AMJ CAMPBELL ANTI-BRIBERY POLICY

Anti-Bribery & Anti-Corruption Charter 

Leading The Fight against Corruption

FIDI is determined to lead the relocation industry by taking a clear stand against bribery and corruption. By doing so, FIDI will protect the best interests of the industry, the Affiliates and their customers.

Background

Membership in FIDI is highly valued by its Affiliates, and to ensure that value continues, all FIDI Affiliates pledge to abide by the highest ethical standards.

This Anti-Bribery & Anti-Corruption Charter is a declaration of commitment. It strengthens the FIDI organization, the FAIM program, and all Affiliates by making it clear what distinguishes FIDI Affiliates from non-FIDI companies.

All FIDI Affiliates agree to sign and be guided by the Charter’s provisions. The Charter covers their employees (whether permanent, fixed term or temporary) and any associated third parties providing services to or on behalf of the FIDI Affiliates.

The Charter is an integral part of the FAIM Standard. The procedural and audit requirements is part of the FAIM Implementation Manual and the Pre-Audit assessment.

What Is Bribery?

• Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action. It is illegal, and it is a breach of trust.
• A bribe is an inducement or reward offered, promised or provided in order to gain a commercial, contractual, regulatory or personal advantage.

FIDI Will Not Tolerate Bribery

Corruption, bribery or attempted bribery is unacceptable. This applies whether offering a bribe, or accepting a bribe. It is against FIDI’s core values of conducting business to the highest legal, moral and ethical standards.

Bribery and corruption are covered by various international laws and statutes. These laws often require companies, including FIDI Affiliates, to have rigorous, pro-active measures in place to detect and prevent corrupt practices.

Charter Statement

Undertaking by all FIDI Affiliates with immediate effect

All FIDI Affiliates commit to legal and ethical behaviour, and to refrain from doing anything that will harm the interests of FIDI, other Affiliates, clients, or the industry. FIDI and its Affiliates will take steps to ensure they are fully informed of applicable regulations and will monitor their employees and business partners to ensure full and continual compliance.

Legal compliance

FIDI Affiliates will ensure that they are aware of all applicable laws countering bribery and corruption in all the jurisdictions in which they operate, and that they will obey and uphold those laws.

The laws that apply to particular international business activities include those of the countries in which the activities occur as well as others that – like the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010 – govern the international operations of national companies and citizens in respect of their conduct both at home and abroad.

Ethical behaviour

As a demonstration of its commitment, FIDI and its Affiliates pledge to take a zero- tolerance approach to bribery and corruption. At all times, FIDI and its Affiliates will act professionally, fairly and with the utmost integrity in all business dealings and relationships. This will apply wherever they operate.

Commitment to the values of FIDI

This Charter will be formally integrated into the FAIM quality standard.

Code of Conduct

By agreeing and committing to this Charter, each FIDI Affiliate undertakes to:

• Never engage in any form of bribery, either directly or through any third party.
• Never offer or make an improper payment, or authorize an improper payment (cash or otherwise) to any individual, including any local or foreign official anywhere in the world.
• Never attempt to induce an individual, or a local or foreign official to act illegally or improperly.
• Never offer, or accept, money or anything of value, such as gifts, kickbacks or commissions, in connection with the procurement of business or the award of a contract.
• Never offer or give any gift or token of hospitality to any public employee or government official or representative if there is any expectation or implication for a return favour
• Never accept any gift from any business partner if there is any suggestion that a return favour will be expected or implied.
• Never facilitate payments to obtain a level of service which one would not normally be entitled to.
• Never disregard or fail to report any indication of improper payments to the appropriate authorities.
• Never induce or assist another individual to break any applicable law or regulation.

 

Anti-Trust Charter 

Compliance with the FIDI Anti-Trust Charter (ATC) is a mandatory requirement for all FIDI Affiliates. 

FIDI Delegates from all FIDI Associations unanimously approved the ATC document during the FIDI Extra-Ordinary General Assembly in Long Beach on 8 October 2017.

Leading the Fight Against Cartels

FIDI supports the adoption of Anti-Trust compliance programs by its Affiliates. In this connection, FIDI is determined to support the fight against cartels, which restrict competition among suppliers to the detriment of customers.

