Privacy and compliance – ANTI BRIBERY / Foreign Corrupt Practices Act
Gifts, hospitality and expenses
All forms of bribery and corruption are prohibited. We will not tolerate any act of bribery or corruption. A bribe does not actually have to take place – just promising to give a bribe or agreeing to receive one is prohibited.
Facilitation payments are any payments, no matter how small, given to an official to increase the speed at which they do their job. For example, this could include speeding up customs clearance.
All facilitation payments are generally prohibited. However, safety is our primary concern and we understand that there may be circumstances in which we have no alternative but to make a facilitation payment in order to protect against loss of life, limb or liberty. Any request for a facilitation payment shall be reported immediately to our local anti-bribery and corruption officer.
Agent, distributors, suppliers and joint venture partners of us could be liable for the acts of people that act on our behalf. This includes agents, distributors, suppliers and joint venture partners (together referred to as “third parties”). As such we are committed to promoting privacy and compliance regulations, with effective anti-bribery and corruption policies by all third parties acting on our behalf.
Dealing with public officials
Although this policy applies to both public and private sectors, dealing with public officials poses a particularly high risk in relation to bribery due to the strict rules and regulations in many countries.
Public officials include those in government departments, but also employees of government owned or controlled commercial enterprises, international organizations, political parties and political candidates.
The provision of money or anything else of value, no matter how small, to a public official for the purpose of influencing them in their official capacity is prohibited.
Compliance with the policy
It is the responsibility of our anti-bribery and corruption officer to ensure compliance with this policy in each business.
Ultimate responsibility for privacy and compliance with this policy throughout the group is taken by Eurosurveillance CI in front of our clients.
We carry an obligation to act with integrity and to ensure that we understand and comply with this policy. Ongoing compliance will be monitored and reported by Eurosurveillance CI’s legal department and its officers.
An internal audit will take place periodically, to ensure the policy implementation and its legal requirements. A copy will be distributed to all our employees and third-party collaborators.
Consent – Wherever possible we obtain a consent before acquiring, holding or using personal data. Our forms, whether paper or web-based, which are designed to gather personal data do contain a statement explaining what the information is to be used for and who it may be disclosed to.
Sensitive data – We are particularly careful with sensitive personal data (i.e. information relating to race, political opinion, physical or mental health, religious belief, trade union membership, sexuality, criminal offences etc).
Review files – We only create and retain personal data where absolutely necessary. Securely disposal of or deletion of any personal data which is out of date, irrelevant or no longer required is mandatory. We run regular reviews of old files and discard unnecessary or obsolete data systematically.
Disposal of records – When discarding paper records that contain personal data we treat them confidentially (i.e. shred such files rather than disposing of them as waste paper). Similarly any unnecessary or out-of-date electronic records are deleted. We do not give away or sell our computers unless Information Services have ensured that all information stored on it has been removed or deleted.
Accuracy – We keep all personal data up to date and accurate, noting any changes of data and other amendments. If there is any doubt about the accuracy of personal data then we do not use it.
Security – We keep all personal data as securely as possible (e.g. in lockable filing cabinets or in rooms that can be locked when unoccupied). We do not leave records containing personal data unattended in offices or areas accessible. We also keep in mind that e-mail is not necessarily confidential or secure so should be secured and/or encrypted to the best of our abilities.
Disclosing data – We never reveal personal data to third parties without the consent of the individual concerned, of the client, or other reasonable justification. We endeavor to co-operate with Inland Revenue, National Courts or the National Police, but steps are first taken to ensure that such requests are genuine and legitimate.
Our Service Agreement on terms and conditions is here. You are encouraged to read and download the document, or just simply contact us for questions on Service Agreement or Privacy and Compliance terms.
Ethics – We always conduct our own services honestly and honorably, and expect our clients and suppliers to do the same. Our advice, strategic assistance and the methods imparted through our training, take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers. If there appears to be a conflict between our Code of Conduct and the law, we always obey the law. But, if our COC sets a higher standard than the law requires, we understand that it must be the standard for behavior.
Confidentiality – We are committed to maintaining the highest degree of integrity in all our dealings with potential, current and past clients, both in terms of normal commercial confidentiality, and the protection of all personal information received in the course of providing the business services concerned. We extend the same standards to all our customers, suppliers and associates.
Duty of care – Our actions and advice will always conform to relevant law, and we believe that all businesses and organizations, including this consultancy, should avoid causing any adverse effect on the human rights of people in the organizations we deal with, the local and wider environments, and the well-being of society at large.
Conflict of interest – Due to the sensitive nature of our particular consultancy services, we will not provide a service to a direct competitor of a client, and we generally try to avoid any dealings with competitor companies even after the cessation of services to a client.
Quality assurance – We maintain the quality of what we do through constant ongoing review with our clients, of all aims, activities, outcomes and the cost-effectiveness of every activity. We encourage regular review meetings and provide regular progress reports. This consultancy has been accredited under a number of quality assurance schemes. Further details are available on request.
Professional conduct – We conduct all of our activities professionally and with integrity, observing with the utmost care our privacy and compliance rules. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients
MEANS OF INQUIRY AND LAW COMPLIANCE
We always endeavor to make our research and work as legally-proof as possible. We never undertake anything even remotely linked to what it may appear to be a non-legit project and in any case, we do not engage in downright illegal operations of an kind, shape or form these may be.
We are always striving to observe the legality of our work; we do not put our clients at risk due to non legit reports sent to client for which he will have to answer to a court of law for the legality of it all.
If you have any questions regarding this document, or any queries at all regarding our policies of privacy and compliance, do not hesitate to contact us.