6. Prevent corruption through third parties
Our business partners who provide services, either formally or informally, toare expected to operate with integrity. They must refrain from paying or receiving any , or on behalf of , or as part of their business.
In some circumstances third parties with whom we have a business relationship or which act for us (“Third Parties”) can putat risk of criminal liability if they bribe another person to obtain or retain business or a business advantage for .
The process in this Section 6 must be followed when engaging any newor when renewing the contract for any existing .
Public Official on our behalf. The most typical include all types of agents, brokers, lobbyists and business consultants. The process in this Section 6 starts with identifying .are who act on our behalf, and therefore present increased bribery risks as they are in a position to obtain or retain business or a business advantage for us, e.g. because they are helping us to win business from a commercial customer or interacting with a
6.3 Process and Responsibility
Step 1 Assign
The business responsible person for a given team / area of business shall assign responsibility for managing the process set forth in this Section 6 to a single point of contact (the “Relationship Owner”).
Step 2 Identify
Follow the steps below to identify whether ais a :
Step 3 Due diligence and Decision Making
Use this GAN Third Party Relationship Tool to assess the risk level of the , conduct due diligence and make informed decision before engaging any Critical Third Party. Read here for more practical instruction about this tool.
For Critical Third Parties with long or revolving contract terms, due diligence needs to be repeated every 12 months for high risk parties, and every 24 months for medium risk parties. You will receive system notification 30 days before such time is due.
6.4 Mergers and acquisitions and joint venture partners
During mergers and acquisitions, the potential entities thatmay acquire or merge with may present risks if we do not take adequate procedures. A joint venture partner could also present risks if they perform services on behalf of and/or the joint venture. Therefore the “M&A Guideline” or its equivalent states that a risk assessment and due diligence must be performed as part of the acquisition analysis considering bribery, as well as other compliance risks.