THIRD PARTIES
AC.3.a. Agents and other associates
Does the company's anti-corruption initiative cover agents, intermediaries and consultants? (Principle 10)
ABOUT THIS QUESTION
Using agents, intermediaries, consultants or other external service providers does not free the company of its responsibility of implementing its anti-corruption initiatives. Following international law and other anti-bribery legislation, the criminal offence of bribery occurs when a financial benefit or other advantage is offered, promised or given to a public official directly or through agents, intermediaries or consultants. Information, training and monitoring of agents, intermediaries or consultants' activities should be carried out on a continuous basis with a clear line of responsibility within the company.
The measures taken by the company should be in accordance with national regulatory requirements, international conventions, agreements, the precautionary approach and best practice. Please see for example: Convention on combating bribery of foreign public officials in international business transactions. OECD; Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations; Business Principles for Countering Bribery. Transparency International; Partnering Against Corruption - Principles for countering Bribery. Partnering Against Corruption Initiative (PACI), World Economic Forum.
ANSWER THIS QUESTION
First answer the following indicators (step 1) and then the main question (step 2).
Step 1. Answer the following indicators:
The company conducts an inquiry an/or attentiveness (e.g. financial, legal, labour, tax, IT, environment, market/commercial) on all agents, intermediaries and consultants.
- AC.3.A.1.
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All agreements with agents, intermediaries and consultants are fully documented in written, signed contracts.
- AC.3.A.2.
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The selection and terms of reference of agents, intermediaries or consultants are approved at the senior management level or at a level above that of the management involved in the operations for which the intermediary is hired.
- AC.3.A.3.
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Contracts with agents, intermediaries and consultants include a section on anti-corruption and that the contract-holder must comply with all applicable laws and regulations.
- AC.3.A.4.
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Agents, intermediaries and consultants are provided with information on the company's anti-corruption commitment, anti-corruption policies, training material on anti-corrupt behavior and information on disciplinary procedures for violations of company anti-corruption policies.
- AC.3.A.5.
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The company ensures that payment to agents, intermediaries and consultants are in line with standard payments for other service providers of similar ranking.
- AC.3.A.6.
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The company only makes payments by bank transfer or check-never in cash-in the country of the agent, intermediary and consultant and never to a third party without prior examination.
- AC.3.A.7.
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Step 2. Answer the main question:
Does the company's anti-corruption initiative cover agents, intermediaries and consultants?
- AC.3.A.
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AC.3.b. Supply chain
Does the company promote its anti-corruption commitment in its interactions with suppliers and business partners? (Principle 10)
ABOUT THIS QUESTION
Anti-corruption values in suppliers, contractors and other business partners are outside the company's immediate sphere of control. However, the company should still apply attentiveness and ensure that all reasonable measures are undertaken to improve and promote anti-corruption and avoid neglect.
The measures taken by the company should be in accordance with national regulatory requirements, international conventions, agreements, the precautionary approach and best practice. Please see for example: Convention on combating bribery of foreign public officials in international business transactions. OECD; Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations; Business Principles for Countering Bribery. Transparency International; Partnering Against Corruption - Principles for countering Bribery. Partnering Against Corruption Initiative (PACI), World Economic Forum; ICC guidelines on Whistleblowing.
ANSWER THIS QUESTION
First answer the following indicators (step 1) and then the main question (step 2).
Step 1. Answer the following indicators:
The company informs all suppliers, contractors and other business partners of it anti-corruption commitment and asks all suppliers, contractors and business partners to comply with this commitment.
- AC.3.B.1.
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The anti-corruption commitment is supported by anti-corruption training of relevant internal staff employed by suppliers, contractors and other business partners.
- AC.3.B.2.
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Where necessary, the company collaborates with individual suppliers to implement continuous improvements of anti-corruption.
- AC.3.B.3.
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The company's procurement practices including prices, delivery times, internal incentive structures and other relevant criteria, support anti-corruption commitment in suppliers and business partners.
- AC.3.B.4.
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The company has and promotes a function by which suppliers, contractors and other business partners can safely report suspicion of corruption-related cases (e.g. hotline or mailbox) and allocates resources to address the issues that are identified.
- AC.3.B.5.
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Step 2. Answer the main question:
Does the company promote its anti-corruption commitment in its interactions with suppliers and business partners?
- AC.3.B.
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TO ANSWER THE QUESTIONS
1. Select a question
2. Click "Answer this question"
3. Answer the indicators
4. Answer the main question
ANSWER CATEGORIES
Yes/No
-if you agree or disagree
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N/A (not applicable)- if it's not relevant to your business
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