ANTI-BRIBERY POLICY

This policy applies to T&M Specialists and all its operating members 

T&M Specialists (hereinafter “T&M”) is committed to the highest standards of business conduct and has zero-tolerance for bribery. At T&M, all employees of the T&M (the “Employees”) are required to follow all applicable laws, rules, and regulations related to anti-bribery and corruption, including Prevention of Bribery Ordinance (Cap. 201), guidance(s) issued by the Independent Commission Against Corruption (“ICAC”) and other similar laws and regulations, jurisdictions at HKSAR. 

T&M’s anti-bribery policies including guidelines on acceptable behaviour, other relevant policies are stipulated and clearly communicated to employees at all levels. Refresher training is periodically arranged to ensure that all employees are aware of the T&M’s zero-tolerance stance on bribery. 

 

Prohibited and Restricted Payments 

  • Offering, promising and authorising the giving of money, or anything else of value, to a government official or client in order to secure an improper advantage is strictly prohibited. 

  • No employee may offer, give, promise or receive money, or anything else of value, to or from an individual or entity in the private sector in order to obtain an improper advantage. Even the mere act of offering is prohibited, regardless of whether or not the item of value is actually accepted by the intended recipient. 

  • The prohibition covers cash payments, benefits and favours. In certain circumstances, it also covers otherwise legitimate business expenditures such as gifts, entertainment, travel, donations, sponsorships or training. 

  • The above-mentioned payments are prohibited regardless of whether or not they are made directly or indirectly through third party 

 

Personal Benefits – In general, Employees are prohibited from soliciting, accepting, or retaining personal benefits from any other Employees, the customer of the T&M, or any individual or organization doing or seeking to do business with the T&M. The T&M has put in place guidelines and procedures which Employees shall follow when personal benefits are accepted or retained under specified circumstances. 

Reporting Breaches or Concerns – Any employee who is in doubt, suspects that this policy has been breached or has concerns about past or proposed actions by anyone in the Carlsberg Group, or any third party working with the Group in any capacity, is encouraged to contact the VP Group Compliance or make use of the Speak Up facilities. 

All directors, agents, suppliers, associated persons, etc. are also expected to act in compliance with all applicable policies, laws, rules, and regulations related to anti-bribery and corruption in the performance of their services for or on behalf of T&M. T&M reserves the right to terminate any business relationship that violates T&M’s zero-tolerance policy against bribery. 

Employees who fail to comply with any legal obligation or statutes, internal or regulatory requirements related to anti-bribery and corruption will be subject to disciplinary action (which may include termination) initiated by T&M and where applicable, to criminal prosecution if concerned authority (e.g. law enforcement agencies) considers appropriate.