ANTI-CORRUPTION POLICY

1. Purpose
The purpose of this Anti-Corruption Policy (the “Policy”) is to provide guidelines to ensure that business is performed in a legal, transparent and ethical way.
This Policy applies to all companies of the Group.

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2. Coverage
2.1.     People concerned
This Policy concerns all employees of the companies of the Group (“Company/ies”) and all third parties acting on behalf of the Company, such as consultants, contractors, business partners and vendors.  These parties will be informed about this Policy and should, to the maximum extent possible, commit to complying with this Policy as well as with all applicable anti-corruption laws and regulations.

2.2.     Important considerations
The Companies of the Group are bound by this Policy; however, they must first and foremost comply with their local laws and regulations. Where the compliance to this Policy by the Company leads to the violation of the local law, the Company shall

            - comply with its local law; and
            - inform the Group about the conflict

In many jurisdictions, only the corruption of Public Officials is illegal; however, this Policy also prohibits corruption of non-public entities/persons, such as companies and/or individuals. 

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3. Definitions
Corruption:       Corruption is the abuse of entrusted power for private gain. The gains can be not only financial, but also non-financial advantages. For the avoidance of doubt, corruption does not only relate to Public Officials but is extended to any individuals and any company.

Corruption also covers favoritism of which there are two forms –nepotism (favoring relatives) and cronyism (favoring personal friends).

The Group:       The Group shall mean the holding company, Teleperformance SA, and all companies directly or indirectly controlled by Teleperformance SA.

Bribery:             Bribery is an offer or receipt of any gift, hospitality, loan, fee, reward or other advantage to or from any person as an inducement to do something which is dishonest, illegal or a breach of trust, in the conduct of the business of the Group.

Bribery also covers trading in influence, which is the promise, offer or giving a Public Official an undue advantage.

Facilitation Payment:
Facilitation Payments are a form of bribery made with the purpose to expedite or facilitate the performance by a Public Official of a routine governmental action to which you have a rightful claim, such as a local tax to pay to the customs officer to bring back home certain goods without a receipt.

Public Official:

  • any person holding a legislative, executive, administrative or juridical office, whether appointed or elected, whether permanent or temporary, whether paid or unpaid
  • any other person who performs a public function, including a public agency or public enterprise, or provides a public service
  • any other person defined as a “public official” in the local law of the companies of the Group
  • the term Public Official also includes family members of any of these people

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 4. Procedures
HOSPITALITY
Hospitality is any invitation to an event, such as meal, reception, sports and cultural event, etc. hosted in a business context.

Before organizing an event or accepting an invitation to an event, employees shall ensure that the event complies with the following conditions:

•          Hospitality is justified by a clear business purpose.
•          The hospitality is just a small part of the program.
•          The total costs are kept within reasonable limits.

Payment of accommodation and travel expenses related to an event should not be received nor offered except under special circumstances:

•          There must be justifiable reasons.
•          Expenses must be reasonable and in line with normal standards.
•          The management must have approved the arrangement in advance.

Actions:        In any case the participation or organization of this kind of
event shall always be clarified in advance with the management.

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GIFTS
Gifts are presents such as gift vouchers, tickets to sports and cultural events, cash, discounts and loans, home improvements, or any other products or services given to an individual and not used in a hosted business context.

•          Employees shall only accept or offer a gift if it is a promotional item bearing a company logo or if it is of nominal value (i.e. inexpensive goods or services).

•          Gifts of moderate value may be accepted in cases where it would seem offensive to refuse it, but the gift will be regarded as the Company property and must be handed over to the management.

•          Gifts of significant value must never be accepted.

Actions:
All gifts of moderate or significant value that an employee may be offered or that an employee may intend to offer shall immediately be fully disclosed to the management.

