Anti-Bribery & Corruption Policy

Orion Promotional Group
Anti Bribery & Corruption Policy



 
1. Introduction

Orion Promotional Group (“Orion” or “the Company”) is committed to conducting business with integrity, transparency, and in full compliance with all applicable laws and regulations regarding anti-bribery and corruption. This Anti-Bribery & Corruption Policy (“Policy”) outlines our commitment to prevent bribery and corruption in all aspects of our operations, whether directly or indirectly related to the Company. This includes all employees, agents, contractors, third-party partners, and any other persons acting on behalf of Orion.

Orion recognizes the importance of maintaining the trust of our clients, employees, business partners, and the communities we serve. We are committed to ensuring that no part of our business is compromised by unethical conduct, including bribery and corruption.


2. Definitions

  • Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of an individual or entity to gain an improper advantage.
  • Corruption: The abuse of power or position for personal gain, including bribery, fraud, extortion, and other dishonest or unethical behavior.
  • Facilitation Payments: Small payments made to expedite or secure a routine government action or service that an individual is already entitled to. These payments are considered a form of    bribery and are strictly prohibited under this Policy.   


3. Policy Statement

Orion strictly prohibits all forms of bribery and corruption, whether direct or indirect, in the conduct of its business. This includes:

  • Offering, giving, or promising a bribe to any person or entity.
  • Requesting, receiving, or agreeing to accept a bribe in exchange for influencing any business decision.
  • Facilitation payments, as described above, are prohibited.
  • Improper political contributions or donations intended to influence decisions.

All employees, officers, directors, contractors, and agents of Orion are expected to conduct themselves with the highest ethical standards and adhere to the principles set forth in this Policy.


4. Prohibited Conduct

The following conduct is strictly prohibited:

  • Bribes or kickbacks in any form, including payments or gifts made to public officials, customers, suppliers, or other third parties.
  • Offering or accepting lavish gifts or hospitality that may be perceived as an attempt to influence business decisions.
  • Engaging in any form of corrupt activity related to the acquisition of business, the payment for services, or the granting of any benefit to gain an unfair advantage.
  • Engaging in fraudulent or deceitful practices designed to deceive stakeholders or evade legal requirements.

5. Gifts, Hospitality, and Entertainment

While providing modest gifts or hospitality may be appropriate in some business contexts, it must be done transparently and in compliance with local laws and regulations. All gifts, hospitality, and entertainment provided to or received from third parties must meet the following criteria:

  • They must be reasonable, proportionate, and necessary for the legitimate purpose of conducting business.
  • They should never be intended to influence a business decision or create a conflict of interest.
  • They must not exceed the Company’s approved limits on gifts or hospitality.
  • All such transactions must be recorded and reported in accordance with internal procedures.

 

6. Due Diligence and Third Parties

Orion will conduct appropriate due diligence on third-party partners, including agents, intermediaries, contractors, and suppliers, to ensure they are not engaged in any corrupt practices. This includes:

  • Ensuring third parties are aware of and committed to this Anti-Bribery & Corruption Policy.
  • Conducting background checks on new partners and suppliers to assess their integrity and reputation.
  • Monitoring the activities of third-party partners to ensure compliance with this Policy.

7. Reporting Violations

Employees and third parties are encouraged to report any actual or suspected breaches of this Policy. Orion is committed to maintaining an open and transparent reporting environment, and no employee will face retaliation for making a good-faith report. Reports may be made to:

    Ryan Rogers, Vice President
    (925) 360-2659
    rdr@orionpromo.com

All reports will be taken seriously and investigated promptly.


8. Investigation and Enforcement

Orion will investigate all reported or suspected violations of this Policy thoroughly and fairly. Any employee found to have violated this Policy may face disciplinary action, up to and including termination of employment. Similarly, any third-party partner found to be in violation may face contract termination and legal action.


9. Training and Awareness

Orion will provide ongoing training on anti-bribery and corruption laws and this Policy for all employees, officers, directors, and relevant third parties. The training will be designed to:

  • Ensure awareness of the risks associated with bribery and corruption.
  • Provide clear guidance on how to avoid bribery and corruption in business operations.
  • Reinforce the importance of compliance with all applicable laws and the Company’s ethical standards.

Training will be delivered regularly and updated as necessary to reflect changes in laws and business practices.


10. Compliance with Laws and Regulations

This Policy is designed to comply with all relevant anti-bribery and corruption laws, including but not limited to:

    The U.S. Foreign Corrupt Practices Act (FCPA)
    The U.K. Bribery Act 2010

In the event of a conflict between this Policy and applicable laws, employees should seek guidance from the Legal Department to ensure compliance.


11. Policy Review

This Anti-Bribery & Corruption Policy will be reviewed on an annual basis or more frequently as necessary to ensure its effectiveness and compliance with applicable laws. The Company will update the Policy as needed to address emerging risks, regulatory changes, or internal process improvements.

Conclusion
Orion Promotional Group LLC is committed to creating and maintaining a culture of ethical conduct, transparency, and compliance in all its business dealings. We expect all employees, agents, contractors, and business partners to share this commitment and uphold the highest standards of integrity.

Approved by:
Roxanne Rogers
President & CEO
April 13, 2019

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