Anti Bribery Policy

Anti Bribery Policy Statement

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our relationships and business dealings wherever we operate and to implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption. We remain bound by the laws of Iraq, including the Criminal bribery law 111 for the year 1969 and its Amendments from article 307 to 314.

In practice fraud, bribery and corruption are managed by first implementing preventive rules and second setting punishment for whom his guilt is proven, preventive actions include not accepting the following (for HMH-Personnel) to:

  1. Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  2. Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
  3. Accept payment from a third party that he knows or suspects is offered with the expectation that it will obtain a business advantage for them;
  4. Accept a gift or hospitality from a third party if he knows or suspects that it is offered or provided with an expectation that a business advantage will be provided by us in return;
  5. Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
  6. Engage in any activity that might lead to a breach of this policy.

In addition to previously explained we:

  1. Must keep financial records and have appropriate internal controls in place which will evidence the business reason for making or receiving payments.
  2. Must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
  3. Must ensure all expenses claims relating to hospitality, gifts or expenses incurred to second parties are submitted in accordance with our expenses policies and specifically record the reason for the expenditure.
  4. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Rezhwan M. Othman
Authorized Manager
18 Aug, 2018