Anti-bribery and Anti-corruption Compliance Policy Sociedad Química y Minera de Chile ( SQM )
|
|
- Lawrence Boyd
- 6 years ago
- Views:
Transcription
1 Anti-bribery and Anti-crruptin Cmpliance Plicy Sciedad Química y Minera de Chile ( SQM )
2 Preface At SQM, we believe in fair cmpetitin. We are cmmitted nt t engage in any acts f bribery r crruptin anywhere in the wrld. We expect the same uncmprmising behaviur frm ur directrs, fficers, emplyees as well as ur distributrs, agents and partners all ver the wrld. Any actin in cntraventin f the present plicy will be dealt with swiftly and severely t the fullest extent f the law. Patrici de Slminihac CEO 2
3 Cnsistent with SQM s Cde f Ethics and cmmitment t fstering and maintaining a strng anticrruptin culture and t uphlding and cmplying with all laws, SQM des nt tlerate any frm f bribery r crruptin. It has been and cntinues t be the plicy f SQM t cnduct its peratins and activities in cmpliance with the letter and the spirit f all applicable dmestic and internatinal anticrruptin laws and regulatins, including, but nt limited t, Chilean bribery and crruptin laws and the Chilean Crprate Criminal Liability Law (Ley 20393), the U.S. Freign Crrupt Practices Act ( FCPA ), and similar laws that apply in the cuntries in which the Cmpany perates (cllectively, Applicable Anti- Crruptin Laws ). Plicy Against Crruptin This Anti-bribery and Anti-crruptin Cmpliance Plicy (the Plicy ) applies t all SQM dmestic and freign peratins, including all directrs, fficers, and emplyees wrldwide (cllectively, Persnnel ), including all SQM subsidiaries, affiliates, and cmpanies in which SQM wns mre than 50% r has management cntrl (even if SQM is nly a part wner r jint venture partner). SQM als requires distributrs, agents, cntractrs, subcntractrs, cnsultants, representatives, intermediaries, business partners, jint venture partners, and any ther third parties assciated with SQM r any f its subsidiaries r wh cnduct business n SQM s behalf (cllectively, Business Partners ) t cmply with this Plicy. Persnnel and Business Partners may be required t cmplete certificatins f cmpliance with Applicable Anti-Crruptin Laws and this Plicy. This Plicy prhibits Imprper Payments made in cnnectin with r n behalf f SQM. Fr the purpses f this Plicy, the term Imprper Payments includes a brad range f crrupt payments f mney r anything f value r any advantage (which des nt need t be financial) made r given in rder t influence favrably sme decisin affecting SQM s business, t btain an imprper advantage, t induce r reward imprper perfrmance, fr the persnal gain f an individual, r where the payment r advantage itself is imprper. Imprper Payments are nt limited t cash payments, but include crrupt: cash equivalents (such as gift cards r prepaid charge cards); gifts; entertainment, meals, and travel; in-kind cntributins and/r services; business, emplyment, r investment pprtunities; uncmpensated r discunted use f SQM prducts, services, facilities, equipment, r prperty; dnatins, r cntributins, including uncmpensated r discunted supply f tangible gds (including scraps r salvage gds); payment f medical expenses; assistance t, r supprt f, family members and friends; charitable cntributins, even t bna fide rganizatins; and 3
4 ther benefits r advantages. SQM s plicy cncerning bribery and crruptin is abslutely clear: n ne may ffer, give r receive bribes r Imprper Payments in cnnectin with their wrk fr SQM t r frm anyne at any time fr any reasn, and n ne shuld ever ask anyne else t engage in bribery r make an Imprper Payment n SQM s behalf. N fficer, directr, emplyee r Business Partner may ever: Offer, prmise, pay, r authrize an ffer r payment f mney r anything f value t a Public Official, r any ther persn r entity, directly r indirectly, which is: Intended t crruptly influence any actin (r failure t act) r decisin in the recipient s fficial capacity r in vilatin f the recipient s duty; Intended t crruptly induce the recipient t use influence t affect any act r decisin f the entity invlved; Intended t crruptly secure any imprper advantage r t assist SQM in btaining r retaining business; r Intended as gratitude fr the recipient having made a decisin r acted in a way that benefited SQM imprperly. Request r accept any mney r item f value, directly r indirectly, which is: Intended t imprperly influence the judgment r cnduct f the recipient, whether t take an actin, fail t act, r t use his r her influence in his r her jb respnsibilities; r Intended as gratitude fr having made a decisin r acted in a way that benefited imprperly the persn r entity giving the item f value t the recipient. These prhibitins are described in mre detail in the fllwing sectins. 1. Prhibited Bribery f Public Official(s) SQM and all Persnnel and Business Partners emplyed by r affiliated with SQM are prhibited frm giving, prmising, ffering, r authrizing, directly r indirectly, an Imprper Payment t a Public Official, r t a Clse Family Member f a Public Official, r t any ther persn at the request f the Public Official r with the Public Official s assent r acquiescence. SQM als prhibits any Imprper Payment, prmise, ffer, r authrizatin f the giving f an Imprper Payment t anyne while knwing it will be given t r shared with a Public Official, Clse Family Member f a Public Official, r ther designee. Fr the purpses f this Plicy, Public Official means: any fficer r emplyee f any natinal, reginal, lcal, r ther gvernment r any department, agency, r instrumentality f such a gvernment, including any elected r appinted fficial (e.g., a member f a the Ministry f Mining), in any branch (executive, legislative, r judiciary); 4
