Zero Tolerance for Bribery and Corruption
The Prudence Group maintains a zero-tolerance policy toward bribery and corruption in all forms, across every jurisdiction in which we operate. This policy ensures that our staff, and the parties with whom we do business, remain fully compliant with laws governing bribery and corruption.
Compliance with Applicable Laws
We are committed to complying with anti-corruption and anti-bribery laws applicable to our business, including those governing dealings with government officials, state-owned entities, and private-sector counterparts. This commitment applies regardless of local business customs that may differ from our own standards.
Prohibition of Improper Payments
No member of our organization, and no third party acting on our behalf, may offer, promise, give, request, or accept any improper payment, benefit, or advantage intended to influence a business decision or secure an improper advantage, whether directly or through an intermediary.
Gifts, Hospitality, and Entertainment
Reasonable and proportionate gifts, hospitality, and entertainment may be appropriate in the ordinary course of business, provided they are transparent, infrequent, and never intended or perceived as an inducement. Anything exceeding this standard should be declined or escalated for review.
Third-Party Intermediaries
We conduct appropriate due diligence on agents, consultants, joint-venture partners, and other intermediaries who act on our behalf, and we require that they adhere to standards consistent with this policy. We do not use intermediaries as a means of circumventing our own anti-corruption commitments.
Books and Records
We maintain accurate books and records that fairly reflect our transactions, in reasonable detail. No undisclosed or unrecorded funds or assets are maintained, and no false or misleading entries are made in our books and records for any purpose.
Training and Awareness
We are committed to ensuring that relevant staff understand this policy and the risks associated with bribery and corruption, through periodic training and awareness activities appropriate to their roles and level of exposure to relevant risk.
Reporting and Investigation
Any individual who becomes aware of a potential violation of this policy is expected to report it promptly to info@prudenceco.com. Reports made in good faith will be reviewed and, where warranted, investigated, without retaliation against the individual who raised the concern.