Background

Membership in FIDI is highly valued by its Affiliates, and to ensure that value continues, all FIDI Affiliates pledge to abide by the highest ethical standards and to free and fair competition.

The Anti-Trust Charter is a declaration of commitment. It will strengthen the FIDI organization, the FAIM program, and all Affiliates by making it clear what distinguishes FIDI Affiliates from non-FIDI companies.

All FIDI Affiliates agree to sign and be guided by the provisions of the Anti-Trust Charter. The Anti-Trust Charter covers their employees (whether permanent, fixed term or temporary) and any associated third parties providing services to or on behalf of the FIDI Affiliates. The Anti-Trust Charter is an integral part of the FAIM Standard. The procedural and audit requirements forms part of the FAIM Implementation Manual and the Pre-Audit assessment.

 What Is a Cartel?

A cartel is an agreement, concerted practice or conspiracy among competitors to fix prices, submit collusive tenders, divide or share markets and, more generally, restrict competition.

A cartel is regarded as the most egregious violation of Anti-Trust laws in most jurisdictions, which may lead to the imposition of significant fines as well as, in certain jurisdictions, criminal penalties.

 FIDI Will Not Tolerate Cartel Conduct

FIDI respects the Anti-Trust laws and regulations in the countries in which it operates and requires that its Affiliates do the same. Involvement in a cartel is unacceptable. It is against FIDI’s core values of competing freely and fairly, based on the added value of its products and services.

The laws and regulations that sanction cartel conduct are in place in most jurisdictions. These laws and regulations are designed to promote free and fair competition and to protect consumers. Anti-Trust compliance programs are e to detect and prevent cartels.

Charter Statement

• Undertaking by all FIDI Affiliates with immediate effect

All FIDI Affiliates commit to legal and ethical behaviour, and to refrain from engaging in any business that will harm the interests of FIDI, other affiliates, clients, or the industry. FIDI and its Affiliates will take steps to ensure they are fully informed of applicable Anti-Trust laws and regulations in connection with cartel conduct and other Anti-Trust violations, and will monitor their employees and business partners to ensure full and continual compliance.

• Legal compliance

FIDI Affiliates will ensure that they are aware of all applicable laws and regulations covering anticompetitive practices in all the jurisdictions in which they operate, and that they will obey and uphold those laws and regulations.

FIDI affiliated companies will ensure that they are aware of, and are complying with, applicable laws and regulations in connection with cartels.

• Ethical behaviour

As a demonstration of its commitment, FIDI and its Affiliates pledge to take a zero-tolerance approach to cartel conduct. At all times, FIDI and its Affiliates will act professionally, fairly and with the utmost integrity in all business dealings and relationships.  This will apply wherever they operate.

Code of Conduct

By agreeing and committing to this Charter, each FIDI Affiliate undertakes to:

Never make direct or indirect (via third parties including agents, suppliers or customers) contact with an actual or potential competitor or other third parties, the object of which is to engage in cartel behaviour.

Never propose or reach an agreement, whether directly or indirectly, formally or informally, with actual or potential competitors, regarding any sensitive competition-related issues, including:

• Fixing prices
• Dividing or sharing markets, customers or territories
• Rigging a competitive bidding process.

Report any indication or initiative of improper anticompetitive business conduct by an actual or potential competitor in accordance to your internal reporting procedure, including but not limited to, reporting to your legal department and/or to the relevant Anti-Trust authorities.

Not to participate in a meeting of a trade association in which sensitive competition-related issues are discussed. If such subjects are raised during a meeting, employees of FIDI Affiliates must immediately ask for the discussion to end.  If not, they must leave the meeting and ask for that to be noted in the minutes of the meeting.

Ensure that all internal and external correspondence, including e-mails and texts, and documents, discussions and public statements do not contain any statements that might be misinterpreted by third parties or Anti-Trust authorities and courts in the context of a potential Anti-Trust investigation.

Maintain independent judgment in pricing or selling of any products and/or services.

Limit any information discussed during commercial negotiations, with or disclosed to competitors or other third parties, to that which is strictly necessary for completing or assessing the transaction.