5 any fficer r emplyee f a cmpany r enterprise wned r cntrlled by r perfrming a functin f a gvernment (e.g., natinal energy and transprtatin cmpanies, healthcare prviders, and state-wned tbacc cmpanies); any fficer r emplyee f a public r state-spnsred university r research rganizatin; any plitical party, plitical party fficial r candidate fr public ffice at any level; any fficer r emplyee f a public internatinal rganizatin (e.g., the Wrld Bank, the United Natins, r the Internatinal Mnetary Fund); any member f a ryal family r member f the military; any individual acting in an fficial capacity fr r n behalf f any f the abve categries (whether paid r unpaid); and any individual therwise categrized as a Public Official under applicable lcal laws r SQM s plicies. Fr the purpses f this Plicy, the term Clse Family Member includes any spuse, partner, parent, grandparent, sibling, child, grandchild, niece, nephew, aunt, uncle, r cusin, whether thrugh bld r marriage; including thse f the Public Official s spuse and/r partner; and any ther individual that shares the same husehld with the Public Official. SQM permits the prvisin f certain business curtesies, such as meals, t Public Officials within a narrw set f exceptins set frth in the SQM Gifts, Entertainment, and Hspitality Prcedure, and nly as permissible under applicable laws, including the written laws f the Public Official s cuntry. 2. Prhibited Cmmercial Bribery SQM and all Persnnel and Business Partners emplyed by r affiliated with SQM are prhibited frm giving, prmising, ffering, r authrizing, directly r indirectly, an Imprper Payment, including any bribe, kickback, r payff, t a supplier, custmer, r ther third party t imprperly influence the actins f anther party t secure an imprper advantage frm his r her emplyer s r principal s cmmercial cnduct. This can be dne by ffering r prviding a benefit t smene withut the knwledge f that persn s emplyer r principal. 3. Prhibited Receipt f Imprper Payments N SQM Persnnel r Business Partners emplyed by r affiliated with SQM may slicit, request, agree t receive, r accept directly r indirectly any financial r ther advantage r anything f value that is related t inducing r rewarding imprper perfrmance r services r benefit by r frm any SQM Persnnel r Business Partner emplyed by r affiliated with SQM. 4. Prhibited Plitical Cntributins SQM des nt make cntributins f any kind t plitical parties, plitical party fficials r candidates fr public ffice. 5
6 5. Prhibited Facilitating Payments Payments made t a Public Official t encurage r speed up the perfrmance f an existing duty r bligatin (ften described as a Facilitating Payment ) are prhibited by SQM. 6. Health and Safety Payments In very rare circumstances, an SQM fficer, directr r emplyee may deem it necessary t make a payment t a Public Official t avid imminent danger such as a threat t persnal health, safety, r freedm and may nt be able t btain preapprval. Such a payment may nt be a Facilitating Payment, but a payment made in respnse t duress where, in the best judgment f that fficer, directr r emplyee at the time, such payment was required t be made in rder t remve r mitigate a threat r risk f imminent physical harm t him, her, his/her family member r clleague, r t the detentin f any f thse persns. If such a payment is made, as sn as pssible, the fficer, directr r emplyee wh made the payment shuld cntact the Risk Management and Cmpliance Officer fr further directin. SQM Persnnel shuld seek t avid the need t make any such health and safety payment. It is the respnsibility f SQM fficers, directrs and emplyees t ensure they have cmplied with all applicable laws, maintain any required dcumentatin and meet health, safety, and immigratin requirements, t reduce the risk f being detained r subjected t ptential physical harm. 7. Recrdkeeping Many f the Applicable Anti-Crruptin Laws als cntain prvisins that require SQM t (a) make and keep recrds which in reasnable detail, accurately and fairly reflect transactins and the dispsitin f assets, and (b) maintain internal cntrls that will prvide reasnable assurances that transactins are executed and recrded prperly. Accrdingly, all Persnnel and Business Partners emplyed by r affiliated with SQM must accurately dcument and recrd all expenditures n behalf f SQM and are prhibited frm hiding r misrepresenting cmpany expenditures r making payments n behalf f SQM withut the apprpriate apprvals and supprting dcumentatin that verifies the validity f the transactin. 8. Vilatins All Persnnel and Business Partners emplyed by r affiliated with SQM are expected t understand and fllw Applicable Anti-Crruptin Laws and this Plicy and failure t d s may result in discipline, up t and including terminatin f emplyment and/r terminatin f affiliatin with SQM. Failure t cmply with these laws discussed in this Plicy can lead t ptentially significant financial penalties fr cmpanies, as well as imprisnment and mnetary fines fr any individuals invlved in miscnduct. Vilatin f the Applicable Anti-Crruptin Laws als can lead t restrictins n ding business, such as suspensin r debarment frm bidding, cause significant damage t the reputatin f cmpanies and their persnnel and even result in the disslutin f SQM. 9. Reprting Obligatins and Additinal Infrmatin All SQM Persnnel and Business Partners emplyed by r affiliated with SQM have a respnsibility t prmptly reprt suspected r knwn vilatins f this Plicy, ther SQM plicies, and any applicable laws. The requirement t reprt suspected r knwn vilatins shuld nt be cnstrued as preventing emplyees frm als reprting pssible vilatins t apprpriate gvernment authrities. Yu may chse t make a reprt t yur supervisr, t any member f the Ethics Cmmittee, Cmpliance 6
7 Cmmittee, r Cmpliance Department, r thrugh ne f the reprting channels listed belw. SQM will ensure the perability f the reprting channels and will ensure accurate cntact infrmatin fr these reprting mechanisms is available. Reprts may be made annymusly, where permitted by lcal law. Phne Number (Vic ): Regular Mail: cnfidential letter, addressed t: SQM s Cmpliance Officer El Trvadr Las Cndes Santiag Chile Addresses: whistleblwer@sqm.cm r denuncias@sqm.cm Whistleblwer Frm: thrugh the crprate website r thrugh the Cmpany intranet SQM will nt retaliate r tlerate retaliatin against any emplyee wh reprts in gd faith a ptential vilatin f this Plicy, even if an investigatin eventually determines that n vilatin ccurred. Questins regarding this Plicy r Applicable Anti-Crruptin Laws shuld be addressed t the Risk Management and Cmpliance Officer. 7
Anti-Bribery and Anti-Corruption Compliance Policy Sociedad Química y Minera de Chile ( SQM ) Version No. [2], June, 2018
Anti-Bribery and Anti-Crruptin Cmpliance Plicy Sciedad Química y Minera de Chile ( SQM ) Versin N. [2], June, 2018 Preface At SQM, we believe in fair cmpetitin. We are cmmitted nt t engage in any acts
More informationAt Sungard Availability Services (Sungard AS), we believe that business thrives best in an environment of open and fair competition.
