The purpose of the Anti-Corruption and Anti-Bribery Policy is to ensure compliance with all applicable anti‑bribery regulations and to ensure EP NL’s business is conducted in a socially responsible manner. EP NL is committed to conduct its business activities in a honest and ethical manner and expects the same of EP NL employees and business partners. EP NL and its shareholders do not tolerate any form of corruption, neither active nor passive, direct or indirect and work against corruption in all its forms. EP NL does not have business relationships with business partners who are known to be in violation of the principles underlying the Policy. EP NL’s golden rule is that it would rather lose a particular business opportunity than engage in illegal or unethical conduct.
The Policy sets principles for preventing corruption and bribery, including the KYC procedure and the “four-eyes” principle. The Policy strictly prohibits EP NL employees from engaging in any form of bribery (offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal or a breach of trust; this includes kickbacks, i.e. payments made in return for a business favor or an advantage), corruption (the abuse of entrusted power or position for private gain including any form of bribery) as well as facilitation payments (the payment of money or granting of other advantage to a Government Official for the purpose of expediting or facilitating the performance of a Government Official for a routine governmental action), regulates offering and accepting of gifts, hospitalities and other advantages, prohibits political contributions and sets rules for charitable contributions. The Policy also covers communication, training, concern raising, monitoring and review, as well as record keeping and sanctions.