Anti-Bribery & Corruption

Overview

Great Dane is committed to the prevention, deterrence and detection of fraud, bribery and all other corrupt business practices. It is Great Dane’s policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, wherever it operates throughout the world, of not engaging in bribery or corruption. 

When Used

This Anti-bribery and Anti-Corruption Policy (this “Policy”) applies to all individuals worldwide working for all affiliates and subsidiaries of Great Dane at all levels and grades, including directors, senior executives, officers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, casual workers, volunteers, interns, agents, or any other person associated with Great Dane (collectively referred to as “You” or “you” in this Policy). In this Policy, “Third Party(ies)” means any individual or organization, who / which come into contact with Great Dane or transacts with Great Dane or you and also includes actual and potential clients, suppliers, vendors, business contacts, consultants, intermediaries, representatives, subcontractors, industry associations, investors, research analysts, agents, advisers, joint ventures and government & public bodies (including their advisers, representatives and officials, politicians and political parties). 

Applicability

Great Dane will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by all the applicable local and national laws including the Foreign and Corrupt Practices Act 1977. In case any of the provision(s) of this policy is found to be conflicting with any other applicable laws and/or statutory provisions which might govern and/or impact the said provisions of this policy, as the case may be, such applicable laws and/or statutory provisions would have overriding effect to the effect of such provisions in this policy. 

Bribes, Kickbacks & Charitable Donations

A bribe is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. A bribe may be anything of value and not just money — gifts, inside information, sexual or other favors, abuse of function, which can pass directly or through a Third-party. Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery. 

Gifts and Hospitality

Employees or members of their immediate families should not provide or promise to provide, solicit or accept or agree to accept at a future date cash or its equivalent, favors, or anything of more than a normal and appropriate value to or from competitors, vendors, suppliers, customers or any other Third-party that do business or are trying to do business with Great Dane. 

Kickbacks

“Kickbacks” are bribes to obtain an undue advantage, where a portion of the undue advantage is ‘kicked backed’ to the person who gave, or is supposed to give, the undue advantage. 

Charitable Donations

As part of its corporate citizenship and/or Corporate Social Responsibility activities, Great Dane supports local charities, sporting, or cultural events. We only make charitable donations that are legal and ethical under local laws and practices and also within the corporate governance framework of the organization. 

Compliance with the Policy

Great Dane employees are expected to read, understand, and comply with this Policy. The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all those working for Great Dane or under Great Dane’s control or connected to Great Dane. You are required to avoid any activity that might lead to or suggest a breach of this Policy. Employees must notify his / her Manager as soon as possible if you believe or suspect that a breach of or conflict with this Policy has occurred or may occur in the future by way of a bribery issue or any other malpractices. Any employee who breaches this policy will face disciplinary action, which could result in dismissal.

Any breach of this Policy would result in Great Dane notifying appropriate authorities and termination of the contract with a Third Party. The Board of the Company or any committee/person authorized by the Board for this purpose shall determine the appropriate action in response to violations of this policy. Anyone who breaches this policy shall indemnify Great Dane against all claims, actions, damages, losses, liabilities, and costs, including reasonable legal fees, that may be incurred /suffered by Great Dane on account of any non-compliance of such person with this policy. In case of dismissal of an employee or termination of the contractual relationship with any third parties for the breach of the policy, no money will accrue for payment by the Company in any manner whatsoever from the date of such dismissal/termination except the amount which is already accrued till then.

The President has overall responsibility for ensuring that this policy complies with our legal and ethical obligations and that all those under our control comply with it. Managers at all levels are responsible for ensuring that those reporting to them are made aware of and understand this Policy, undertake training on how to implement and adhere to it, and also monitor compliance of it.