1 / 6 GLOBAL ANTI-CORRUPTION POLICY At Sungard Availability Services (Sungard AS), we believe that business thrives best in an envirnment f pen and fair cmpetitin. Bribery and ther crrupt acts undermine
More informationAnti-Corruption Compliance Plan
Anti-Crruptin Cmpliance Plan Apprved By: Pascal Budge Effective Date: 23 May 2016 Number: 11-1 Revisin: 01 This material cntains prprietary infrmatin f IAP Wrldwide Services, Inc. (IAP). Disclsure t thers,
More informationBUSINESS ETHICS ASSESSMENT
TENDER / ASSIGNMENT TENDER / ASSIGNMENT NUMBER TENDER MANAGER / ASSIGNMENT LEADER AUTHOR DATE 20160118 PART 1 (2) BUSINESS PARTNER NAME REGISTERED ADDRESS HOMEPAGE VISITING ADDRESS (IF DIFFERENT FROM ABOVE)
More informationCODE OF CONDUCT AND ETHICS POLICY ON CONFLICTS OF INTEREST
CODE OF CONDUCT AND ETHICS POLICY ON CONFLICTS OF INTEREST Magna Internatinal Inc. Plicy n Gifts & Entertainment 1 POLICY ON CONFLICTS OF INTEREST Magna emplyees have a duty t act in Magna s best interest.
More informationGifts & Hospitality. Effective Date Author Owner Approval Last Review Revise Date August 2017
Gifts & Hspitality Effective Date Authr Owner Apprval Last Review Revise Date August 2017 Iain Simm Jeremy Arn Miles Rberts Nvember 2011 August 2019 The Pwer f Less www.dssmith.cm Gifts and Hspitality
More informationGifts & Hospitality Policy
Gifts & Hspitality Plicy Effective Date: 1 January 2016 Fr internal and external use. Table f Cntents Intrductin... 2 Wh des this Plicy apply t?... 2 What is a Gift, Hspitality?... 2 When is giving r receiving
More informationCODE OF CONDUCT AND ETHICS POLICY ON COMPLIANCE WITH SANCTIONS & TRADE EMBARGOES
CODE OF CONDUCT AND ETHICS POLICY ON COMPLIANCE WITH SANCTIONS & TRADE EMBARGOES Magna Internatinal Inc. Plicy n Gifts & Entertainment 1 POLICY ON COMPLIANCE WITH SANCTIONS & TRADE EMBARGOES Magna is cmmitted
More informationThe Company is a public company incorporated in Bermuda and its securities are listed on AIM.
(Incrprated in Bermuda Registratin N. 44512) POLICY FOR TRADING IN COMPANY SECURITIES The Cmpany is a public cmpany incrprated in Bermuda and its securities are listed n AIM. Schedule 1 t this Plicy cntains
More informationHIPAA Privacy Rule LINKS AND RESOURCES AFFECTED ENTITIES IMPACT ON EMPLOYERS. Provided by Brown & Brown of Louisiana, LLC
Prvided by Brwn & Brwn f Luisiana, LLC HIPAA Privacy Rule The HIPAA Privacy Rule establishes natinal standards t prtect individuals medical recrds and ther persnal health infrmatin. The Privacy Rule applies
More informationAnti-Bribery & Corruption Policy
Anti-Bribery & Crruptin Plicy Effective Date: 1 January 2016 Fr internal and external use. Table f Cntents Intrductin... 2 What is the purpse f Pearsn s ABC Plicy?... 2 Wh des Pearsn s ABC Plicy apply
More informationSNAKK MEDIA LIMITED FINANCIAL PRODUCTS TRADING POLICY AND GUIDELINES
SNAKK MEDIA LIMITED FINANCIAL PRODUCTS TRADING POLICY AND GUIDELINES Date adpted: 5 Nvember 2015 Versin: 1 1 SCOPE OF POLICY FINANCIAL PRODUCTS TRADING POLICY AND GUIDELINES This plicy applies t all directrs,
More informationAnti-fraud and bribery Policy
Anti-fraud and bribery Plicy IIED Plicy: Anti-Fraud and Bribery Plicy Cntact: Debrah Harris Issued/updated: January 2016 Plicy Statement In carrying ut its wrk, IIED is cmmitted t preventing fraud and
More informationANTI-BRIBERY AND CORRUPTION POLICY
ANTI-BRIBERY AND CORRUPTION POLICY 1. INTRODUCTION This plicy applies t Kemcre Suth Africa Prprietary Limited and its subsidiaries and assciate cmpanies (cllectively referred t as Kemcre ) are cmmitted
More informationHospitality, Gifts and Bribery Policy
POLICY DOCUMENT Hspitality, Gifts and Bribery Plicy LAST UPDATED (by) Rachel Lawsn 6 th Nvember 2018 LAST REVIEWED (by) POLICY TYPE REVIEW FREQUENCY Vluntary Every tw years RESPONSIBLE Leadership Team
More informationExtending Ethics and Compliance to Third Parties Managing Third Party Risk of Corruption October 23, 2009
Extending Ethics and Cmpliance t Third Parties Managing Third Party Risk f Crruptin Octber 23, 2009 Diana M. Lutz, JD Greg Triguba, JD, CCEP 1 Our Jurney Review the rle f third parties in cnducting business
More informationWindham School District Procurement Policy for Federal Funds
1 f 5 Windham Schl District Prcurement Plicy fr Federal Funds DJB-FED The fllwing Prcurement Plicies shall apply t all Cntracts fr and Purchases f gds and services. All prcurements made with Federal funds
