitimate business reason for such payment, the commission is commercially reasonable, and proper documentation is maintained. Commissions must not be paid to induce or influence any party, particularly government officials, to act improperly or in violation of applicable laws.
XV. Reporting and Whistleblower Protection.
Cinchio Solutions encourages all employees, officers, directors, contractors, and agents to report any potential violations of this policy. Reports can be made anonymously through People Department or directly to Cinchio’s Managing Director. Cinchio Solutions is committed to protecting whistleblowers from retaliation. Any retaliation against employees who report in good faith will not be tolerated.
XVI. Training and Awareness.
Cinchio Solutions will provide anti-corruption and business ethics training to all employees, particularly those involved in procurement, sales, and any functions that involve interaction with government officials or third parties. Training will be conducted as part of the onboarding process for new employees. As part of any annual review Employees will confirm their understanding of this Anti-Corruption and Business Code of Ethics Policy and additional training will be implemented as required.
XVII. Monitoring and Enforcement.
Cinchio Solutions will regularly monitor compliance with this policy. Employees found to be in violation of this policy may be subject to disciplinary action, including termination of employment, in accordance with company policies.