Anti-Corruption Policy and Standards

  1. Introduction

    Para Dive 98 Ltd (herein after referred to as the Company) is committed to maintaining high ethical standards and vigorously enforces the integrity of its business practices wherever it operates throughout the world. The company will not engage in bribery or corruption.

    The purpose of this document is to set out the firms policy in relation to bribery and corruption. The policy applies strictly to all employees, directors, agents, consultants, contractors and to any other people or bodies associated with the Company, within all regions, areas and functions.

    It is important that you read, understand and act in accordance with this policy.

  2. Scope

    This policy applies to all individuals working at all levels, including partners, consultants, employees (whether permanent, fixed-term or temporary), contractors, trainees, homeworkers or any other person associated with us, wherever located (collectively referred to as either workers or employees in this policy).

  3. Policy and Procedures

    General Prohibition

    All forms of bribery and corruption are prohibited. The Company 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. Any breach of this policy or local law could result in disciplinary action being taken and ultimately could result in dismissal.

    Bribes and Kickbacks

    The Company does not take part in acts of corruption, or pay bribes or receive kickbacks either directly or indirectly. The Company prohibits its employees from engaging in acts of corruption, and from paying bribes or kickbacks to, or accepting bribes or kickbacks from, public officials and private individuals such as the personnel of companies with which the company does business.

    Gifts, Hospitality and Expenses

    According to various worldwide anti-corruption laws, it is illegal to provide cash or anything else of value (like gifts, business meals or entertainment) to individuals to obtain or retain business, or to secure any improper advantage. These laws do not prohibit reasonable and customary business gifts, meals and entertainment.

    Lavish or unreasonable gifts or hospitality, whether these are given or received, are unacceptable as they can create the impression that we are trying to obtain or receive favorable business treatment by providing individuals with personal benefits. In addition, gifts and hospitality can themselves be a bribe. Make sure that all gifts and hospitality should be for a genuine purpose, reasonable, given in the ordinary course of business.

    Facilitation Payments

    The Company does not make, and will not accept, facilitation payments or kickbacks of any kind. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the compliance manager.

    All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by the Company.

    Personal conflicts of interest

    Company employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of the Company. This includes: acting on any client information gained through their employment with the Company for personal gain; passing such information to a third party; or acting in any way that could be construed as insider trading.

    Conflicts of interest can arise if individuals have a personal interest in business dealings involving the Company. Personal interest can be direct or indirect, and refers not only to personal interests but to those of family members and friends. If there is a potential for conflict, the interests of the Company must take priority. Employees must disclose any personal conflict of interest or perceived conflict to their line manager.

  4. Record-Keeping

    The Company keeps financial records and has appropriate internal controls in place which will evidence the business reason for making payments to third parties.

    All accounts, invoices and other documents and records relating to dealings with third parties, such as customers, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness.

  5. Authority and Responsibility

    • If in any doubt about the application of this policy refer to the General Manager.

    • Consult the General Manager in confidence if you suspect that a company employee is engaged in bribery, corruption, fraud or any other unacceptable or unethical conduct.

  6. Relevant Legislation

    All national laws related to bribery and corruption, especially such laws that are in place in jurisdictions where the Company has an office(s) or carries out its work, are of importance to the Company.

    In setting out the principles included in this policy particular attention has been paid to the requirements of the EU anti-corruption acts. Adherence to its requirements is mandatory for many of the Company clients and its requirements are fully adopted by the Company.

  7. Synopsis

    • You must ensure that you read, understand and comply with this policy at all times.

    • The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

    • You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

    • Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct.

    • We reserve our right to terminate our contractual relationship with other workers if they breach this policy.