More informationAssessing the Impact of Proposed California Assembly Bill No on "Pay to Play"
Assessing the Impact f Prpsed Califrnia Assembly Bill N. 1743 n "Pay t Play" Cntributed by: Kenneth Muller, Thmas Devaney, and Seth Chertk, Mrrisn & Ferster LLP Califrnia Assembly Bill N. 1743 (Bill) passed
More informationCHARTER OF THE NOMINATING AND CORPORATE GOVERNANCE COMMITTEE OF THE BOARD OF DIRECTORS OF PLURALSIGHT, INC. Adopted May 3, 2018
CHARTER OF THE NOMINATING AND CORPORATE GOVERNANCE COMMITTEE PURPOSE OF THE BOARD OF DIRECTORS OF PLURALSIGHT, INC. Adpted May 3, 2018 The purpse f the Nminating and Crprate Gvernance Cmmittee (the Nminating
More informationPershing Financial Services Guide (FSG) including its Privacy Policy
Pershing Financial Services Guide (FSG) including its Privacy Plicy Issued by Pershing Securities Australia Pty Ltd ABN 60 136 184 962 Australian Financial Services License N. 338 264 Date FSG was prepared:
More informationUnderstanding Self Managed Superannuation Funds
Understanding Self Managed Superannuatin Funds Hw t read this dcument Managing yur finances t meet yur day t day requirements as well as yur lng-term gals can be a cmplex task. There are all srts f issues
More informationHuntington Bancshares Incorporated
Audit Cmmittee Apprved By: Bard f Directrs Huntingtn Bancshares Incrprated Apprval Date 1 f 6 Purpse f Cmmittee The Audit Cmmittee (Cmmittee) is established by the Bard f Directrs (Bard) t assist the Bard
More informationCMMI Institute Code of Professional Conduct, Version 1.0
CMMI Institute Cde f Prfessinal Cnduct, Versin 1.0 CMMI Institute COPC V1, 2015 1 CONTEXT... 2 1.1 PURPOSE... 2 1.2 PERSONS TO WHOM THE CODE APPLIES... 2 2 PRINCIPLES... 3 2.1 PROFESSIONALISM... 3 2.2
More informationAudit and Risk Management Committee Charter
Audit and Risk Management Cmmittee Charter Pivtal Systems Crpratin ("Cmpany") 1. Objectives The Audit and Risk Management Cmmittee (Cmmittee) has been established by the bard f directrs (Bard) f the Cmpany.
More informationClub and Organization Conduct Procedures
Club and Organizatin Cnduct Prcedures Purpse The purpse f the Student Cde f Cnduct ( Cde ) is t maintain the general welfare f the University cmmunity and supprt cmmunity safety and student grwth by helping
More informationA-1110 Wien. Privacy Notice
Eurfins Lebensmittelanalytik Tel. +43 (1) 944 33 44-0 ffice@eurfins.at www.eurfins.at Privacy Ntice Table f cntents 1 Cntrller infrmatin... 2 2 What infrmatin shuld yu give Eurfins?... 2 3 Why d we use
More informationLIVINGSTON COUNTY I. POLICY 1. PURPOSE:
LIVINGSTON COUNTY LIVINGSTON COUNTY, MICHIGAN RESOLUTION # 2017-05-081 APPROVED: MAY 1, 2017 1. PURPOSE: I. POLICY Livingstn Cunty places the highest value n the safety and health f its emplyees and the
More informationSTATE OF NEW YORK MUNICIPAL BOND BANK AGENCY
STATE OF NEW YORK MUNICIPAL BOND BANK AGENCY Recvery Act Bnd Prgram Written Prcedures fr Tax Cmpliance and Internal Mnitring, adpted September 12, 2013 PROGRAM OVERVIEW The State f New Yrk Municipal Bnd
More informationInformation concerning the constitution, goals and functions of the agency, including 1 :
Annual Reprt cmpliance checklist This checklist utlines the gvernance, perfrmance, reprting cmpliance and prcedural requirements f the Financial Administratin and Audit Act 1977 and the Financial Management
More informationHOC Works Program Requirements
HOC Wrks Prgram Requirements Last Revisin: March 2018 INTRODUCTION The Husing Opprtunities Cmmissin f Mntgmery Cunty (HOC) established the HOC Wrks prgram in 2015 in rder t guarantee that HOC emplyment
More informationPlease Note: It is your sole responsibility to review and understand your employer's policies
MICROSOFT RETAIL EXPERTZONE PROMOTION OFFICIAL RULES Please Nte: It is yur sle respnsibility t review and understand yur emplyer's plicies regarding yur eligibility t participate in trade prmtins such
More informationNCTJ Conflicts of Interest Policy and Procedures
NCTJ Cnflicts f Interest Plicy and Prcedures Purpse This plicy aims t draw attentin t the pssibility f cnflicts, minimise r prevent a cnflict ccurring and manage cnflicts that have arisen. Definitin f
More informationBACKGROUND CHECK DISCLOSURE DOCUMENT
