---
title: "Anti-Bribery Policy Statement"
canonical: "https://support.soutron.net/space/AP/367132674/Anti-Bribery%20Policy%20Statement"
format: markdown
---
Soutron Global maintains an Anti-Bribery Policy prohibiting any improper or unethical payment to government officials or a party to a private commercial transaction anywhere in the world by any Soutron Global officer or associate (together, simply “Soutron Global associates”) or agent of Soutron Global. 

 

This Anti-Bribery Policy is designed to comply with the requirements of the U.S. Foreign Corrupt Practices Act (the “FCPA”), the U.K Bribery Act 2010 (the “U.K. Bribery Act”) and the anti-bribery laws of those other jurisdictions in which we do business.  These laws generally prohibit bribes, kickbacks, or illegal payments to influence business transactions and require us to maintain accurate books and records and a system of internal controls. 

Soutron Global ’s Anti-Bribery Policy states:

No Soutron Global associate or agent has the authority to offer payments of money or anything else of value, whether directly or indirectly, to a government official or a participant in a private commercial transaction to improperly induce that person to affect any act or decision in a manner that will assist Soutron Global or any of its subsidiaries or divisions, or any of its associates or agents, to obtain or retain business. 

Every Soutron Global associate and agent has the obligation to record accurately and fairly all of their transactions involving any expense of Soutron Global or any other transaction involving the disposal or transfer of Soutron Global assets.    

In addition to direct payments of money, other examples of prohibited payments would include the following made at the direction, or for the benefit, of a government official or a commercial business partner:

       gifts, or travel, meals, entertainment or other hospitality expenses;

       contributions to any political party, campaign or campaign official; or

       charitable contributions and sponsorships.

      

The Anti-Bribery Policy extends to Soutron Global ’s operations anywhere in the world, including all subsidiaries, divisions, agents, vendors, consultants or other representatives, as well as to any joint venture or other business enterprise in which Soutron Global is a participant. The Anti-Bribery Policy is applicable to activities of individual Soutron Global associates, as well as corporate and business unit programs, events, campaigns and other initiatives.

# Penalties

Violations by any Soutron Global associate of the anti-bribery laws or this Anti-Bribery Policy will result in progressive discipline, including possible termination of such associate's employment with Soutron Global. Violations by any Soutron Global associate or agent can also result in severe penalties for both Soutron Global and such individuals.

For example, individuals can receive five years of imprisonment and a $100,000 fine for each violation of the anti-bribery provisions of the FCPA, and 20 years imprisonment and a $5 million fine for each violation of the record keeping provisions of the FCPA.

Under the U.K Bribery Act, bribery and corruption is punishable for individuals by up to ten years imprisonment and companies could face an unlimited fine.

The FCPA specifically prohibits a company from reimbursing an officer, director, stockholder, employee, or agent for fines imposed for violations of the FCPA, so any fines for violations for which you are responsible will be paid from your personal assets. In addition, and in accordance with Soutron Global 's general legal compliance policy, Soutron Global will cooperate fully with law enforcement authorities in the investigation and prosecution of alleged violations of anti-bribery laws.

# Permitted Expenses

Government Officials

Soutron Global permits Soutron Global logo items (such as Soutron Global  logo pen and pencil sets, shirts, hats and other similar items) to be given to government officials as modest gifts in the ordinary course of business, provided that:

       such gifts do not exceed U.S. £10 in value;

       only one such item per calendar year be given to any single government official;

       presenting any such gift will be in conformity with the written laws of the country in which the gift has been made; and

        the associate presenting such gift makes an immediate written report to senior management.

Soutron Global also permits reasonable expenditures for travel, meals and entertainment expenses legitimately related to tours of Soutron Global ’s facilities, training in the use of Soutron Global ’s products and services, or otherwise related directly to Soutron Global’s promotion of its products and services, provided such expenditures are not extravagant and otherwise conform to the limitations in this Policy and to the laws and customs (as recognized by the written local law or a published judicial decision) of the country in which the expenditures are incurred.   Before providing, directly or indirectly, <u>any</u> such travel, meals or entertainment expenditure for a government official, you must first obtain written permission from Soutron Global’s Finance Director.

 

It will never be acceptable to offer any gift or incur any expense in expectation of receiving something in return (quid pro quo).

The following persons are considered “government officials”:

          officers and employees of any government, department, agency, bureau, authority, instrumentality or public international organization;

           persons acting in an official capacity on behalf of a government;

           employees of entities that are owned or controlled by a government; and

           candidates for political office.

The U.S. Department of Justice and the Securities and Exchange Commission have adopted a very broad interpretation of what constitutes an instrumentality of a foreign government.  For purposes of this Anti-Bribery Policy, any entity with significant governmental ownership or influence shall be viewed as an instrumentality of a foreign government.

