We have zero tolerance for Stora Enso’s employees, officers, or third parties acting for or on behalf of the .of any kind, whether committed by
is the misuse of entrusted power for private gain. and are two most common forms of . is committed to conducting its business free from any forms of . It is also our policy to use our best endeavours to ensure that external business partners acting on our behalf are aware of and share our commitment to conducting business ethically.
Please remember that this Section 5 regarding Corruption Through Third Parties, Section 7 Gifts, Hospitalities and Expenses and Section 8 Rebate and Commission.must be read together with Section 6 Prevent
5.1 What are a ?and a
Ais one common form of . It is the offering, providing, authorising, requesting or receiving of any money, gift, loan, fee, reward or any financial or other advantage or anything of value, to or from any person as an inducement to act, or omit to act, in a way which is dishonest, illegal or a breach of trust. This means:
- It is intended as an inducement or reward for the improper performance of a relevant function by the recipient (whether or not they are a or otherwise connected with government). It does not matter whether the advantage or benefit is offered, provided, requested or received by a different person than the person who is to perform the relevant function;
- It is otherwise improper for the recipient to request or receive the relevant financial or other advantage (whether or not they are a
- It is offered or provided to a or to a third party at a ‘s request or with their consent or acquiescence with the intention of influencing the in their official capacity, inducing them to violate any lawful duty or inducing them to influence any government authority, in each case for the purpose of obtaining a business or any other advantage in the conduct of business or securing any other improper advantage.
Typical examples of:
- Money in the form of cash or secret , or other fraudulent or dishonest payment;
- of inappropriate value such as an expensive watch or phone;
- of inappropriate value, e.g. all-inclusive weekend stay at luxury resort hotels; or
- Unjustified favours, e.g. employing an unqualified relative of a or unjustified visa invitations.
Aneed not necessarily be of large value. It might include meals, entertainment, travel, incentive programs, signing bonuses, overpaying government suppliers, or doing business with a designated supplier who will rebate a portion of the purchase price. It might also include intangible benefits such as the provision of information or advice or assistance in arranging a business transaction or in obtaining any other benefit or advantage.
a visa process against invoices) to make to public authorities generally are permitted if they do not involve making payments directly to any particular public official. You should seek further guidance from if you are in any doubt as to whether a payment should be made.
5.2 Zero Tolerance of
Unless your or another person’s safety, health or liberty would be at risk, you must not:
- Offer, promise or give a to any person;
- Ask for or receive a from any person;
- Make a , even if such payments are common in the jurisdiction in which they are requested; or
- Agree, pay or receive or other fraudulent or dishonest payments.
5.3 Specific Rules in Relation to
Bribing ais a serious offence and carries particular reputational and legal risks. The definition of is very broad and includes central and local government officials and employees of public agencies and state-owned enterprises.
Unless specifically permitted or required under written applicable law, you must not offer or promise anything of value to, or for the benefit of, anyin order to influence a and to obtain or retain business or a business advantage, even if this would not involve the performing his job improperly.
Section 7 sets out particular rules which you must follow when offering or receiving.
Noofficer or employee may make a without the prior approval of the CEO. must never be used as a way of influencing a in his or her official capacity to obtain or retain business or a business advantage.
and must be free from any suspicion of bribery, whether direct or indirect. You must ensure that such activities are not made as an inducement for the purpose of obtaining any improper advantage or favour. All and must comply with the “Sponsorship and Donations Policy” or its equivalent.
- If you are offered or receive a request for , you must promptly make a report to ; and or
- Obtain prior approval from the CEO before making any Political Contribution.
Case studies and best practices
- Read the “Sponsorship and Donations Policy” or its equivalent for more information on Donations and .