ASCOM International is dedicated to upholding the highest standards of ethical, moral, and legal conduct in all aspects of its business. In line with this commitment, and with the aim of transparent communication, vendors and associated individuals are encouraged to raise concerns. Their identity will remain confidential, and they will be safeguarded against retaliation or discrimination for reporting issues in good faith.
Anti-bribery and anti-corruption
ASCOM is committed to complying with applicable domestic and international laws, regulations, and conventions related to anti-bribery and anti-corruption. It opposes corrupt practices, including bribery intended to secure business or gain an undue advantage.
Engaging in corruption is illegal and against ASCOM's values. Unlawful payments, including facilitation payments aimed at influencing routine actions by government officials, are denounced. ASCOM has a zero-tolerance policy toward bribery and corruption.
No bribes — whether offered by public officials, private individuals, or third parties — are tolerated. Employees, vendors, and contractors are expected to understand that offering or providing an improper benefit to sway a decision, even if the recipient is not a government representative, may result in disciplinary action and potential criminal prosecution.
Expected behaviour
Comply with applicable laws and regulations that prohibit paying or giving anything of value, either directly or indirectly, to a government official or a family member of a government official, a private individual, or employees of companies that are wholly or partially owned by a government entity.
Ensure that interactions and transactions with government officials, or with employees of companies, are clearly and accurately recorded.
Never allow joint-venture or consortium partners, subcontractors, suppliers, agents, consultants, intermediaries, or others to make prohibited payments on ASCOM's behalf.
Seek advice in advance from the division or corporate HR department, or from the department head, before offering gifts, entertainment, other hospitality, meals, travel expenses, or charitable donations.
Report observed conduct that potentially violates anti-corruption law.
Definitions
Bribery. A bribe is an amount of money or any favour given or promised in order to influence the judgment or conduct of a person in a position of trust. A bribe may also take the form of gifts, travel expenses, below-market loans, favours, and business or employment opportunities.
Prohibited or facilitation payments. Offering or giving improper benefits, or making payments, in order to influence the decision of the recipient.
Conflict of interest. A conflict may exist when an employee, or a member of that employee's family, is involved in an activity or has a personal interest that could impair, or appear to impair, objective and fair decisions, or that could create an incentive to act in a way that advances personal interests at the expense of ASCOM.
Raising a concern
To raise a concern, include your full name, company or vendor name, phone number, email address, the concern, any evidence, and a message. Use the contact form and choose “Code of conduct”. The form opens your email program, so evidence can be attached to the email before it is sent. The form is not an anonymous hotline.