BRIBERY AND CORRUPTION COMBATING POLICY

The Bribery and Corruption Combating Policy is established to articulate the anti-bribery and anti-corruption approaches of AFMPACK.

This Policy encompasses all levels of company executives and employees, including members of the Company’s Board of Directors, as well as companies and their employees from whom the Company purchases and sells goods and services, suppliers, consultants, lawyers, external auditors, and all individuals and organizations acting on behalf of the Company.

The Company complies with legal regulations related to bribery and corruption in all countries where it operates and is represented. The Company adopts a “zero tolerance” approach towards bribery and corruption and is committed to conducting its activities fairly, honestly, legally, and in accordance with ethical rules.

Under this Policy;

Bribery: An agreement made by a person with another person to act contrary to the requirements of his/her duty in exchange for providing, offering, or promising direct or indirect benefits to expedite, delay, perform, or abstain from an action related to his/her duty.

Bribery and corruption can take many forms, including:

  • Cash payments,
  • Political or other donations,
  • Commissions, gifts, hospitality,
  • Social benefits, etc.

Corruption: The misuse of an assigned duty or authority for personal gain, either directly or indirectly.

Bribery and Corruption can be carried out in various ways, including cash payments, political or other donations, commissions, social benefits, gifts, hospitality, employment privileges, or other advantages to the individual, their family, acquaintances, and/or other third parties indicated by them.

AFMPACK employees:

  • Cannot seek or offer material benefit under the name of commission or any other title while performing their duties.
  • Cannot make any direct or indirect offers of advantage to public or private individuals or organizations, unrelated to business, nor enter into verbal or written agreements.
  • Cannot create advantageous situations in exchange for privilege in their relations with third parties and institutions, nor accept such offers.
  • Exercise utmost care to ensure that even their actions with different intentions do not give rise to suspicion or the impression of bribery and corruption.

Compliance with the principles of the Policy and relevant legal regulations is mandatory for Business Partners.

The implementation and updating of the Policy are the responsibility of the Board of Directors. In this context, the Board of Directors:

  • Establishes and develops necessary control mechanisms to prevent bribery and corruption.
  • Ensures the establishment of communication channels for reporting non-compliant behaviors, takes measures to protect the confidentiality and security of those reporting.
  • Ensures necessary investigations and inquiries are conducted on complaints, reports, and allegations received.
  • Ensures audits are conducted to ensure compliance with the Policy and corrective measures are taken.

The Board is responsible for determining and operating notification, investigation, and sanction mechanisms in cases of non-compliance with policies, rules, and regulations.

All stakeholders encountering violations related to this Policy should report the violations to the AFMPACK Ethics Reporting channel, accessible at info@afmpack.com. All reports are kept confidential. Confidentiality rules are observed during the investigation, inquiry, and reporting processes of the notifications. Necessary sanctions are applied according to the nature of the case upon the conclusion of the investigation and evaluation. Those who refrain from reporting violations related to this Policy may be subjected to disciplinary penalties, including termination of the employment contract.

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