NOTICE TO SAFESTHIRES CLIENT: The sample dcuments included in this PDF shuld NOT be cnstrued as legal advice, guidance r cunsel. Emplyers shuld cnsult their wn attrney abut their cmpliance respnsibilities
More informationPAYMENT BY CARD TERMS & CONDITIONS
PAYMENT BY CARD TERMS & CONDITIONS Versin 2.0 - June 2013 Effective frm 1 st June 2013 Issued n 1 st June 2013 Terms & Cnditins fr use f Credit/Debit card fr Payments (POS) Intrductin This Service is ffered
More informationPSNC Briefing on the NHS Complaints procedure (from 1 April 2009)
PSNC Briefing n the NHS Cmplaints prcedure (frm 1 April 2009) Under the prvisins f the Natinal Health Service (Pharmaceutical Services) Regulatins 2005 1 pharmacy cntractrs are required t make arrangements
More informationTerms of Reference - Board of Directors (approved by the Board on 12 April 2018)
Terms f Reference - Bard f Directrs (apprved by the Bard n 12 April 2018) 1. Respnsibility and Principal Duties The Bard f Directrs has the verall respnsibility fr the gvernance f the Cmpany and fr supervising
More informationBank Secrecy Act & USA Patriot Act
Bank Secrecy Act & USA Patrit Act Cmpliance Handbk Agent s Name Agent s Address City State Zip Cde Telephne N. Prvide by TRANSFAST as a training service fr its Agents 1 CONTENTS Intrductin 3 Applicable
More informationANTI-BRIBERY POLICY. Reviewed by: Finance and General Purposes Committee Approved: February 2017 Next review date: February 2021
ANTI-BRIBERY POLICY Reviewed by: Finance and General Purpses Cmmittee Apprved: February 2017 Next review date: February 2021 Cntents Intrductin 1 Scpe 1-2 Public Service Values 2-3 Plicy 3-5 Definitins
More informationPRIMERICA, INC. COMPENSATION COMMITTEE CHARTER Adopted on March 31, 2010 and revised as of August 15, 2018
PRIMERICA, INC. COMPENSATION COMMITTEE CHARTER Adpted n March 31, 2010 and revised as f August 15, 2018 Missin The Cmpensatin Cmmittee (the Cmmittee ) f Primerica, Inc. (the Cmpany ) is respnsible fr determining
More informationJOHN L. LITTLE, D.D.S, P.A ACKNOWLEDGEMENT OF RECEIPT OF NOTICE OF PRIVACY PRACTICES. May Refuse to Sign This Acknowledgement-
JOHN L. LITTLE, D.D.S, P.A ACKNOWLEDGEMENT OF RECEIPT OF NOTICE OF PRIVACY PRACTICES -Yu I, Privacy Practices. May Refuse t Sign This Acknwledgement- ---, have received a cpy f this ffice's Ntice f {Please
More informationCustomer due diligence guide for clients
Custmer due diligence guide fr clients Nvember 2018 19499409 2 As a reprting entity under the Anti-Mney Laundering and Cuntering Financing f Terrrism Act 2009 (the AML/CFT Act), MinterEllisnRuddWatts has
More informationPHILADEPHIA PROMOTING HEALTHY FAMILIES AND WORKPLACES ORDINANCE (PAID SICK LEAVE LAW)
PHILADEPHIA PROMOTING HEALTHY FAMILIES AND WORKPLACES ORDINANCE (PAID SICK LEAVE LAW) Eligibility Wrkers emplyed in Philadelphia fr at least 40 hurs in a calendar year (January 1 t December 31) will accrue
More informationTERMS OF REFERENCE FOR THE PROVISION OF OUTSOURCED INTERNAL AUDIT SERVICE
W&RSETA Standard Bidding Dcuments Terms f Reference TERMS OF REFERENCE FOR THE PROVISION OF OUTSOURCED INTERNAL AUDIT SERVICE 1 W&RSETA Standard Bidding Dcuments Terms f Reference 1. BACKGROUND TO W&RSETA
More informationCHARTER OF THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF PLURALSIGHT, INC. Adopted May 3, 2018
CHARTER OF THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF PLURALSIGHT, INC. Adpted May 3, 2018 PURPOSE The purpse f the Cmpensatin Cmmittee (the Cmpensatin Cmmittee ) f the Bard f Directrs (the
More informationNATCHITOCHES HISTORIC DISTRICT DEVELOPMENT COMMISSION STATE OF LOUISIANA
NATCHITOCHES HISTORIC DISTRICT DEVELOPMENT COMMISSION STATE OF LOUISIANA Independent Accuntants* Reprt n Applying Agreed-Upn Prcedures June 30, 2013 GRIFFIN & COAAPANY, LLC CERTIFIED PUBLIC ACCOUNTANTS
More informationEnvironmental Health & Safety Requirements for Master Agreement of Services
Envirnmental Health & Safety Requirements fr Master Agreement f Services If Cntractr emplyees will perfrm Services n any Michelin premises, Cntractr must cmply with the fllwing requirements: Cmply with
More informationTERMS AND CONDITIONS FOR APPOINTMENT OF INDEPENDENT DIRECTOR
TERMS AND CONDITIONS FOR APPOINTMENT OF INDEPENDENT DIRECTOR 1 PRIVATE & CONFIDENTIAL Date: T, Independent Directrs, Subject: Appintment as an Independent Directr InfBeans Technlgies Limited Dear Sir/Madam,
More informationFraud Prevention Policy and Procedure
