AudioCodes
con4PAS has become the AudioCodes Channel Partner with the certification:
Registered VAR / Systems Integrator
con4PAS has become the AudioCodes Channel Partner with the certification:
Registered VAR / Systems Integrator
This document aims to reinforce the position of con4PAS, a.s. (“con4PAS”) in combating and preventing corruption in the company’s activities and operations, and to outline the measures taken and envisaged to achieve these objectives.
Honesty and integrity, as well as the ethical values of con4PAS are enshrined in its Code of Ethics. They can be described using the abbreviation “PCO”. “PCO” stands for Professionalism, Courtesy and Openness – three interlinked qualities that are explained in the con4PAS’ statement of core corporate objectives.
The Code of Ethics forms the basis for issuing specific guidelines, such as the con4PAS’ rules of compliance.
The company values are based on the imperative of maintaining professionalism based on good reputation, while respecting the rules of competition and working conditions. Making any direct or indirect offers, providing payments, asking for a bribe and accepting a bribe – all these practices are unacceptable.
Employees must avoid conflicts of interest that could arise when providing investment or ancillary services to a client in cases that entail a significant risk of damage to the interests of one or more clients.
All business transactions must reflect con4PAS’ rules and regulations. As part of this Policy, con4PAS also prohibits payments intended to expedite routine or customary official acts, and strives to ensure that no such payments are provided by employees and contractors.
con4PAS expects its staff to follow the established rules and defend the corporate group’s interests in their work, and to be vigilant in relation to any potential criminal activity, serious breaches of rules or regulations, or suspected conduct, as described in the Whistleblower Protection Policy and elsewhere.
The company Anti-corruption and Anti-bribery Policy is supported by a number of structures and procedures developed at various levels of the corporate group to achieve the objectives set by this Policy.
This Policy applies to all con4PAS employees, entities, activities, operations and suppliers. In turn, it also covers the actions of con4PAS staff and any person or entity that carries out such an activity or represents con4PAS in any capacity. This Policy expresses con4PAS’ attitude towards corruption and fraudulent or coercive practices in the conduct of business. Such practices may include bribery aimed to influence the award of a contract, theft or misuse of public property, falsification of accounts to conceal the transfer of public funds to private accounts, breach of confidentiality or disclosure of classified information to help friends or relatives.
con4PAS will exercise zero tolerance in cases where, following an inquiry, the company determines that its staff members, consultants or persons acting as its agents have engaged in corrupt, fraudulent or coercive practices. con4PAS will under no circumstances tolerate its employees’ complicity in corrupt practices as defined in this Policy.
Each con4PAS entity is required to adopt a policy regulating the acceptance of gifts and commissions by its employees, linked to the corporate group’s gift acceptance policy. Any such action will be addressed properly by the relevant corporate group department.
con4PAS will not tolerate or turn a blind eye to any form of gifts to politically exposed persons, public figures or political parties that violate the applicable law.
Under no circumstances will con4PAS accept any supervisor’s instructions, recommendations or tolerance relating to an employee’s corrupt practices. con4PAS will not tolerate cases where an employee’s refusal to commit corrupt practices might cause harm to that employee within the organisation.
Payments intended to expedite a routine or customary official act are generally prohibited. If such payments cannot be avoided, they should be reported immediately to con4PAS’ management and Supervisory Board. Senior management has adopted a policy regarding the acceptance of gifts and commissions by con4PAS employees.
Any instance of corruption or failure to comply with the letter or spirit of the law or with this Policy will be penalised in accordance with the relevant employment contract and the local labour regulations of the entity concerned.
In accordance with this Whistleblower Protection Policy, con4PAS has enabled its employees to report possible fraudulent conduct or other gross negligence at the earliest possible opportunity without fear of retaliation. On its basis, whistleblowers are assured that their complaints will receive due attention and will be investigated properly.
Employees are encouraged to first try and use normal reporting channels, and only resort to this Policy if such normal channels prove to be useless.
Employees must refrain from abusing the whistleblowing procedure to deliberately harm others. Accusations made with dishonest or defamatory intent will be punished accordingly.
The con4PAS Whistleblower Protection Policy covers all types of fraudulent conduct and gross negligence in relation to major breaches of internal and external regulations or rules against market abuse, insider trading, breaches of bank secrecy or confidentiality in relation to insurance matters, money laundering, theft, fraud, corruption and bribery.
con4PAS guarantees in accordance with this Policy that a whistleblower who reports fraudulent conduct or gross negligence in good faith will not face any negative consequences ensuing from such a complaint.
con4PAS’ management and Supervisory Board are responsible for monitoring the operation of this Policy and for ensuring that the relevant reporting channels and guidelines are established.
con4PAS’ management and Supervisory Board are responsible for preventing any compliance risks and damage that may result from non-adherence to applicable laws, regulations and internal rules that fall within the scope of the compliance function or within the scope assigned to the compliance function by senior management. The Board of Directors, possibly acting through the Audit Committee, carries out annual assessment of the compliance risk control on the basis of the relevant report. Senior management is responsible for establishing this function, developing and implementing the integrity policy, reviewing the adequacy of the corporate group policies and ensuring compliance.
con4PAS’ management and Supervisory Board conduct tests based on a compliance monitoring programme that focuses on the application of these policies within the company.
The decision to establish the compliance monitoring programme was made in order to mitigate compliance risks by verifying the existence and reliability of internal control mechanisms (the first level of defence) and the reliability of their assessment.
The design of the compliance monitoring programme consists of an overview of compliance requirements arising from the existing legislation and policies, and a set of related control mechanisms. A risk-based approach is used to test the functioning of these mechanisms. The programme then results in structural recommendations or specific action plans. They also include follow-up and final reporting.
A “corrupt practice” is defined as direct or indirect offering, providing or accepting things of value with a view to dishonestly financing the action or omission by another person.
“Payments intended to expedite an official act” are usually payments of certain sums of money to public officials to secure or expedite a routine official act, often aimed to avoid bureaucratic delays or inaction that might occur if such a payment is not made.
“Whistleblower protection” applies to con4PAS employees or third parties who discover corruption in the company and file a complaint in accordance with the whistleblowing procedure.
“Bribery” includes the payment of money or the provision of an advantage to persons in the business community or government with a view to obtaining a business advantage. An obvious example is a case where a contractor offers money to a company employee to win a contract from that company. Bribery leads to a loss of trust and the damage suffered as a result of bribery generally exceeds the material value of the bribe. Bribery has an insidious effect on the company and can seriously damage the company’s reputation and undermine its authority to do business.
