Anti-Bribery and Corruption Policy
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Anti-Bribery and Corruption Policy

Last Updated: March 31, 2023

Purpose, scope, and responsibility

The Anti-bribery and corruption policy establishes principles that must govern our conduct in order to: a) conform to the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and similar anti-corruption laws worldwide and b) more broadly, reinforce our intention and obligation to act honestly and ethically in all of our business dealings.
This policy applies to all partners and employees in wholly and majority-owned entities of Moriox.
The Chief Compliance Officer of Moriox is the final authority for this policy.
The Moriox Partners and Compliance Committee oversees the assessment of bribery and corruption risks across the enterprise, as well as, evaluating controls, consulting, and reporting to senior management and the board of directors regarding anti-bribery and corruption (AB&C) risks.

Policy statement

This policy applies to every entity related to Moriox and its employees, directors, officers, contractors, or any third party working on behalf of the company.
Bribery and corruption are not only against our company values; they are illegal and can expose both the employee and the company to fines and penalties, including imprisonment and reputational damage.
At Moriox, bribery is never permitted. We will not seek to influence others, either directly or indirectly, by offering, paying, or receiving bribes or kickbacks, or by any other means that is considered unethical, illegal, or harmful to our reputation of honesty and integrity. Employees and representatives of the company are expected to decline any opportunity which would place our ethical principles and reputation at risk. While certain laws apply only to bribes to government officials (domestic and foreign); this policy applies to non-government business partners as well.

Scope

Bribery is offering, giving, or receiving anything of value with the intention of inducing a person to act or to reward a person for having acted. This includes kickbacks—giving a payment to someone who helps facilitate a transaction. It’s important to understand that a corrupt act has occurred even if:

  • A bribe does not succeed.
  • A person authorizes or provides direction for a bribe, but no bribe is ultimately offered or paid.

    • “Anything of value” includes, but is not limited to:
  • Cash, cash equivalents (such as gift certificates/cards), stock, personal property, and assumption or forgiveness of a debt.
  • Gifts, meals, entertainment, and travel—any corporate travel, gifts, entertainment, and meals must be proportionate to the occasion and comply with the gift & entertainment policy/standards applicable to your location.
  • Political contributions.
  • Charitable contributions—if made to a charity at the direct request of a government official or private business partner, it could be considered an indirect bribe made in order to obtain or retain business or to secure other improper business advantage.
  • Job offers or internship awards—offers to government officials (or their relatives) can present a risk of violating anti-bribery or anticorruption laws and regulations.

    • Compliance must be consulted prior to making such offers. Corruption is dishonest or fraudulent conduct by those in power, typically involving bribery.