Anti-Corruption and Fair Trade Policy

Business Partner Anti-Corruption Policy

This policy applies to third-party Business Partners doing business with or on behalf of Infiana.

 

Infiana’s Anti-Corruption and Fair Competition Policy Statement.

Because Infiana does business internationally, Infiana and its business partners have to comply with national and international laws and conventions.  

 

Clear rules, clean business:

Infiana competes fairly for orders with the quality and the price of its innovative products and services, not by offering improper benefits to others.

Likewise, Infiana expects its business partners to comply with all applicable anti-corruption laws and regulations.

This is why Infiana strictly prohibits its business partners from directly or indirectly offering, promising, granting or authorizing the giving of money or anything else of value to a government official or to a counterparty in the private sector to influence official action or obtain an improper advantage for Infiana.

Any offer, promise, grant or gift made by a business partner in connection with Infiana business must comply with applicable laws and Infiana policies, and must not create an appearance of bad faith or impropriety.

This means that no such offer, promise, grant or gift may be made if it could reasonably be understood as an effort to improperly influence a government official or as a bribe to a commercial counterparty to grant a business advantage.

The term "government official" must be understood broadly to include officials or employees of any government or other public body, agency or legal entity at any level, including officers or employees of state-owned enterprises and public international organizations.

It also includes candidates for political office, political party officials and employees as well as political parties.

Fair competition is also protected by antitrust law in many countries. Antitrust law prohibits agreements between companies that restrict competition, e.g. price fixing, market or customer allocation, market sharing or bid rigging with competitors, or the abuse of a dominant position in the market.

Infiana has a strict policy to act in compliance with antitrust law and expects its business partners (hereafter "Business Partners") to do the same.

This policy applies to Infiana Group GmbH of Forchheim, Germany, and all of its worldwide subsidiaries, affiliates, directors, employees and Business Partners.

 

Your responsibilities and confirmation in writing as an Infiana Business Partner.

As an Infiana Business Partner, you represent and agree to the following:

1. Improper Payments. You will not promise, offer, give, authorize, request, agree to receive or receive “anything of value” (defined below), directly or indirectly, to or from anyone, including any Public Official or an employee of a commercial enterprise, to improperly influence the behavior of such person as to obtain or retain business or secure an improper advantage (e.g., obtaining a contract, getting taxes reduced, laws changed, imports cleared, telephone/electricity connected, or permits obtained to conduct business).

2. Facilitation Payments. You will not make facilitation payments on behalf of Infiana to secure or expedite routine government actions by Public Officials.

3. Gifts and Hospitality. You will not promise, offer, give, authorize, request, agree to receive or receive any gifts or hospitality to or from Public Officials anywhere in the world. You may promise, offer, give, authorize, agree to receive or receive gifts or hospitality to or from a person who is not a Public Official only if the following requirements are met:

a. It is not in the form of cash;
b. It is not requested by the recipient or by a third party on behalf of the recipient;
c. it complies with local law;
d. it complies with the Infiana rules and policies on gifts and hospitality of the recipient’s organization;
e. it is authorized by Infiana; and
f. it complies with the other provisions of this Business Partner Anti-Corruption Policy.

Gifts or hospitality to or from a relative, friend, acquaintance, charity, political party or other organization designated by a person with whom you have a business relationship are considered gifts or hospitality given or received directly to or by the person with whom that business relationship exists.

4. Books & Records. You will keep books, records and accounts that accurately and fairly reflect the disposition of Infiana’s assets and all transactions that you conduct on behalf of Infiana.

5. No Affiliation with Public Officials. You are not a Public Official, and no officer, director, employee or agent of your business is a Public Official.


Definitions

“Anything of value” covers just about any form of benefit, which includes, but is not limited to, money, gifts, hospitality, entertainment, promotional expenditures, expenses, services or personal favors, loans, employment offers or promises of future employment, or political or charitable contributions.

“Public Official” is a broad term which includes:

1. An employee, officer, official of, or consultant to:

a. A government at national, state, regional, provincial or local level;
b. A government agency, public authority or other public body;
c. A state-owned or state-controlled enterprise;
d. Groups with special status such as Native American tribes or nations in the US; or
e. An international public organization (e.g, the United Nations or the European Union), and their agencies and other related bodies; or

2. A politician at any level of government, whether they hold political office or not, political candidates, political parties and anyone working for them; or

3. Members of royal or other ruling families.

 

Termination

Failure to follow this Policy can result in termination of your business relationship with Infiana. Doing business with the Infiana Group means that you accept and underwrite these principles.

To report violations of our Anti-Corruption Policy, please refer to Infiana’s Ethics and Compliance Hotline.

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