Connor does not tolerate bribery, kickbacks, or corrupt acts of any kind or in any circumstances from Connor staff, or its clients, agents, consultants, licensees, vendors, or representatives of any kind.
Corruption is the misuse of power for private profit or gain. Bribery is broadly defined as offering to make or making a payment, or offering to provide or providing anything of value, to influence a decision or create an improper advantage. This prohibition includes making or offering to make payments through intermediaries or to third parties; and it does not require that payments actually be made.
Staff must abide by all applicable anti-bribery and anti-corruption laws. All Connor staff in all countries are subject to the U.S. Foreign Corrupt Practices Act (“FCPA”). The FCPA prohibits improper payments to government officials and officials of public international organizations. Connor staff living or working in countries other than the US may also be subject to national anti-corruption laws. All staff are required to raise potential issues before they lead to problems and to seek additional guidance when necessary.
Connor considers compliance with anti-corruption laws, and with Connor’s internal policies relating to anti-corruption, to be a serious matter, and will thoroughly investigate any allegations of bribery. Connor employees, and others working on Connor’s behalf or for its benefit, who do not comply with such laws and policies may be subject to disciplinary action up to and including termination of their employment or other relationship. In addition, individuals violating applicable anti-corruption laws may be subject to a range of penalties, which could include fines and imprisonment.