This policy supplements Section 3.1 of the Saporina Code of Business Conduct. Both documents should be read together.
1. Purpose and Commitment
Saporina has earned its reputation through the quality of our products, not through illicit favors. We have a zero-tolerance approach to bribery and corruption. This means we do not pay bribes, nor do we accept them, regardless of the business stakes.
This policy outlines the standards required to ensure Saporina complies with all applicable anti-bribery laws and maintains the trust of our customers and partners.
2. Scope
This policy applies to:
Saporina Team
All employees, officers, and directors of Saporina.
Our Network
Any third party acting on our behalf or authorized to manufacture our products. This includes our manufacturing network, agents, distributors, and logistics providers.
3. Key Prohibitions
3.1 Bribery
You must never offer, promise, give, request, agree to receive, or accept anything of value to improperly influence a decision or gain a business advantage.
The Rule
If it feels like you are "buying" a favor, don't do it.
3.2 Facilitation Payments
"Facilitation payments" (small payments to public officials to speed up routine actions like customs clearance or permit issuance) are strictly prohibited, even if they are considered "common practice" in a specific country.
Safety Exception
If your safety or physical security is threatened, pay the demand and report it to the Saporina Compliance Committee immediately.
Your personal safety always takes priority. No disciplinary action will be taken against you in this circumstance.
3.3 Kickbacks
We do not accept "kickbacks" or secret commissions from suppliers or partners in exchange for allocating production volume to them.
4. Gifts and Hospitality
We recognize that business gifts and hospitality are normal parts of building relationships. However, they must never be used to exert improper influence.
4.1 Acceptable Gifts
Gifts and hospitality are permitted only if they meet all the following criteria:
Reasonable Value
Modest and appropriate for the occasion.
Transparent
Given openly, not in secret.
No Quid Pro Quo
Not given with the expectation of a specific favor in return (e.g., signing a contract).
Legal
Permitted under local law.
4.2 Strictly Prohibited
Cash or Cash Equivalents
You must never give or accept cash, gift cards, or loans.
During Negotiations
No gifts or hospitality should be exchanged during a tender process or contract negotiation.
Indecent or Inappropriate
Anything that would embarrass Saporina if published on the front page of a newspaper.
5. Managing Our Manufacturing Network
Saporina operates through a strategic network of authorized partners. We rely on them, but we must also verify them.
5.1 Due Diligence
Before engaging a new partner, distributor, or agent, Saporina must conduct risk-based due diligence. We must understand:
- Who owns the company?
- Do they have a reputation for integrity?
- Do they have connections to government officials?
5.2 "We Don't Outsource Liability"
You cannot use a third party to do what you cannot ethically do yourself.
Example
You cannot tell a customs broker, "Get this shipment cleared by any means necessary," if you know or suspect they will use a bribe to achieve it.
Your Duty
If you suspect a partner in our network is engaging in bribery, you must report it immediately and halt business transactions until investigated.
6. Record Keeping
We must keep financial records that accurately and fairly reflect our transactions.
No "Off-the-Books" Accounts
All payments must be recorded accurately.
Accurate Descriptions
You must never hide a bribe or improper gift under a vague expense category like "marketing," "miscellaneous," or "consulting fees."
7. Reporting and Consequences
7.1 How to Report
If you are asked for a bribe, or if you suspect corruption within our operations or our manufacturing network, you must report it via:
Reporting Channels
Your Direct Manager
For initial concerns, suspected red flags, or situations where you need immediate guidance on how to proceed.
Legal Department
For matters involving government officials, regulatory exposure, cross-border transactions, or situations where legal counsel is needed before acting.
Saporina Ethics & Compliance Channel
Anonymous and confidential. Available 24/7. Use this channel if you are unable or uncomfortable reporting through the other channels.
ethics@saporina.com
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+1 (000) 000-0000
7.2 Zero Retaliation
Saporina will protect anyone who reports a concern in good faith. Retaliation against a reporter—including demotion, exclusion, harassment, or termination—is grounds for immediate dismissal of the retaliator, regardless of their seniority. This protection extends to employees of our manufacturing and distribution partners.
7.3 Consequences
For Employees
Violation of this policy will result in disciplinary action, up to and including termination.
For Partners
Bribery by a partner or supplier is grounds for immediate termination of the business relationship and legal action.