ABC standards
EIB is committed to observe the following adequate procedures principles (T.R.U.S.T.):
1. Top Level Commitment
The top-level management spearheads the Company’s efforts to improve upon the effectiveness of its bribery
and corruption risks management framework, internal control system, review and monitoring and training and
communication. The Company’s CEO and senior management have the responsibility to act as role models
and build a transparent, safe and trustful culture within their teams ensuring that there are sufficient
processes and resources to undertake the required roles and responsibilities for the effective operation
of the ABC programme
The Company’s CEO will appoint a suitable person as the ABCO who leads the ABC function and has a reporting
line to appropriate the Company’s senior management in order to oversee the application of the ABC
policy in the Company.
2. Risk Assessment
The Company conducts bribery and corruption risk assessments at least annually and when there is any significant
change in the business or regulatory requirements. When performing risk assessments, the Company takes into
consideration of various factors including its relationship with third parties in its supply chain.
The completed RA is reviewed and signed-off by the Company’s CEO as the person accountable for the ABC
Policy together with the ABC Officer. The completed risk assessment is submitted to the Head Office Compliance
and reported to the Board of Directors and Audit and Compliance Committee (ACC).
3. Undertake Control Measures
The Company has put in place the appropriate controls and contingency measures to address any bribery and corruption
risks:
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Due diligence
The Company conducts due diligence on relevant parties prior to entering any formalised relationships.
Methods may include background checks, document verification process and risk assessment.
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ABC Policy
The Company’s policy must be approved by the Board and is reviewed and/or refreshed annually and
when there is any significant change in the Company’s business and regulatory requirements
in order to ensure the Company’s ABC Policy remains up-to-date and relevant.
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Reporting channel
The Company has in place an accessible and confidential reporting channel called ‘Speak Out’.
The Company encourages its staff to raise concerns of bribery and corruption and their identities
will be protected and the Company prohibits any form of retaliation against those making reports
in good faith.
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A general ABC policy and statement
The Company ensures clear and unambiguous ‘tone from the top’ to all employees and business
partners that the bribery and corruption are unacceptable.
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Conflict of interest
The Company has in place Conflict of Interest Policy which requires declaration of conflict of interest
to manage such risks.
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Gifts and hospitality
While the Company welcomes great rapport with its business partners, the Company follows a strict gifts
and hospitality policy.
Gift is an object or item given to a person(s) in recognition of an event or special occasion.
Hospitality refers to provision of meals, entertainment, travel or accommodation.
We are committed to promote integrity when giving and receiving gifts and hospitality and we are bound
by the following:
- Principles of gifts and hospitality The gifts and hospitality:
- Must not be solely due to promoting relationship, but they must have a justified business rationale;
- Must be proportionate with the intention behind them i.e. not extravagant and lavish;
- Must not influence any party’s influence or compromise their judgment;
- Must be consistent with the norm in the industry sector;
- No elements of concealment.
- Our staff are not allowed to give or receive gifts and hospitality that are:
- Of cash or cash equivalents (including pre-paid card, cash/gift vouchers, etc.)
- Indecent, inappropriate or would damage the Company’s integrity or reputation;
- Breaching any local law or regulation;
- The recipient is not permitted to receive by their employer/principal;
- Where a staff attempts to circumvent our gifts and hospitality policy by personally paying the gifts and
hospitality (out of pocket expenditures);
- Persons engaged in negotiations (e.g. contract awards / tenders);
- When the Company is actively pursuing commercial engagements, regardless of value.
- The Company is also not allowed to request our business associates to sponsor the cost of our staff events
or for lucky draw prizes.
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For certain types of gifts and hospitality such as the provision of external training, travel and/or accommodation; the Company
would bear the cost of travel and accommodation and the Company would issue a Transparency Letter to
ensure no excessive gifts and hospitality is offered. Additionally, if the cost of the external training
/ event exceeds the Approval Threshold above, the Company must pay for the training.
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Meals and refreshments as well as gifts associated with a company-organised marketing events must be reviewed and approved
in accordance with the Company’s governance framework for such events and must be recorded and
assessed for appropriateness (i.e. it must be proportionate to the relationship and not extravagant or
excessive).
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Charitable donations and sponsorships
The Company prohibits political contributions. All charitable contributions and sponsorship must be undertaken
in line with agreed and documented processes with supporting authorisations in line with corporate
schemes and guidelines.
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Facilitation payments
Facilitation payments are not permitted or condoned by the Company.
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Financial and non-financial controls
o Separation of duties and approving powers or multiple signatories for transactions;
o Separation of duties and approving powers or a pre-tendering process;
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Monitoring framework
Managing and improving upon any inadequacies in the anti-corruption monitoring framework;
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Record keeping
The Company’s CEO and CFO must ensure accurate and honest recording within company books and records
(which are not limited to finance related records). All relevant records to demonstrate compliance
with the relevant regulatory requirements will be maintained.
4. Systematic Review, Monitoring and Enforcement
The Company consistently review and assess the effectiveness of its ABC framework e.g. internal audit, monitor
the performance of personnel in relation to our ABC standards and conducting disciplinary proceedings against
personnel found to be non-compliant to the programme.
5. Training and Communication
The Company will develop and disseminate internal and external training and communications relevant to its ABC
management system, in proportion to its operation, covering the following areas:
- policy;
- training;
- reporting channel; and
- consequences of non-compliance.
The Company will provide its employees and business associates with adequate training to ensure their thorough understanding
of the Company’s ABC position, especially in relation to their role within or outside the Company.
Advanced training should be provided to relevant higher risk staff and senior management in order to prepare and
support these employees in the discharge of their duties.
The Company is committed to train its Board of Directors, senior management, staff and business associates via appropriate
channels in relation to its ABC standards.
Responsibility for adherence to EIBABCS
Every employee is responsible for compliance with the Company’s ABC policy The responsibility to ensure the Company’s
adherence to relevant regulations and the Company’s ABC policy rests ultimately with the Board and CEO.
ABC Compliance responsibilities should be documented clearly in the official job description for all ABC roles, organisation
charts outlining the ABC function within the company structure as well as the relationship among the various ABC