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ANTI BRIBERY AND ANTI CORRUPTION POLICY

Policy Statement

This Policy is intended to assist everyone in conducting our business legally, ethically and with integrity. It is not meant to stop legitimate business activities so long as those activities comply with the law and with the Company’s internal policies.

The purpose of this policy is to:

(a) set out our responsibilities in observing and upholding our position on bribery and corruption

(b) provide information and guidance on how to recognize and deal with bribery and corruption

issues.

Who is Covered by the Policy?

This policy applies to all individuals working at all levels and grades whether permanent, fixed-term or temporary.

In this policy, third party means any individual or organization you come into contact with during the course of your work, and includes actual and potential clients, customers, suppliers, agents and government and public bodies.

What Is Bribery?
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action. It is illegal, and it is a breach of trust.
A bribe is an inducement or reward offered, promised or provided in order to gain a commercial, contractual, regulatory or personal advantage.

We Will Not Tolerate Bribery
Corruption, bribery or attempted bribery is unacceptable. This applies whether offering a bribe, or accepting a bribe. It is against FIDI’s core values of conducting business to the highest legal, moral and ethical standards.
Bribery and corruption are covered by various international laws and statutes. These laws often require companies, including FIDI Affiliates, to have rigorous, pro-active measures in place to detect and prevent corrupt practices.

Charter Statement
Undertaking by all FIDI Affiliates with immediate effect
All FIDI Affiliates commit to legal and ethical behavior, and to refrain from doing anything that will harm the interests of FIDI, other affiliates, clients, or the industry. FIDI and its Affiliates will take steps to ensure they are fully informed of applicable regulations and will monitor their employees and business partners to ensure full and continual compliance.

Legal Compliance
FIDI Affiliates will ensure that they are aware of all applicable laws countering bribery and corruption in all the jurisdictions in which they operate, and that they will obey and uphold those laws.
The laws that apply to particular international business activities include those of the countries in which the activities occur as well as others that - like the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010 - govern the international operations of national companies and citizens in respect of their conduct both at home and abroad.
We, as a FIDI affiliated company, have to ensure that we are aware of, and are complying with, applicable laws.

Ethical Behavior
As a demonstration of its commitment, FIDI and its Affiliates pledge to take a zero- tolerance approach to bribery and corruption. At all times, FIDI and its Affiliates will act professionally, fairly and with the utmost integrity in all business dealings and relationships. This will apply wherever they operate.

Commitment to the Values of FIDI
This Charter will be formally integrated into the FAIM quality standard.

Code of Conduct
By agreeing and committing to this Charter, each FIDI Affiliate undertakes to:
1. Never engage in any form of bribery, either directly or through any third party.
2. Never offer or make an improper payment, or authorize an improper payment (cash or otherwise) to any individual, including any local or foreign official anywhere in the world.
3. Never attempt to induce an individual, or a local or foreign official to act illegally or improperly.
4. Never offer, or accept, money or anything of value, such as gifts, kickbacks or commissions, in connection with the procurement of business or the award of a contract.
5. Never offer or give any gift or token of hospitality to any public employee or government official or representative if there is any expectation or implication for a return favor
6. Never accept any gift from any business partner if there is any suggestion that a return favor will be expected or implied.
7. Never facilitate payments to obtain a level of service which one would not normally be entitled to.
8. Never disregard or fail to report any indication of improper payments to the appropriate authorities.
9. Never induce or assist another individual to break any applicable law or regulation
Content Ownership

All information made available on this Web site is property of S&M Moving Systems and its affiliates, and may not be disclosed, disseminated, or distributed to any unauthorized party.

Charter Changes

S&M Moving Systems reserves the right to add, modify, or remove portions of this policy at any time. It is recommended that you check back frequently.

Other Terms and Conditions

To have information corrected, and/or to address concerns over misuse of data please contact us at:

1-800-234-7554

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