1. Purpose
This Anti-Bribery and Corruption (ABC) Policy is a formal annex to the Corporate Code of Conduct and demonstrates Novum LS LLC's unwavering commitment to integrity, transparency, and compliance with all applicable anti-bribery and anti-corruption laws worldwide. The purpose of this policy is to ensure that bribery and corruption do not occur in any aspect of our operations.
2. Scope
This Policy applies globally to all employees, officers, directors, contractors, consultants, agents, joint venture partners, and any other third parties acting on behalf of Novum LS LLC and its subsidiaries. It covers all business dealings and transactions, regardless of country or industry.
3. Policy Statement
Novum LS LLC and its subsidiaries adopt a strict zero-tolerance approach to bribery and corruption. Any form of bribery—whether offered, given, received, or solicited—is strictly prohibited. We commit to upholding all relevant anti-corruption laws, including the UK Bribery Act 2010, the U.S. Foreign Corrupt Practices Act (FCPA), and other applicable international standards.
4. Definitions
- Bribery: Offering, promising, giving, or receiving anything of value to influence a decision improperly.
- Corruption: Abuse of entrusted power for private gain.
- Facilitation Payments: Small, unofficial payments made to expedite routine actions, strictly prohibited under this policy.
- Kickbacks: Any form of payment returned to someone as a reward for making a favorable decision.
- Gifts and Hospitality: Non-cash benefits including meals, entertainment, or other items of value.
5. Prohibited Conduct
Personnel must not:
- Offer, give, solicit, or accept bribes in any form.
- Make facilitation payments or unofficial payments to public officials.
- Ignore or fail to report any suspicious activity or potential breaches of this policy.
- Engage third parties to do anything that would be a breach of this policy if done by company personnel.
- Fail to perform adequate due diligence on third-party relationships.
6. Gifts and Hospitality
Gifts and hospitality must be reasonable, proportionate, and for legitimate business purposes. They must not influence, or be perceived to influence, business decisions. All such expenditures must be recorded accurately and approved in accordance with the internal procedures.
7. Political and Charitable Contributions
Novum LS LLC does not permit political donations. Charitable contributions must not be used as a subterfuge for bribery and require appropriate due diligence and documentation.
8. Third Parties and Due Diligence
Due diligence must be conducted before engaging any third party. Contracts must include ABC clauses, and third-party performance must be regularly monitored. High-risk relationships require enhanced due diligence.
9. Risk Assessment and Internal Controls
Novum LS LLC will periodically assess bribery and corruption risks and implement proportionate controls. This includes transaction monitoring, financial controls, and audits.
10. Reporting Violations and Whistleblowing
All personnel are encouraged to report suspected violations in good faith through secure and confidential reporting channels. The company strictly prohibits retaliation against whistleblowers.
11. Training and Communication
ABC training is mandatory for all employees and relevant third parties. This policy will be prominently communicated and integrated into onboarding and compliance programs.
12. Monitoring and Review
Novum LS LLC and its subsidiaries will regularly review this policy to ensure it remains effective and aligned with evolving legal and business requirements.
13. Responsibilities
Senior management, compliance officers, and business unit leaders are responsible for ensuring policy enforcement, fostering a culture of integrity, and taking prompt action against violations.