Esmeran Company for Bitumen and Petroleum Derivatives is committed to managing all its affairs with utmost integrity and full compliance with applicable laws and regulations, including those related to anti-bribery and corruption. This policy outlines the principles and guidelines that govern our commitment to preventing bribery and corruption in all aspects of our operations.
This policy applies to all employees, contractors, agents, and any individuals or entities acting on behalf of the company, and covers all company operations.
The Anti-Bribery and Corruption Policy is continuously monitored and reviewed to ensure its effectiveness through regular audits to assess compliance.
This policy is communicated to all employees, contractors, agents, and concerned parties and made accessible via the company’s website or other relevant communication platforms.
Any employee who violates this policy will be subject to disciplinary actions up to dismissal from work, and any suspected cases of bribery or corruption will be reported to the competent authorities.
The company applies a zero-tolerance policy towards corruption and abuse of influence and prohibits all forms, especially the payment of bribes. It commits to full compliance with ethical and professional standards.
Regarding gifts and invitations, they must be of reasonable value, occasional, and on special occasions. Offering or accepting gifts or invitations that may influence one’s impartiality is prohibited.
Each gift or invitation must be assessed based on:
All employees must adhere to the policy to ensure daily operations are conducted with honesty and integrity. The Code of Professional and Ethical Conduct is an additional reference.
Providing donations that may be considered as a means to gain advantages or contracts, or fund political parties, elected officials, or election candidates in a professional context.
Funding individuals or institutions that may harm the reputation, interests, or image of the company, or whose board members or managers are unknown.
Funding organizations that directly or indirectly benefit public officials or their relatives, especially when related to company activities.
Requesting or accepting any kind of benefit from a person executing a collaborative project in exchange for the company’s financial support of that project.
Providing charitable contributions to private companies or legal entities at the request of a local elected official or equivalent.
Commitment not to resort to bribery of any individual or entity, or to request, offer, or accept it, whether directly or indirectly, such as bribes offered by intermediaries of other parties.
Giving bribes is strictly prohibited under all circumstances, and dealing with government officials presents an increased risk.
Government officials include individuals in any government or regulatory agency position.
Employees in public bodies, international or non-governmental organizations.
Politicians, political candidates, or employees of any political party.
Using an unreliable commercial intermediary not monitored according to company procedures.
Requesting or accepting any benefit from a supplier in exchange for directing procurement procedures or splitting contracts.
Requesting or accepting a benefit for employing a relative of a public official.
Requesting or accepting a bribe from a supplier during procurement, such as overbilling or fictitious services.
Requesting or accepting a benefit to waive or settle claims illegally.
All types of facilitation payments are prohibited, even if commonly practiced in some countries, and must be reported.
All gifts, hospitality, and charitable donations must align with the company's policies and approved local annexes.
Use of company funds for political contributions is prohibited unless with prior written authorization from the competent authorities.
Bribery and corruption risks must be assessed and reviewed through approved procedures, and specialists must be informed.
Any conduct implicating the company in corruption or bribery must be reported immediately.
Report to the legal affairs or ethics and compliance team when red flags are present in current or future third-party relationships.
Non-compliance with this policy is a disciplinary offense warranting dismissal and may constitute a criminal offense.
Any suspicious inquiries should be reported through:
The Executive Director or Human Resources Manager.
Members of the legal affairs or compliance team.
Anonymous email.
The third party refuses to provide information or provides false information.
Raises concerns about compliance or conceals information.
Complex ownership structure or links to sanctioned entities or governments.
Requests for cash payments or payments via a third party without commercial justification.
Requests to modify invoices or contract terms, or submits inflated invoices.
Conducts suspicious money transfers or without clear reasons.
Repeatedly refuses visits, installation services, or disclosing product usage.