Introduction

Phones Canada is committed to conducting its business ethically and in compliance with all applicable laws and regulations regarding anti-corruption and bribery. This policy outlines the company’s stance on preventing corruption and bribery in all its forms and provides guidelines for its employees and business partners.

Scope

This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other parties who are involved in conducting business on behalf of Phones Canada.

Policy Statement

Phones Canada strictly prohibits bribery and corrupt practices in any form, whether directly or indirectly, involving public officials or private sector employees. This includes, but is not limited to, offering, promising, giving, or accepting any form of bribe or kickback.

Definitions

• Bribery: The offering, giving, receiving, or soliciting of any item of value to influence the actions of an official or other person in charge of a public or legal duty.
• Corruption: Abuse of entrusted power for private gain.

Guidelines

1. Compliance with Laws: All company operations must comply with the anti-corruption laws of Canada and any country where we operate.
2. Gifts and Hospitality: Gifts and hospitality may be offered or accepted only when they are modest, infrequent, and do not obligate the recipient. All gifts and hospitality must be reported and recorded in accordance with company procedures.
3. Donations and Sponsorships: Charitable contributions and sponsorships must be transparent and made without intention of influencing business decisions.
4. Due Diligence: Phones Canada will conduct due diligence on partners, agents, and third parties to ensure compliance with this policy.
5. Training and Awareness: Regular training will be provided to all employees to ensure they understand their responsibilities under this policy.
6. Reporting Violations: Employees are encouraged to report any suspicious activity or violations of this policy anonymously through the company’s whistleblowing channels.

Enforcement

Any breach of this policy will result in disciplinary action, up to and including termination of employment or contracts, and may also result in legal proceedings.

Policy Review

This policy will be reviewed and updated regularly to ensure it remains effective and compliant with all applicable laws and regulations.

Conclusion

Phones Canada is dedicated to upholding the highest standards of integrity and ethics in all aspects of our business. This Anti-Corruption and Bribery Policy is a testament to our commitment to combat corruption and ensure a transparent, fair business environment.