M&O Partners’ rules of business conduct include doing business with integrity, which means avoiding any type of corruption. Our anti-corruption policy prohibits bribery and other corrupt conduct in any form involving government officials, customers, suppliers and others counterparties in the commercial marketplace.
In no business situation it is allowed to offer, promise or give a financial or other advantage to another person intending to reward a person for the improper performance of a function or activity. We are complying with the anti-corruption laws of every country in which we operate.
- Companies and Persons Covered by This Policy
M&O Partners’ ABC Policy applies to:
- All employees, officers, and directors at M&O Partners and all of its affiliates worldwide; as well as
- Any third party intermediaries/representatives such as agents, resellers, regulatory consultants, or anyone else expected to represent M&O Partners before customers or Government Officials.
- Applicable Legislation
M&O Partners is subject to ABC laws in countries in which it operates directly or through third party intermediaries, including, but not limited to, the Norwegian Criminal Code, the US Foreign Corruption Practices Act, and Anti Bribery laws of country(-ies) of main operations. ABC laws include those adopted by other countries to implement the Organization for Economic Cooperation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
M&O Partners prohibits bribery in any form, direct or indirect. A bribe is not defined by a specific amount of money or gifts changing hands. A bribe may include any offering, giving, or receiving, of payments, lavish or excessive entertaining, favors, gifts, other inducements, or anything else of value in order to gain an unfair business advantage.
- Prohibited Activities
No M&O Partners officer, director, employee, agent, intermediary, or other representative worldwide may, directly or indirectly, offer, promise, pay, give, or authorize any financial or other advantage, or anything else of value, to any other person or organization, with the intent to exert improper influence over the recipient, induce the recipient to violate his or her duties, secure an improper advantage for M&O Partners or its members, or improperly reward the recipient for past conduct.
This prohibition applies with special force to benefits provided to Government Officials. M&O Partners personnel and representatives who interact with Government Officials must ensure that any benefit conveyed to a Government Official complies with all applicable laws and regulations, with the internal rules of the recipient’s organization, and with the policies and procedures in this Policy.
Note that employees/consultants of state, or partially state owned, companies, including national oil and energy companies, are considered Government Officials.
M&O Partners and its employees and intermediaries/representatives can be held liable both civilly and criminally for bribery and other corrupt conduct. Violations of anti-corruption laws can give rise to substantial fines and/or imprisonment.
- Payment of Travel and Accommodation to Third Parties
Travel and accommodation cannot be provided to third parties in order to improperly affect or influence the outcome of a business transaction or regulatory decision. Travel expenses for a customer, Government Official, or any other third party may only be paid if the trip has a clear and legitimate business purpose, costs are reasonable, transparency exists between the persons who are traveling and their employer exists. Time spent on non-business activities (such as sightseeing) should not exceed the time spent on business activities. The purpose of the travel should always be with a focus on business activities, and non-business activities should always be kept to a minimum level.
- Gifts, Hospitality and Entertainment
Gifts, hospitality, and entertainment are limited to reasonable and bona fide expenses that have a legitimate business purpose. They cannot under any circumstances be provided in order to improperly affect or influence the outcome of a business transaction.
- “Facilitating” Payments
A “facilitating” payment is a small payment that is designed to secure or expedite a routine government action by a government official. Examples include processing a visa, providing police protection, or securing mail pick-up or delivery. Facilitating payments are prohibited, even if considered legal or customary in the country where business is done. However, if you believe that the safety or health of you or another individual are in jeopardy then a payment to protect safety or health would not be considered a breach of this policy. The M&O Partners CEO or CFO must be notified promptly if this situation occurs, and payments must be accurately documented as such on expenses or bookkeeping records.
- Reporting of Unethical and Illegal Activities
Employees and third parties are required to report directly to M&O Partners’ Global CFO and CEO any unethical or illegal activity that they witness or are made aware of. All allegations will be investigated. If employees and third parties prefer to remain anonymous they may, but it is important that all information regarding the actual events and details of incidents be provided so that a thorough investigation may be completed.
- Whistleblower Protection
No retaliation against individuals who come forward in good faith with allegations or information of wrongdoing will be tolerated by the management or Board of Directors of M&O Partners.
- Record Keeping
All payments made in connection with the business activities of M&O Partners must be accurately recorded in the books of the paying organization, and accurate records regarding the payment must be maintained.