Policy Statement
We at the Mollie Plotkin Group (“MPG”) implore our employees to adhere to ethical business practices. This includes compliance with the following Anti-Bribery Policy and all relevant Anti-Bribery laws. Following the Anti-Bribery Policy (“Policy”) is essential to upholding trust between our clients and fellow employees.
This policy also includes the prohibition of bribery when it comes to any government official (domestic or abroad), as well as commercial bribery committed by employees or third parties representing MPG.
If you have any questions or concerns regarding the terms or penalties of this policy, please contact info@mollieplotkingroup.com
Risk and/or consequences of non-compliance
Non-compliance will lead to civil and criminal penalties and reputational harm to MPG.
This policy is also incorporated into our Code of Business Conduct (COBC) and violation could lead to termination. Furthermore, third parties who do not adhere to the Policy are also subject to termination of all relationships with MPG.
Purpose
This Policy outlines the risks and responsibilities under the relevant anti-corruption laws and MPG policies. All Mollie Plotkin Group employees should conduct business in an ethical manner and understand the requirements of anti-bribery laws and best practices. The Policy will also inform you on how to report concerns regarding potential cases of bribery or corruption.
Scope
The Mollie Plotkin Group expects all employees and third parties working on the behalf of MPG to refrain from engaging in any form of bribery or corruption as defined by relevant laws and our Code of Business Conduct.
Third Parties
Any third parties (including subcontractors) which are representing The Mollie Plotkin Group are prohibited from making corrupt payments on the behalf of MPG. Any payments made to third parties must be conventional and reasonable depending on the good or service, and they must also be accurately recorded in the books and records of MPG.
Once a third party has begun to receive payments, it is the responsibility of the relevant employee to make sure that the third party’s activities and expenses remain compliant with anti-corruption laws and MPG policies.
Government Officials
Any and all third parties which interact with government officials, or other related entities, must be approved by upper management from within MPG. All agreements with third parties who intend on working with government entities must be recorded in writing and must include pertinent anti-bribery wording.
Red Flags
Any red flags raised during the review of a third party must be addressed to the MPG Legal Counsel, or upper management prior to beginning work with the third party.
Reporting Violations
If you have observed any misconduct in relation to this policy or others, please contact the Mollie Plotkin Group so that we can investigate these claims. Suspected violations will be looked over and may lead to disciplinary or even legal action.
Failure to report misconduct is a violation of this policy and code of business conduct which may result in disciplinary action or termination.