1 Fraud Preventin Plicy and Prcedure 1. Aim The Library is cmmitted t taking all practicable steps t prevent all types f fraud within the rganisatin (internal fraud) and t prevent the rganisatin being
More informationCONSENT FOR TREATMENT
Thank yu fr chsing 2 nd Street Dental, LLC as yur dental prvider. We are cmmitted t yur treatment being successful. Please understand that payment f yur fees is cnsidered part f yur treatments. The fllwing
More informationHSBC USA INC. HSBC BANK USA, N.A. CHARTER OF THE COMPLIANCE COMMITTEE
HSBC USA INC. HSBC BANK USA, N.A. CHARTER OF THE COMPLIANCE COMMITTEE I. Cmmittee Purpse The Cmpliance Cmmittee (the Cmmittee ) is appinted by the Bards f Directrs f HSBC USA Inc. (the Crpratin ) and HSBC
More informationINDEPENDENT ACCOUNTANTS' REPORT ON APPLYING AGREED-UPON PROCEDURES
^001 GRIFFIN & COMPANY, LLC CERTIFIED PUBLIC ACCOUNTANTS Stephen M. Griffin, CPA Rbert J. Furman, CPA INDEPENDENT ACCOUNTANTS' REPORT ON APPLYING AGREED-UPON PROCEDURES T the Bard Members Atchafalaya Basin
More informationAnti-Bribery Corporate Policy
Anti-Bribery Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup and nn-emplyees, including agents,
More informationAPPLICATION TO CHANGE OR ADD A CORPORATE OFFICER OF A CORPORATION OR MEMBER / MANAGER OF A LIMITED LIABILITY COMPANY. General Instructions
NEVADA STATE CONTRACTORS BOARD 2310 Crprate Circle, Suite 200, Hendersn Nevada, 89074 (702) 486-1100 Fax (702) 486-1190 Investigatins (702) 486-1110 5390 Kietzke Lane, Suite 102, Ren, Nevada, 89511 (775)
More informationAMENDMENTS TO NASDAQ RULES ON COMPENSATION COMMITTEES
March 2013 AMENDMENTS TO NASDAQ RULES ON COMPENSATION COMMITTEES Summary. The Securities and Exchange Cmmissin recently apprved the fllwing amendments t the NASDAQ listing rules relating t cmpensatin cmmittees:
More informationIRDA Update: Draft Guidelines on Web Aggregators
IRDA Update: Draft Guidelines n Web Aggregatrs 17 March 2011 By way f an update, the IRDA has issued draft guidelines n web aggregatrs n 16 th March 2011. Cmments have been invited by 31 st March 2011.
More informationPREQUALIFICATION QUESTIONNAIRE (Ireland)
PREQUALIFICATION QUESTIONNAIRE (Ireland) COMPANY DETAILS 1.1 Please cmplete the cmpany details belw: Cmpany: Cntact: Address: Pst Cde: Tel: E-mail Title: CRN: VAT N: Website: 1.2 Des this Cmpany have a
More informationTerms and Conditions - UPAY Services JANUARY, Upay Department UNITED COMMERCIAL BANK LIMITED UCB.COM.BD UPAYBD.COM
JANUARY, 2019 Upay Department UNITED COMMERCIAL BANK LIMITED UCB.COM.BD UPAYBD.COM A. Intrductin 1. These terms and cnditins ("Terms") apply t and regulate yur use f United Cmmercial Bank Limited's (the
More informationThe UK Register of Trusts 21 December 2017
The UK Register f Trusts 21 December 2017 If yu are a trustee f a UK resident trust r f a nn-resident trust which has UK assets r UK surce incme yu may need t take actin befre 5 January 2018. Backgrund
More informationEMPLOYMENT APPLICATION LEE COUNTY GOVERNMENT P.O. Box 398 ATT: Human Resources Fort Myers, Florida (239)
PERSONAL INFORMATION EMPLOYMENT APPLICATION LEE COUNTY GOVERNMENT P.O. Bx 398 ATT: Human Resurces Frt Myers, Flrida 33902 (239) 533-2245 http://www.lee-cunty.cm JOB NUMBER: JOB TITLE: EXAM ID#: Received:
More informationINDEPENDENT ACCOUNTANTS' REPORT ON APPLYING AGREED-UPON PROCEDURES
d^^ GRIFFIN & COMPANY, LLC CERTIFIED PUBLIC ACCOUNTANTS Stephen M. Griffin, CPA Rbert J. Furman, CPA INDEPENDENT ACCOUNTANTS' REPORT ON APPLYING AGREED-UPON PROCEDURES T the Bard Members Luisiana State
More informationCorporate Governance Principles
Crprate Gvernance Principles Revised 05-03-2018 Amphenl s Crprate Gvernance Principles have been apprved by the Bard f Directrs and, tgether with the Cmpany s Certificate f Incrpratin, as amended and/r
More informationFAQs about North Carolina s Ethics and Lobbying Laws (Revised February 2013)
FAQs abut Nrth Carlina s Ethics and Lbbying Laws (Revised February 2013) Nrth Carlina has enacted a series f ethics and lbbying laws that significantly increased the state s regulatin f interactins between
More informationTHE CLOROX COMPANY AUDIT COMMITTEE CHARTER. [Effective May 8, 2017]
THE CLOROX COMPANY AUDIT COMMITTEE CHARTER [Effective May 8, 2017] PURPOSE AND AUTHORITY The Audit Cmmittee ( Cmmittee ) is established by the Bard f Directrs ( Bard ) fr the purpses f: 1. Representing
