Anti-Bribery Policy for CxO Coaching
Purpose: At CxO Coaching, we are committed to conducting our business affairs with the highest level of integrity, transparency, and ethical standards. This Anti-Bribery Policy outlines our zero-tolerance approach towards bribery, corruption, and unethical practices. The policy applies to all employees, contractors, agents, and representatives associated with CxO Coaching.
Compliance with Anti-Bribery Laws: CxO Coaching is committed to complying with all applicable anti-bribery laws, including but not limited to the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act. All individuals associated with CxO Coaching are required to adhere to these laws, regardless of their location or the jurisdiction in which they operate.
Prohibited Conduct: a. Bribery: CxO Coaching strictly prohibits offering, promising, giving, requesting, or accepting bribes, kickbacks, or any improper payments, whether directly or indirectly, to or from any individual, including public officials, business partners, clients, or suppliers. b. Facilitation Payments: CxO Coaching prohibits facilitation payments, which are small payments made to expedite routine actions or services to which the company is already entitled. c. Gifts and Hospitality: While CxO Coaching acknowledges the importance of building and maintaining business relationships, gifts, hospitality, or other benefits should never be used to influence or obtain an unfair advantage. All gifts, hospitality, or entertainment offered or received must be reasonable, proportionate, transparent, and in compliance with applicable laws and regulations. d. Conflicts of Interest: Individuals associated with CxO Coaching must avoid situations that could lead to a conflict of interest or compromise their judgment. Any actual or potential conflicts of interest must be disclosed promptly.
Due Diligence: CxO Coaching is committed to conducting thorough due diligence on its business partners, including clients, suppliers, agents, and intermediaries. The company will assess the reputation, integrity, and anti-bribery practices of its partners before entering into any business relationship.
Reporting and Whistleblowing: a. Reporting: Any individual associated with CxO Coaching who becomes aware of or suspects a violation of this policy must report it immediately to their supervisor, the Compliance Officer, or through the designated reporting channels. b. Whistleblowing: CxO Coaching encourages individuals to report any concerns or suspicions of bribery or corruption through its anonymous whistleblower hotline or other available channels. The company is committed to protecting whistleblowers from retaliation and ensuring their confidentiality.
Training and Communication: CxO Coaching will provide training and awareness programs to all employees, contractors, agents, and representatives to ensure their understanding of this policy, anti-bribery laws, and the potential risks associated with bribery and corruption. The policy will be communicated to all relevant stakeholders and made readily available to the public through the company's website.
Compliance Monitoring and Enforcement: CxO Coaching will implement regular monitoring, and review processes to ensure compliance with this policy. Any violations will be subject to appropriate disciplinary action, which may include termination of employment or contractual relationship, as well as legal proceedings if necessary.
Continuous Improvement CxO Coaching is committed to continuously reviewing and improving its anti-bribery practices to ensure effectiveness and alignment with evolving legal and regulatory requirements.
This Anti-Bribery Policy is binding on all individuals associated with CxO Coaching and supplements any other relevant policies or codes of conduct in place. Failure to comply with this policy may result in disciplinary action, legal consequences, and damage to the company's reputation.