No To Bribery and Corruption

Policy Against Bribery and Corruption

WMSI Updates

Introduction

Wallem Maritime Services, Inc. (WMSI) is committed to upholding its TRIPLE corporate values when dealing with external service partners. As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated.

This policy sets out WMSI’s stand in preventing acts of, or analogous to, bribery and corruption, and have been designed to comply with our company Code of Conduct.

Furthermore, this policy aims to provide guidance on determining when an act or a transaction is prohibited, and what to do to ensure that our core values are advocated.

Who this policy applies to

The fundamental corporate values under which we operate do not vary depending on where we work or who we are dealing with. This policy applies to WMSI officers, employees (full and part-time), contractors and sub-contractors, suppliers and representatives. It is the responsibility of each of us to ensure that we comply with this policy in our daily working lives.

Part of WMSI’s commitment to defend this policy is to ensure that the people acting on our behalf also do so in compliance with effective anti-bribery and corruption policies. Accordingly, where we engage third parties such as agents, representatives, or suppliers, we have obligations to complete sufficient due diligence when entering into arrangements to ensure that they are not committing against this policy, and to periodically monitor their performance to ensure their active and ongoing compliance.

Failure to comply with this policy, whether or not that failure is intentional, may lead to disciplinary action (up to and including dismissal from the service), and may even include criminal liability for the individual involved. Our employees are required to confirm that they have read and understood this policy and that they will comply with its requirements as part of their continued employment.

Getting help

If you have questions or concerns about this policy, its terms or implementation, please get in touch with our

Human Resources Department
Wallem Maritime Services, Inc.
Wallem Philippines Building
Beaterio cor. Legaspi Street Intramuros 1002, Manila, PH
hrd@walcrew.com.ph 

What is bribery?

Bribery involves the following:

  • when a financial or other advantage is offered, given or promised to another person with the intention to induce or reward them or another person to perform their responsibilities or duties improperly (it does not have to be the person to whom the bribe is offered that acts improperly); or
  • when a financial or other advantage is requested, agreed to be received or accepted by another person with the intention of inducing or rewarding them or another person to perform their responsibilities or duties inappropriately (it does not have to be the person who receives the bribe that acts improperly).

It does not matter whether the bribe is:

  • given or received directly or through a third party (such as someone acting on WMSI’s behalf, for example an agent, supplier, or other intermediary); or
  • for the benefit of the recipient or some other person.

Bribes can take many forms, for example:

  • money (or cash equivalent such as GCs);
  • unreasonable gifts, entertainment or hospitality;
  • kickbacks;
  • unwarranted rebates or excessive commissions (e.g. to agents or other intermediaries);
  • unwarranted allowances or expenses;
  • “facilitation” payments/payments made to perform their normal job more quickly and/or prioritize a particular customer;
  • uncompensated use of company services or facilities; or
  • anything else of value.

How do I know if something is a bribe?

In most circumstances, common sense will determine when a bribe is being offered. However, here are some guidelines if in doubt:

  • Are you being asked to pay something or provide any other benefit over and above the cost of the services being performed, for an example an excessive commission, a lavish gift, or a kickback?
  • Are you being asked to make a payment for services to someone other than the service provider?
  • Are the hospitality or gifts you are giving or receiving reasonable and justified?
  • When a payment or other benefit is being offered or received, do you know or suspect it is to induce or reward favorable treatment, to undermine an impartial decision making process, or to persuade someone to do something that would not be in the proper performance of their job?

General prohibition

All forms of bribery and corruption are prohibited. We will not tolerate any act of bribery or corruption. Any breach of this policy could result in disciplinary action being taken and ultimately could result in dismissal.

A bribe does not actually have to take place – just promising to give a bribe or agreeing to receive one is prohibited.

Gifts, hospitality and expenses

Giving or receiving gifts or hospitality is often an important part of maintaining and developing business relationships. However, all gifts and hospitality should be for a genuine purpose, reasonable, given in the ordinary course of business and should comply with the current policies of WMSI as prescribed in HR-WMSI 09-01 and in the Interdepartmental Memo dated 06 September 1985.

Lavish or unreasonable gifts or hospitality, whether these are given or received, are unacceptable as they can create the impression that we are trying to obtain or receive favorable business treatment by providing individuals with personal benefits. In addition, gifts and hospitality can themselves be a bribe.

Reporting

WMSI is committed to ensuring that employees, agents, suppliers or other intermediaries can speak up with confidence if they have any concerns or need to ask for help in relation to this policy.

If you suspect or observe anything that you think might be in contravention of this policy, you have an obligation to report it. You should raise your concerns to:

Human Resources Department
Wallem Maritime Services, Inc.
Wallem Philippines Building
Beaterio cor. Legaspi Street Intramuros 1002, Manila, PH
hrd@walcrew.com.ph

WMSI will not tolerate retaliation in any form against anyone for raising concerns or reporting what they genuinely believe to be improper, unethical or inappropriate behavior. All reports will be treated confidentially.