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FACILITATION PAYMENTS
Facilitation Payments are small payments designated to obtain permits, licenses and other official documents, processing governmental papers such as visas and work order without obtaining a receipt. Facilitation of payments are not condoned in any circumstance and entirely prohibited. Before travelling it is recommended to check whether the country has ratified and enacted the provisions of the UN Convention against Corruption.

Actions:
The employee should request a receipt and inform the officer that the Embassy will be notified. In case of a continued issue, the employee should immediately inform his/her manager and request to speak with the manager of the officer.

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BIDDING
When participating in a tender (bidding) process with a government, a government-owned company, or directly with government officials and the Company is asked to support a program in the country concerned, such Company should not support the program if it is linked to the tender, as it can be categorized as an undue advantage.

Actions:
If asked to support a program, the Company should ensure that the entire process is transparent and request to know who will run the program, who will manage it and who will benefit from it.

Making donations to beneficiaries who are themselves or related to decision makers on outstanding bids is not permitted. Giving an advantage to family members or others close to a Public Official may also constitute corruption.

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CHARITABLE CONTRIBUTIONS AND SPONSORSHIP
Charitable Contributions and Sponsorship are acceptable, be it in-kind services, knowledge, services exchange, or direct financial contributions.

Actions:
Managers and employees must ensure through due diligence that charitable contributions and sponsorships are not used as a maneuver for and do not constitute bribery.

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TRADING IN INFLUENCE
Trading in influence is the promise, offering or giving to a Public Official or any other person, directly or indirectly, of an undue advantage in order that the Public Official or the person abuse his or her influence with a view to obtaining from an administration or public authority an undue advantage for the company.

When using intermediaries, the Company shall make sure to comply with the following requirements in order to reduce the risk of trading in influence:

           •          Perform a background check before hiring the intermediary.
           •          All agreements with intermediaries should be in writing and in line with national laws and the values and principles of the Group.
           •          Lobbyists should always clearly disclose that they represent the Company. 

Red Flags:

            •          Intermediary wants the money to be transferred into a foreign bank.
            •          Compensation is too high given the scope of work.
            •          The scope of work is not clearly defined.

Actions:
In case of any doubt, the employee shall escalate to his/her manager who must ensure that all the above mentioned requirements are applied.

No employee will be penalized due to delay or loss of business resulting from their refusal to receive bribes.

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 5. Implementation
Provisions:
From the date of this Policy, in all contracts with third parties employees, clients, suppliers, intermediates, contractors, etc.) clauses should be included to ensure compliance with anti-corruption laws.

All such third parties shall be made aware of the ethical values of the Group including its anti-corruption principles.

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Escalation Process:
Any employee directly or indirectly encountering any form of corruption that they feel might affect their business judgment or create conflicts of interests should seek advice from their manager who may concert with local Human Resources or Legal Officer.

If the issue cannot be solved locally, the Group should be notified.

Reports of violations will be kept strictly confidential.
Except as a requirement of the resulting investigation, the identity of the employee reporting a violation of this Policy shall not be disclosed if anonymity is requested.

No employee will be penalized for escalating a concern.

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Communication & training:
The Company should ensure that all its employees are informed about and understand the anti-corruption program. Each employee should receive relevant training and new employees will be briefed as a part of the Welcome orientation & Induction training.

At a minimum, key employees will receive yearly mandatory training including compliance with laws, regulations or standard conducts relevant for the Company’s field of business.

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6. Prevention
It is every employee’s responsibility to use best efforts in order to prevent bribery and corruption in the Group.

The Company should raise the awareness of any new hire through an induction module. The employees are provided with the UN Global Compact e-learning modules on the Group e-learning platform.
Furthermore, virtual conferences on anti-corruption have been organized for all managers and a recorded version is available on the Group Intranet my.teleperformance.com.

Internal and external auditors are essential elements in our global prevention approach.

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7. Sanction
Any employee who has attempted to breach or allegedly breached this Policy, whether by negligence or willful misconduct will be subject to disciplinary sanctions, in accordance with applicable laws.