Anti-Bribery Corruption (ABAC) Policy Statement

DuoCircle conducts its business professionally, with integrity, and in compliance with the laws of those jurisdictions in which it operates. Our reputation for acting fairly is built on our values as a company and the values of our employees. As part of our commitment to ethical business practices, we will not tolerate acts of bribery or corruption.

Most countries have laws that prohibit bribery and corruption. DuoCircle’s Anti-Bribery Policy, Anti-Malpractice Policy, and Code of Labor Standards are not intended to supersede local laws and regulations. They are intended to ensure that DuoCircle personnel, and those acting on our behalf, behave in a manner that is consistent with anti-bribery and corruption laws in all countries in which DuoCircle does business.

The Policies apply to all DuoCircle employees (whether permanent or temporary), contractors, officers, and directors of DuoCircle, its subsidiaries, and joint venture companies under DuoCircle’s control. Third parties acting on behalf of or in the name of DuoCircle, including agents, representatives, and other intermediaries, are required to act consistently with DuoCircle’s Anti-Bribery Policy. Joint venture companies not under DuoCircle’s control, and our joint venture partners, are encouraged to adopt a similar policy and procedures to prevent bribery.

DuoCircle operates a zero-tolerance approach to bribery and corruption in relation to bribes (payment, offer or promise to pay or provide anything of value), gifts and hospitality, facilitation payments (small payments or fees to speed up or facilitate the performance of routine action to which an entitlement already exists) and payments to government officials.

Third parties engaged to represent DuoCircle’s interests must comply with the principles set out in the Anti-Bribery Policy. It is DuoCircle’s policy not to make any political donations. We support contributing to the communities in which we do business. Many fundraising and sponsorship activities are undertaken at a local level.

The Code of Conduct guides our business relationships and provides a baseline for our ongoing review of ethical work standards

  • Applying the Code directly with our employees and in businesses in which DuoCircle has a controlling interest and / or has contractually mandated control over standards of operation.
  • Seeking, in businesses in which DuoCircle does not have control, to influence significant business partners and suppliers to adopt similar principles.
  • Make third parties, such as contractors, agents, or consultants, aware of our Code of Labour Standards and include compliance as a consideration in our decision to award contracts.

Including, but not limited to, local employment requirements, ethical practices, safe working environments, freedom from discrimination, freedom from harassment, freedom of expression and association, forced labor, child labor, and human trafficking, the Code reflects DuoCircle’s commitment to conduct its business professionally, with integrity and in compliance with the laws of those jurisdictions in which it operates.

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