Schimper Energy

1. PURPOSE

The purpose of this Anti-Bribery and Corruption Policy is to:

• Ensure that Schimper Energy and all its employees, directors, contractors, and partners comply with applicable anti-bribery and anti-corruption laws.

• Provide guidance on recognizing and preventing bribery and corruption.

• Establish procedures for reporting suspected violations.

This policy applies to all employees, directors, officers, contractors, suppliers, and business partners, as well as any subsidiaries and affiliates of Schimper Energy.

 

2. DEFINITION OF BRIBERY AND CORRUPTION

Bribery is the offering, promising, giving, accepting, or soliciting of an undue advantage as an inducement for action that is illegal, unethical, or a breach of trust. It can take many forms, including but not limited to:

• Cash payments

• Disproportionate Favourable contracts or terms

• Disproportionate Kickbacks or commissions

Corruption refers to the abuse of entrusted power for private gain, which includes bribery, embezzlement, fraud, and other forms of dishonest or unethical conduct.

 

3. OUR COMMITMENT

Schimper Energy is committed to:

• Zero tolerance for bribery and corruption: We prohibit all forms of bribery and corruption, whether direct or indirect, within all aspects of our operations.

• Compliance with laws: We comply with all applicable anti-bribery and anti-corruption laws.

• Ethical business practices: We promote transparency, accountability, and ethical conduct in all of our business dealings.

 

4. RESPONSIBILITIES

4.1. Employees and Representatives

All Schimper Energy employees, directors, contractors, and agents must:

• Not offer, give, solicit, or receive bribes in any form.

• Avoid any activity that might lead to, or suggest, a breach of this policy.

• Report any suspicion or knowledge of bribery, corruption, or unethical behaviour.

4.2. Suppliers and Business Partners

Schimper Energy expects all its suppliers, contractors, consultants, and business partners to act with integrity and uphold similar anti-bribery standards. Any third party acting on behalf of Schimper Energy must comply with this policy and relevant anti-bribery laws.

 

5. GIFTS AND HOSPITALITY

Schimper Energy recognizes that offering and accepting gifts and hospitality can be part of building business relationships. However, these must be carefully managed:

• Permissible Gifts and Hospitality: Must be reasonable, proportionate, and not intended to improperly influence business decisions.

Employees are required to seek guidance and approval before offering or accepting any gift or hospitality that could be perceived as inappropriate or could violate this policy.

 

6. FACILITATION PAYMENTS

Facilitation payments, sometimes referred to as “grease payments” are strictly prohibited including facilitation payments of any kind.

If any employee or contractor is asked to make a facilitation payment, they must refuse and report the incident immediately.

 

7. POLITICAL AND CHARITABLE DONATIONS

Schimper Energy does not make contributions to political parties, organizations, or individuals engaged in politics to gain an advantage in business. Any charitable donations or sponsorships made by Schimper Energy are transparent, legally compliant, and not used as a cover for bribery or undue influence.

 

8. REPORTING AND WHISTLEBLOWING

Schimper Energy encourages all employees, contractors, and partners to report any concerns or suspicions regarding bribery or corruption.

 

9. CONSEQUENCES OF NON-COMPLIANCE

Any employee, director, or representative of Schimper Energy found to have violated this Anti-Bribery and Corruption Policy will face disciplinary action, which may include termination of employment or contract. Schimper Energy may also terminate relationships with suppliers, contractors, or business partners who engage in bribery or corruption.

Violations of anti-bribery laws may also result in significant legal penalties, including fines and imprisonment.

 

10. MONITORING AND REVIEW

Schimper Energy will regularly review and update this Anti-Bribery and Corruption Policy to ensure its effectiveness. We will also monitor compliance with the policy through audits, assessments, and internal reviews.