Interactive Paper GmbH is committed to conducting business in accordance with the highest ethical standards and applicable laws. This policy outlines our approach to preventing bribery and corruption within our organization and in our dealings with third parties.
Scope
This policy applies to all employees, contractors, agents, and third-party vendors who work with or provide services to Interactive Paper GmbH.
Message of Zero Tolerance
Interactive Paper GmbH strictly prohibits any form of bribery or corruption, including facilitation payments. We expect all employees, contractors, agents, and third-party vendors to adhere to this policy and refrain from engaging in any activity that could compromise our integrity or reputation.
Prohibition of Facilitation Payments
Facilitation payments are small payments made to government officials or other individuals to expedite routine administrative tasks or secure minor favors. These payments are illegal under the Foreign Corrupt Practices Act (FCPA) and are strictly prohibited under this policy.
Integration with Compliance Program
Interactive Paper GmbH has established a comprehensive Compliance program that includes policies, procedures, and controls aimed at preventing bribery and corruption. This policy is an integral part of our Compliance program and is reviewed and updated regularly to ensure its continued relevance and effectiveness.
Existence and Training on Speak-Up Line
Interactive Paper GmbH maintains a confidential Speak-up line that allows employees to report any concerns or suspected misconduct without fear of retaliation. All employees are required to participate in training sessions that explain the purpose and proper use of the Speak-up line.
Assessed for Effectiveness
The effectiveness of this policy is regularly assessed through internal audits, compliance reviews, and employee surveys. Any issues identified through these assessments are addressed promptly, and corrective actions are taken to improve the policy's effectiveness.
Tracking and Documentation:
.1Details of any payments made by the Third Party and any expenses incurred.
.2Description of any concerns, issues, solicitation, etc. arising out of the relevant period.
.3A log of all interactions and transactions (of any value/no value) with Government Officials (GOs) (including hospitality) and all other relevant details (such as name/titles of GOs, dates and rationale for meeting, etc.).
Evidence of Compliance
To demonstrate compliance with this policy, Interactive Paper GmbH requires third-party vendors to provide evidence of their compliance with the policy's provisions. Such evidence may include certificates of compliance, training records, and documentation of Speak-up line usage.
Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action against the non-compliant individual, up to and including termination of employment or contract. Additionally, Interactive Paper GmbH reserves the right to terminate any agreement or contract with a third-party vendor who fails to comply with this policy.
Certification
By accepting this policy, third-party vendors certify that they have read, understood, and agree to abide by its terms. They also acknowledge that they have received adequate training on the policy's provisions and understand their responsibilities under it.
Appendix:
The following appendices provide additional guidance on the implementation of this policy:
Definitions
For the purposes of this policy, the following definitions apply:
"Third-party vendor" refers to any external entity or individual that provides goods or services to Interactive Paper GmbH.
"Government official" means any officer or employee of a government agency, including elected officials, civil servants, or military personnel.
"Facilitation payment" means a payment made to a government official or other person to expedite or secure performance of a routine governmental action or to obtain a minor favor.
"Bribe" means an offer, promise, or gift given to a government official or other person to influence their decision or behavior in relation to a business transaction or activity.
"Corruption" means the abuse of public office for private gain, including bribery, embezzlement, nepotism, or extortion.
"Speak-up line" refers to Interactive Paper GmbH's anonymous reporting channel for employees to report concerns or suspected misconduct.
Reporting Suspected Misconduct
If you suspect that a third-party vendor has engaged in bribery, corruption, or facilitation payments, you must immediately report your concerns to Interactive Paper GmbH using one of the following methods:
Contacting the Compliance Department directly
Using the Speak-up line
Submitting a report through Interactive Paper GmbH's intranet or online portal
All reports will be treated confidentially and investigated promptly. You can choose to remain anonymous when reporting, but please note that providing your contact information can help us follow up with you for additional information or clarification.
Investigation Process
When a report of suspected misconduct is received, Interactive Paper GmbH will initiate an investigation led by the Compliance Department. The investigation may involve interviewing witnesses, reviewing documents, and collaborating with external experts or law enforcement agencies.
During the investigation, we will take appropriate measures to protect whistleblowers from retaliation and ensure their anonymity, if desired.
After gathering facts and evidence, we will determine whether there has been a violation of this policy and what disciplinary action, if any, is warranted.
Disciplinary Action
In case of a confirmed violation of this policy, Interactive Paper GmbH will take appropriate disciplinary action against the responsible third-party vendor, up to and including termination of the business relationship.
Depending on the severity of the offense and the extent of damage caused, we may also pursue legal action, seek restitution, or refer the matter to law enforcement authorities.
Employees who violate this policy may face disciplinary action, up to and including termination of employment, depending on the circumstances.
Retaliation against anyone who reports suspected misconduct or cooperates in an investigation is strictly forbidden and will lead to disciplinary action.
It's important to remember that adherence to this policy is essential for preserving Interactive Paper GmbH's reputation and avoiding legal and financial consequences. Therefore, we encourage everyone involved in our business operations to act with integrity and speak up whenever they suspect unethical behavior.
By implementing this policy, Interactive Paper GmbH reaffirms its commitment to doing business ethically and in compliance with all applicable laws and regulations. We expect all third-party vendors to join us in this effort and to uphold the highest ethical standards in their dealings with us and on our behalf.
Team Training
Here you can find the certificates of the team members of the TRACE Global Anti-Bribery Compliance for Intermediaries.