More informationTD Insurance s Multi-Year Accessibility Plan
TD Insurance s Multi-Year Accessibility Plan TABLE OF CONTENTS... 1 INTRODUCTION AND STATEMENT OF COMMITMENT... 1 OUR PLAN... 1 ACCESSIBILITY POLICIES...1 TRAINING...1 INFORMATION COMMUNICATION STANDARDS...2
More informationRelocation/Moving Procedures for New Employees
Relcatin/Mving Prcedures fr New Emplyees Purpse T prvide guidelines and restrictins regarding thse cases where relcatin csts are necessary fr an individual t accept emplyment with the University and t
More informationCITIGROUP INC. AUDIT COMMITTEE CHARTER As of January 18, 2018
CITIGROUP INC. AUDIT COMMITTEE CHARTER As f January 18, 2018 Missin The Audit Cmmittee ( Cmmittee ) f Citigrup Inc. ( Citigrup r the Cmpany ) is a standing cmmittee f the Bard f Directrs ( Bard ). The
More informationDPS Purchasing Practices, Policies and Ethics. June 17, 2017
DPS Purchasing Practices, Plicies and Ethics June 17, 2017 Purchasing What We D Acquire quality gds & services at best value fr District thrugh an pen cmpetitive bidding prcess Identify and establish a
More information2017 BUSINESS TAX ORGANIZER
2017 BUSINESS TAX ORGANIZER Instructins: The fllwing infrmatin is required fr preparatin f yur Business Tax Returns. Please fill ut this frm cmpletely and return it with the requested infrmatin fr yur
More informationAudit Committee Charter
Audit Cmmittee Charter I. Purpse f Audit Cmmittee The purpse f the Audit Cmmittee, which is part f the Bard, shall be (a) t assist the Bard s versight f (i) the integrity f the Cmpany s financial statements,
More informationAudit Committee Charter
www.subsea7.cm Audit Cmmittee Charter 5 23.May.17 Mark Fley VP Grup Financial Cntrller Dd Fraser Chairman f the Audit Cmmittee Revisin Revisin Date Dcument Owner Dcument Apprver Revisin: 5 Audit Cmmittee
More informationThe UK Register of Trusts 23 October 2017
The UK Register f Trusts 23 Octber 2017 If yu are a trustee f a UK resident trust r f a nn-resident trust which has UK assets r UK surce incme yu may need t take actin befre 5 December 2017. Backgrund
More informationThe Complaint Process and Your Responsibility
and Yur Respnsibility Lessn Objective: Understand the cmplaints prcess and yur rle as a cmmander. Desired Learning Outcmes (DLO): 1. Explain the rle f the IG in the cmplaints prcess. 2. Explain the duty
More informationOFFICE OF THE PRESIDENT HUMAN RESOURCES POLICY MANUAL SECTION 11 JULY 28, 2006 REDUCTION IN FORCE GUIDELINES
Purpse A reductin in frce is an actin t reduce the number f emplyees in a wrk unit r university-wide. A reductin in frce may becme necessary due t reduced funding, rerganizatin, change in wrklad, r ablishment
More informationBlackprint Ltd T/A Alloy Heat Treatment Purchasing Terms and Conditions
Blackprint Ltd T/A Ally Heat Treatment Purchasing Terms and Cnditins General These cnditins shall apply t all Blackprint Ltd rders, and are additinal t and withut prejudice t Blackprint Ltd. s right at
More informationD&B Compliance Verification
D&B Verificatin Safeguard yur business thrugh cmprehensive Checks Verify Business Partners Strengthen Crprate ~ Tday's business envirnment is becming increasingly regulated in a glbal attempt t enfrce
More informationWe process personal data for some or all of the following purposes depending on our relationship with the individual data subject:
PRIVACY POLICY Our purpses fr prcessing yur persnal data We prcess persnal data fr sme r all f the fllwing purpses depending n ur relatinship with the individual data subject: T adhere with all statutry
More informationProposal regarding the provision of administration services in respect of Isle of Man Companies
Prpsal regarding the prvisin f administratin services in respect f Isle f Man Cmpanies We understand that Alimentatin Cuch-Tard Inc (Client) is cnsidering the establishment f an Isle f Man cmpany (Cmpany).
More informationHow to Count Employees Determining Group Size Under the Medicare Secondary Payer Regulations
Hw t Cunt Emplyees Determining Grup Size Under the Medicare Secndary Payer Regulatins 1. Wh is an Emplyee? An emplyee is an individual wh wrks fr an emplyer r an individual wh, althugh nt actually wrking
More informationEmployment Application. Name: Last First Middle. Home ( ) Alternate( ) Type: i.e. cell phone, message, etc. Social Security No.