# **Commercial Partners**

Other than for gifts with a value of no more than £20 given or received in the normal course of business, neither you nor your relatives may give gifts to, or receive gifts from, Soutron Global 's current or prospective clients, vendors or any other commercial partners.  Presenting or accepting any other gifts to or from private commercial parties requires prior written approval from the Finance Director, who must review the proposed gift with the Soutron Global Board of Directors.

 

Soutron Global permits accepting or incurring proportionate and reasonable expenditures for travel, meals and entertainment expenses legitimately designed to show appreciation to existing business partners, present products and services, or establish cordial business relations, provided that such expenditures:

         are not excessive and always appropriate to the nature of business relationship with the recipient;

         conform to the laws and customs (as recognized by the written local law or a published judicial decision) of the country in which the expenditures are incurred, as well as the policies, rules or codes of conduct of the recipient;

          do not place the recipient under an obligation or expectation to confer any business advantage in return for such hospitality (quid pro quo), or create an impression that the recipient's independence will be affected; and

          occur only occasionally.

 

Before providing or accepting, directly or indirectly, any travel, meals or entertainment expenditure reasonably valued at more than £50** **per each guest, you must first obtain written permission from the Finance Director. 

 

It is crucial that entertainment should not be given or received on such a scale that it forms an inducement to enter into a business transaction or arrangement that would not otherwise be undertaken.  Moreover, in no event may any gift or hospitality cause any other provision of this Anti-Bribery Policy to be violated, or put Soutron Global or you in a position that may cause embarrassment.

# Recordkeeping

Any gift, entertainment or hospitality given, received or offered will be accurately recorded, and no expenditure may be made with the express or implied agreement that it is to be used for any purpose other than as described by the records reflecting the expenditure.

 

# Third Parties’ Compliance with Soutron Global ’s Anti-Bribery Policy

Soutron Global 's obligation of ethical and legal behavior includes and encompasses the activities of Soutron Global 's agents, representatives, vendors, consultants and business partners (including joint venture partners).  Soutron Global will be held accountable for the actions of third parties doing business in any market on behalf of Soutron Global, so every associate and agent must remain vigilant to ensure such third party's actions are consistent with this Anti-Bribery Policy.  Willful ignorance of facts or circumstances which make it likely that bribery could be occurring will be a violation of this Anti-Bribery Policy and anti-bribery laws.

 

Before establishing a relationship with any third party to represent Soutron Global in any marketplace, sufficient due diligence must be performed to determine that the third party's commitment to ethical business practices is consistent with Soutron Global 's high standards and this Policy.  Any arrangement with such third party should include proper contractual provisions and monitoring procedures to ensure a compliance with anti-bribery laws and consistency with Soutron Global 's Anti-Bribery Policy.  

 

Particular care should be taken in any instance where the third party has interactions with government officials in the performance of its services on behalf of Soutron Global. 

# Red Flags

Among many other situations, the following situations, whether or not involving a government official, could expose Soutron Global and the individuals involved to a risk of a violation, and need to be reported as set forth below:

1. Requests or demands for a bribe.
2. Requests from a third party for Soutron Global to make payments (or portion of a payment) on behalf of the third party to someone else.
3. Requests or suggestions that Soutron Global make a charitable donation to a particular charity.
4. Requests for employment either on his or her own behalf or on behalf of another.
5. A person with whom Soutron Global is dealing has a reputation for receiving questionable payments.
6. A demand or strong suggestion that a particular local representative should be retained for any purpose.
7. A non-governmental person with whom Soutron Global is dealing has a known family or other significant relationship with government officials.
8. A request for an unusual or excessive payment, such as a request for over-invoicing, unusual up-front payments, unusual commissions, or a request for payments to be made to a third party (or to a third country), to a foreign bank account, in cash or otherwise untraceable funds.
9. A proposed agent or representative has little or no expertise or experience in the area (whether geographic, professional or otherwise) in which it will represent Soutron Global.
10. A proposed agent or representative refuses to provide written assurances that he or she will not make any improper payments.
11. A proposed agent or representative with whom Soutron Global seeks to do business requests an unusually high commission.
12. A proposed agent or representative with whom Soutron Global is conducting business fails to provide standard invoices.
13. A potential governmental customer requests an unusual credit or rebate with or from Soutron Global in return for its business.
14. Unusual bonuses or other amounts paid to agents or representatives of Soutron Global.
15. Soutron Global ’s operations are in, or it is transacting business with a person in, a country perceived to have high levels of corruption.

 

# Reporting Violations

Your conduct can reinforce an ethical atmosphere and positively influence the conduct of fellow associates. If you are aware of or suspect misconduct, you must report it to the CEO immediately upon discovery or suspicion.

 

This policy was last updated on Jan 2024