On Anti-Corruption & Anti-Bribery
Netway Communication prohibits corruption of government officials and the payment of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector.
Corruption promotes poverty, hunger, disease, and crime, and keeps societies and individuals from reaching their full potential. Corruption is one of the leading obstacles to economic and social development. It distorts the rule of law and the institutional foundation on which Netway Communication depends.
Netway Communication is committed to observing the standards of conduct set forth in the laws and the applicable Anti-Corruption and Anti-Money laundering laws of the country/countries in which we operate. Netway Communication is also committed to continual improvement of the anti-bribery management system in place to assess, monitor, and manage potential bribery risks.
Overview of Standards of Business Conduct
As responsible business leaders, it is not enough to intend to do things right, we must also do them in the right way. That means making business decisions and taking appropriate actions that are ethical and in compliance with applicable legal requirements. The Netway Communication Standards of Business Conduct summarizes the regulatory requirements and business practices that guide our decision making and business activities. The Standards contain basic information about our policies as well as information about how to obtain guidance regarding a particular business practice or compliance concern.
Netway Communication policy and practice encourage the use of good judgment, discretion, and moderation when giving or accepting gifts or entertainment in business settings. Gift giving and entertainment practices may vary in different cultures, however, any gifts and entertainment given or received must be in compliance with law, must not violate the giver's and/or receiver's policies on the matter, and be consistent with local custom and practice. We do not solicit gifts, entertainment, or favors of any value from persons or firms with which Netway Communication actually or potentially does business. Nor do we act in a manner that would place any vendor or customer in a position where he/she may feel obligated to make a gift, provide entertainment, or provide personal favors in order to do business or continue to do business with Netway Communication.
Working with Trustworthy Representatives
Netway Communication requires its channel partners (for example, resellers, software advisors, original equipment manufacturers, and distributors), suppliers, vendors, consultants, lobbyists, and any other third-party representative (collectively, "Netway Communication Representatives") to comply with this Policy.
Netway Communication prohibits corruption of government officials and the payments of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector.
Netway Communication is committed to observing the standards of conduct set forth in the United States Foreign Corrupt Practices Act ("FCPA") and the applicable Anti-Corruption and anti-money laundering laws of the countries in which we operate.
Partners are responsible for training all employees who work on behalf of Netway Communication. We provide online training free of charge and other resources in the materials.
Partner Code of Conduct
Netway Communication partners and their employees, agents, and subcontractors (collectively referred to as “Partners”), in collaboration with Netway Communication, serve our customers. It is important for Netway Communication that Partners embrace and continually improve on the Netway Communication values. While conducting business with Netway Communication customers, Netway Communication expects its Partners to commit to operating in full compliance with all applicable laws and regulations, and to adhere to the principles outlined in the Partner Code of Conduct.
Supplier Code of Conduct
Through the Standards of Business Conduct, Netway Communication has established company standards that include ethical business practices and regulatory compliance. These standards apply to all Netway Communication employees, directors, and officers. Similarly, Netway Communication expects its suppliers to embrace this commitment to integrity by complying with and training its employees on the Netway Communication Supplier Code of Conduct.
Suppliers and their employees, agents, and subcontractors (collectively referred to as "Suppliers") must adhere to this Supplier Code of Conduct Policy while conducting business with or on behalf of Netway Communication (The terms "vendor" and "supplier" are used interchangeably). Suppliers must promptly inform their Netway Communication contact (or a member of Netway Communication management) when any situation develops that causes the Supplier to operate in violation of this Code of Conduct Policy.
While Netway Communication Suppliers are expected to self-monitor and demonstrate their compliance with this Code of Conduct, Netway Communication may audit Suppliers or inspect Suppliers' facilities to confirm compliance. Netway Communication may require the immediate removal of any Supplier representative(s) or personnel who behave in a manner that is unlawful or inconsistent with this Code of Conduct or any Netway Communication policy. Compliance with this Code of Conduct, and attending training on this Code of Conduct, as may be offered by Netway Communication, is required in addition to any other obligations in any agreement a Supplier may have with Netway Communication.
Representative Vetting and Contracting
Netway Communication performs regular monitoring of its Anti-Corruption program through various methods, one of which is risk-based due diligence ("vetting") of Representatives. Netway Communication requires that certain Representatives be subject to enhanced vetting before they are permitted to start or renew a business relationship with our Company, or any subsidiaries.
Contracts between Netway Communication and Representatives generally include mandatory Anti-Corruption clauses.