ANTI-CORRUPTION PROGRAMME

1. Against corruption

For the purposes of this Anti-corruption Programme, the following definition of corruption is established: abuse of power or position for private gain in such manner that is in violation of the law or ethics. 

GLOMEX Military Supplies has decided to introduce the Anti-Corruption Programme, designed to:
a) minimize the risk of corruption across GLOMEX Military Supplies business activities
b) play a preventive role against the risk of internal corruption while securing services and products on behalf of the Company
c) as an integral part of the industry to set an example on how to prevent corruption and unethical conduct

GLOMEX Military Supplies Anti-Corruption Programme consists of:

• GLOMEX Military Supplies employee Code of Ethics, sections of which are focused on the public procurement
• e-mail address set up to support reporting of any corrupt practices in relation to GLOMEX Military Supplies
• set of processes and measures to evaluate corruption risks within each company activity, employee group or specific market

GLOMEX Military Supplies Anti-corruption Programme is available to all interested parties, including the public, GLOMEX Military Supplies Customers and Suppliers, media and authorities.

2. GLOMEX Military Supplies Code of Ethics

The Code of Ethics is one of the main instruments of GLOMEX Military Supplies Anti-corruption Programe, which all employees undertake to comply with. However, some of its provisions apply to GLOMEX Military Supplies partners, such as GLOMEX Military Supplies agents. The Code of Ethics was set up in response to british Transparency International requirements.

Code of Conduct components:

• Ban on corruption
• Ban on activities which could represent a conflict of interest
• Corruption/Unethical conduct reporting
• Trade sector specific obligations
• Sponsorship / support of political parties and movements guidelines
• Commitment to promote GLOMEX Military Supplies Anti-corruption Programme beyond GLOMEX
  Military Supplies activities

Full version of GLOMEX Military Supplies Code of Ethics is available here.

3. GLOMEX Military Supplies sponsorship guidelines

No sponsorship is to be assigned to any public/private sector commercial transaction handling, as like as to any activity that could represent a conflict of interest, such as any GLOMEX Military Supplies employee/employee relative commercial activity. Any GLOMEX Military Supplies sponsorship is made public by publishing a press release or on company web pages.

4. Support of political parties and movements

Any GLOMEX Military Supplies support of political parties and movements must be transparent. At the same time, no sponsorship is to be assigned to any public sector business opportunity. GLOMEX Military Supplies strictly adheres to any legal requirements applying to support of political parties and movements.

5. Gifts and benefits

Providing Partners with unreasonably luxurious accommodation, unethical and expensive entertainment services or gifts of clearly unreasonable value is forbidden. Such conduct towards GLOMEX Military Supplies Partners will be deemed corruptive. Similarly, acceptance of gifts or benefits as described above by any GLOMEX Military
Supplies employee or management is forbidden. Any attempt to do so by GLOMEX Military Supplies Partners must be reported to immediate superior.

6. Facilitation payments

Public administration may require so-called facilitation payments on some of the foreign markets, legal locally. GLOMEX Military Supplies will under no circumstances make any payment of such nature, this excludes commissions to Partners or Agents within private sector.

7. GLOMEX Military Supplies participation on offset programmes

GLOMEX Military Supplies will solely participate on any offset programme in line with local national legislation, generally to meet the Client requirement to be able to partly produce and service locally. GLOMEX Military Supplies refuses and will not participate on offset programmes aiming at procurement in other than own industry,
holding a potential for corruptive conduct. GLOMEX Military Supplies will make public announcement about any activity that may be considered a direct offset (transfer of production will not be looked into for any but major projects)

8. GLOMEX Military Supplies Ethics Line

GLOMEX Military Supplies set up an e-mail in order to offer opportunity to communicate any unethical, corruptive, illegal, unsafe or environmentally harmful behaviour.

Send your input to: info@glomex-ms.com

GLOMEX Military Supplies strongly discourages submitting anonymous inputs, as such inputs alone pose a risk of unethical behaviour and Ethics line misuse. Anonymous inputs, however, are not forbidden.

All inputs will be dealt with by GLOMEX Military Supplies management, who will confirm receipt and inform the sender within 14 days about any measures taken and on the outcome of the investigation.

GLOMEX Military Supplies declares to support and appreciate any submissions to the Ethics line, excluding untrue and defamatory submissions. Such submissions alone pose a violation of GLOMEX Military Supplies Ethics code and Anti-corruption Programme, with all implications arising.

All submissions are treated as confidential in order to make objective investigation possible.