Tribal Lending Enterprise (TLE) a whlly wned Crpratin f the Habematlel Pm f Upper Lake 635 B E. Hwy 20 Upper Lake, CA 95485-0516 7300 Cllege Blvd., Ste. 650, Overland Park, KS 66210 D: (913) 717-4664 TF:
More informationAudit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd
Audit Cmmittee Charter St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Versin 3.0, 19 February 2018 Apprver Bard f Directrs St Andrew
More informationHow to Become a Delaware Public Benefit Corporation
Hw t Becme a Delaware Public Benefit Crpratin This utline describes the majr steps required fr an existing Delaware crpratin t becme a Delaware public benefit crpratin. 1. Summary. In rder t becme a public
More informationAlabama Department of Revenue Driver Or Vehicle Data Information Request
Alabama Interactive, Inc 104 Nrth Jacksn Street Mntgmery, AL 36104 (866) 353-EGOV www.alabamainteractive.rg subscriptins@alabamainteractive.rg Alabama Department f Revenue Driver Or Vehicle Data Infrmatin
More informationANTI-MONEY LAUNDERING AND COUNTERING TERRORISM FINANCING CORPORATE FRAMEWORK
ANTI-MONEY LAUNDERING AND COUNTERING TERRORISM FINANCING CORPORATE FRAMEWORK FINAL VERSION: JULY 2017 Page 1 f 12 TABLE OF CONTENTS 1) Intrductin 2) Definitin and scpe 3) Scpe f applicatin and implementatin
More informationGENERAL MOTORS COMPANY AUDIT COMMITTEE CHARTER. Amended and Restated: December 13, 2017
GENERAL MOTORS COMPANY AUDIT COMMITTEE CHARTER Amended and Restated: December 13, 2017 Purpse The purpse f the Audit Cmmittee is t assist the Bard f Directrs f General Mtrs Cmpany in its versight f the
More informationHawaii Division of Financial Institutions 2019 Renewal Checklist
Hawaii Divisin f Financial Institutins 2019 Renewal Checklist Instructins Renewal requests must be submitted thrugh by the date specified by yur state regulatr(s). Click here t review all renewal deadlines,
More informationHOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
January 1, 2014: NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. Centre
More informationPrivacy & Data Protection Policy
Privacy & Data Prtectin Plicy Whitby & District Fishing Industry Training Schl Limited and 54 Nrth Maritime Training ("Whitby Fishing Schl", WDFITS, 54 Nrth Maritime "we" r "us") are cmmitted t prmting
More informationBECCLES INDOOR BOWLS CLUB
. BECCLES INDOOR BOWLS CLUB PRIVACY NOTICE FOR OUR MEMBERS We are cmmitted t respecting yur privacy. This ntice is t explain hw we may use persnal infrmatin we cllect befre, during and after yur membership
More informationTraining Plan for Newly Elected Officials
Training Plan fr Newly Elected Officials Lines f Business: General Liability, Public Officials Liability www.tridentinsurance.net Suggested Prgram Elements: 1. Management Statement: Assign Training Respnsibilities
More informationGrant Application Guidelines
Grant Applicatin Guidelines The prgram staff f the Cmmunity Fundatin f Greater New Britain lks frward t wrking with yu. This frm is fr rganizatins that have submitted a Letter f Intent t us and were invited
More informationChapter 1. Introduction and Overview of Audit & Assurance
Assurance & Auditing Textbk Ntes Chapter 1 Intrductin and Overview f Audit & Assurance Audit prcess in Fcus 1.1 Auditing & Assurance Defined - An assurance is an engagement where an auditr r cnsultant
More informationSpecial School District (SSD) Effective Date: August, Overtime
Luisiana Department f Educatin Emplyee Plicies Special Schl District (SSD) Effective Date: August, 2015 Overtime ************************************************************************ Applicability This
More informationNebraska Total Care Notice of Privacy Practices
Nebraska Ttal Care Ntice f Privacy Practices PRIVACY NOTICE There are times we need t use yur medical infrmatin t help yu get care. This ntice tells yu hw medical infrmatin abut yu may be used. It tells
More informationNEENAH INC ETHICAL PURCHASING POLICY
NEENAH INC ETHICAL PURCHASING POLICY This Plicy was issued by Michael D. Wdy, Vice President U.S. Prcurement n December 1, 2011 Revised January 2018 Ethical Purchasing Plicy Sustaining an ethical prcurement
More informationDEPARTMENT: Patient & Financial POLICY DESCRIPTION: 501 (c)(3) Charity Care & Financial Assistance Policy & Procedures PAGE: 1 of 7
PAGE: 1 f 7 PURPOSE: This plicy is intended t cmply with the financial assistance and emergency care plicies required by Internal Revenue Sectin 501(r) and shall be interpreted t s cmply. This plicy applies
More informationORDER FORM FOR NOMINEE SERVICES - SINGAPORE OR HONG KONG COMPANY
Ntice: We are cllecting the infrmatin n this frm fr the purpse f administering yur accunt and prviding the services which yu are requesting. This infrmatin will be retained and used fr thse purpses and
More informationThis policy outlines the Company s guidelines, expectations and requirements related to:
COMMUNICATION & RELEASE OF INFORMATION POLICY #77 Intrductin This plicy utlines the Cmpany s guidelines, expectatins and requirements related t: Use f devices t capture phtgraphs, vide and/r audi while
More informationARIZONA FIRE DISTRICT ASSOCIATION FINANCIAL PROCEDURES POLICY
FINANCIAL PROCEDURES POLICY 1. PURPOSE The purpse f these Financial Prcedures is t prvide cnsistent applicatin f cnduct and prper internal cntrls t safeguard the assets f the Arizna Fire District Assciatin
More informationVIVINT SOLAR, INC. COMPENSATION COMMITTEE CHARTER. (Adopted as of May 9, 2014)
VIVINT SOLAR, INC. COMPENSATION COMMITTEE CHARTER (Adpted as f May 9, 2014) PURPOSE The purpse f the Cmpensatin Cmmittee (the Cmmittee ) f the Bard f Directrs (the Bard ) f Vivint Slar, Inc. (the Cmpany
More informationFINANCE & AUDIT COMMITTEE
FINANCE & AUDIT COMMITTEE Page 1 f 8 CHARTER f the Finance & Audit Cmmittee f the Bard Of Directrs f Spectral Medical Inc. Purpse The primary functin f the Finance & Audit Cmmittee (the Cmmittee ) f the
More information