7.1 Anti-bribery policy
Bribery means: paying money, promising to pay money, authorizing to pay money, or offering or promising anything of value to a person in a position of trust in order to unduly influence the judgment or conduct of that person.
ACE considers any form of bribery, extortion and corruption unacceptable.
ACE does not engage in the bribery of any public official, political candidate, party, party official, private sector employee or individual. Even where ACE is faced with extortion, in the form of a threat of financial harm or loss of business, bribery of any kind is not allowed. There are no exceptions for small amounts or the so called “facilitation-“ or “grease-“ payments. Furthermore, ACE also prohibits its employees from accepting or soliciting bribes or any other undue advantages.
7.2 Charitable contribution policy
Charitable contributions are donations given to a reputable non-profit institution or organization, for example in the field of disaster relief, without the intent to achieve a business advantage other than goodwill and reputational benefits. Charitable contributions can be financial or in kind (e.g. services) and are often provided in the framework of a company’s corporate social responsibility activities.
ACE allows for charitable contributions only under restricted circumstances:
- They are not made in order to secure a business deal;
- They are made for a legitimate purpose;
- They are given to a recognized and reputable charitable organization, not to an individual. In exceptional cases, with approval from ACE Group managing director, charitable contributions may be made to public or government institutions (e.g. hospitals). Charitable contributions to public or government institutions must not be made to gain an improper business advantage;
- The recipient of the charitable contribution has no business or private ties whatsoever with ACE and its employees;
- The amount of the contribution is reasonable;
- Pre-approval by the company managing director.
7.3 Sponsorship policy
Sponsorships are payments to an organization or an individual, made in cash or in kind. The purpose is to link ACE to a popular event (e.g. sports activity, concert, festival etc), or to a well-known person (e.g. a singer, sportsman, etc). The benefit to ACE is association of its name with the well-known and famous, an association which usually results in more publicity and a stronger brand. The business relationship between the sponsor and the receiving party as well as the commercial advantage for the sponsor distinguishes sponsorship from charitable contributions.
ACE allows for sponsorships only under restricted circumstances:
- The sponsored party can only be a recognized and reputable organization or individual;
- The sponsorship payments are made for the benefit of ACE and for a legitimate purpose;
- The sponsored party has no private ties with ACE employees, such as family relationship;
- The sponsorship payment is transparently documented in an agreement with the organization;
- The contribution can be financial or in-kind;
- The amount is reasonable and inline with local practices;
- Pre-approval by the company managing director.
7.4 Political contribution policy
A political contribution (also referred to as political donation) is any contribution made to a politician or a political campaign or a political party. This includes payments made directly or indirectly (i.e. through an acquaintance or any other intermediary), and contributions in cash or in kind.
ACE employees are prohibited from making political contributions in any form for or on behalf of ACE. Personal contributions by ACE employees may be made in their own capacity, if they are not made with the intention or result of directly or indirectly benefiting ACE and if no ACE funds, resources, time or assets are involved.
Furthermore, ACE employees must not use third parties (i.e. agents, subcontractors, consultants or other intermediaries) to make political contributions on ACE’s behalf.
7.5 Gift and entertainment policy
ACE allows the offering and receiving of gifts, hospitality, entertainment and expenses if they are:
- in compliance with relevant laws and acceptable according to local culture;
- offered/promised/given or received openly and unconditionally;
- given without the intention of obtaining or retaining any direct business advantage;
- of reasonable/modest value, i.e. insignificant compared with local average salaries;
- given or received infrequently;
- in good taste, i.e. not offending the feelings of others in relation to disability, gender, culture, nationality, etc.;
- properly recorded and documented according to local legislation;
- pre-approval by the company managing director.
“Gifts” are benefits given to an institution or an individual, either in the public or the private sector without the intent of achieving a business advantage in return other than goodwill and reputational benefits. Example: office trinkets.
“Hospitality and Entertainment” include occasional invitations to ordinary sports, theatre or other cultural events as well as invitations to modest meals / refreshments or customer events.
7.5.1 Additional requirements for gifts
Private sector gifts have to be given in good faith, as a gesture of goodwill or to further a good cause. Furthermore, gifts must always be given in kind and never in cash.
Differences between the public sector and private sector need to be considered:
Public sector
Most countries have tight restrictions in regards to the value of gifts which can be given to public officials. Therefore all gifts to public officials (exceptions are promotional materials such as pens, paperweights, T-shirts or other items bearing the Company logo) must be pre-approved by the corporate manager. All gifts given to officials must stay within the cost limits specified in local law and must be recorded to a central list.
Private sector
Giving gifts: all gifts that are given to third parties must be approved by the company managing director. Exceptions are promotional materials such as pens, paperweights, T-shirts or other items bearing the Company logo. Gifts must be of modest value and reflect good local customs.
Receiving gifts: all gifts that are accepted by ACE employees from business partners must be of modest value and reflect good local customs.
7.5.2 Additional requirements for hospitality and entertainment
Hospitality and entertainment must be secondary and related to the main business purpose. Furthermore, hospitality and entertainment must always be in kind and never in cash.
Differences between the public sector and private sector need to be considered:
Public sector
Most countries have tight restrictions in regards to the value of hospitality and entertainment that can be provided to public officials. Therefore all hospitality and entertainment provided for public officials must be pre-approved by ACE Group managing director. All entertainment provided to officials must stay within the values specified in local law and must be documented according to local law.
Private sector
Entertaining: expenses for entertaining third parties (dinners, lunches etc.) must be of modest value and reflect good local customs.
Should this value be exceeded (i.e. sponsoring events etc.), then the company managing director needs to approve this in writing prior to occurring the expense.
Receiving entertainment: expenses for receiving entertainment by business partners (dinners, lunches etc.) must be of modest value and reflect good local customs. Should this value be exceeded (i.e. sponsoring events, conferences etc.), then the company managing director needs to approve this in writing prior to the event.
7.5.3 Additional requirements for expenses
Only the expenses of reputable institutions or organizations should be reimbursed.
Reimbursement should never be transferred to an individual’s personal bank account.
