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Anti-Corruption Policy

At the Religious Freedom & Business Foundation (RFBF), the way we do things is just as important as what we do. We want to create a workplace where each employee achieves the highest business and personal standards, and where everyone feels proud of our Foundation and the job which he or she does.

RFBF is a team with core values: Accountable, Service Focused and Team Driven. These values guide how we work every day. We bring these values to life in the way we perform, giving our best effort every day, being accountable for what we do, delivering on our commitments to each other and to our collaborators, setting objectives, meeting our goals, and working together to achieve business results. A core objective of our Foundation is creating a successful and inclusive culture that drives results.

By working as an employee at RFBF, you are representing the Foundation to our collaborators and everyone else you come into contact with. As laid out in our Code of Business Conduct (COBC) you are expected to adopt the highest standards of professional and personal behavior and demonstrate Respect, Integrity, Good judgment, Honesty and Trust, the RIGHT Way, in all your actions, no matter what the circumstances.

One of the guiding principles of the COBC is ‘complying with anti-corruptions laws’. The Anti-Corruption Policy extends on this principle, and is applicable to all employees and everyone we do business with, including agents, representatives, consultants, independent contractors and anyone acting on behalf of RFBF.

If you have any questions regarding RFBF’s Anti-corruption Policy, please contact your supervisor.

Purpose of the Anti-Corruption Policy

Bribe: Anything of value given in an attempt to affect a person’s actions or decisions in order or to gain or retain a business advantage. Anything of value includes cash, entertainment or other gifts or courtesies.

Corruption: The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.

Facilitation payments: Small sums paid to government officials to facilitate or expedite routing. Non-discretionary government actions are considered facilitation payment.

Kickbacks: The return of a sum already paid or due as a reward for awarding of furthering business.

What Does ‘Anti-Corruption’ Mean to You?

Corruption can take place in many types of activities. It usually is designed to obtain financial benefits or other personal gain. For example, bribes are intended to influence behavior – they could be in the form of money, a privilege, an object of value, an advantage, or merely a promise to influence a person in an official or public capacity. Usually, two people are involved and both will benefit. Examples of a bribe include:

  • » Offer or receipt of cash in the form of a kickback, loan, fee or reward
  • » Giving of aid, donations or voting designed to exert improper influence

 

The areas of business where corruption, including bribery, can most often occur include:

  • Gifts, Entertainment and Hospitality
  • Facilitation Payments
  • Procurement Process
  • Political, Community and Charitable Contributions

1. Gifts, Entertainment and Hospitality

Gifts, entertainment and hospitality are acceptable if they are reasonable, proportionate and made in good faith and in compliance with our Foundation policies. These activities must be in compliance with our Code of Business Conduct (guiding principle: ‘avoiding conflicts of interest’), RFBF’s Collaborator Entertainment Policy and Corporate Hospitality Guidelines. Although no two situations are the same, the Corporate Hospitality Guidelines define what is usually acceptable and what is never acceptable.

Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and occurrence.

How do you know if an offered gift, entertainment or hospitality by RFBF or to RFBF is acceptable? First, take a step back and ask yourself the following:

  • » What is the intent – is it to build a relationship or is it something else?
  • » How would it look if these details were on the front of a newspaper?
  • » What if the situation were reversed – would there be a double standard?

 

If you find it difficult to provide a comfortable answer to one of the above questions, ASK your manager, local Legal Department or the Ethics and Compliance Office.

What to do when you doubt if you can accept? If you are unsure if you should accept something of value – ASK. Ask your manager. If your manager is participating, seek a higher-level manager. If you prefer, ask your local Legal Department or contact the Ethics and Compliance Office.

As a general rule, RFBF employees and business partners should not provide gifts or hospitality to, or receive them from, a government or other public official (or their close families and business associates). You may give a modest gift to these parties when appropriate and allowed by local law provided you discussed it with and received written approval in advance from your supervisor.

2. Facilitation Payments

Facilitation payments are not allowed. If you are unsure whether certain payments represent facilitation payments, please contact your supervisor.

3. Procurement Process

You must follow RFBF processes and adhere to the system of internal controls around Collaborator selection. Collaborator selection should never be based on receipt of a gift, hospitality or payment. When Collaborator selection is a formal, structured invitation for the supply of products or services (often called a ‘tender’), it is most important we maintain documentation supporting our internal controls. In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption.

A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality.

4. Political Community and Charitable Contributions

You are not allowed to make political contributions from Foundation funds without authorization. Importantly, RFBF is not permitted to make political contributions.

Bribery is a criminal offense. As an employee you will be accountable whether you pay a bribe yourself or whether you authorize, assist, or conspire with someone else to violate an anti-corruption or anti-bribery law. Punishment for violating the law are against you as an individual and may include imprisonment, probation, mandated community service and significant monetary fines which will not be paid by RFBF.

Questions or How to Raise a Concern

If you want to ask a question about the requirements in this policy or are concerned that an anti-corruption violation is occurring or has occurred, report it immediately to your supervisor or directly to the Foundation’s President.

In the US you are required by law to report any suspected violation and failing to do so is itself a breach of our COBC.

The Religious Freedom & Business Foundation also has the following policies.

Whistleblowing — An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. RFBF has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor

Equal opportunities — Discrimination against employees and applicants due to race, color, religion, sex (including sexual harassment), national origin, disability, age (40 years or older), military and veteran status is prohibited. Violations of this policy will be subject to discipline, up to and including termination.

Health and safety — The safety and health of our employees is RFBF’s most important business consideration. No employee will be required to do a job that they consider unsafe. We enforce company safety and health rules and require employees to follow the rules as a condition of employment.

Security Risk management — It is the policy of RFBF to achieve best practice in the management of all risks that threaten to adversely impact the Foundation, its customers, people, assets, functions, objectives, operations or members of the public. Risk Management will form part of strategic, operational and line management responsibilities and be integrated into the strategic and business planning processes. In respect of a special risk responsibility may be assigned to a nominated officer of RFBF, or a committee chairman, as determined by need.

Conflict of interest — RFBF has an annual conflict of interest policy and a conflict of interest review for officers and board.

Money laundering or Funding terrorist organizations — It is the policy of RFBF to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.