Anti-Bribery and Anti-Corruption Policy

Last updated: June 28, 2024

1. Purpose

Calima (hereinafter referred to as “the Company”) is committed to conducting business ethically and with integrity. This Anti-Bribery and Anti-Corruption Policy outlines our stance against bribery and corruption, including prohibitions on providing illegal or improper bribes, kickbacks, payments, gifts, or anything of value to government entities and officials.

2. Scope

This policy applies to all employees, contractors, consultants, agents, and any other third parties acting on behalf of Calima (collectively referred to as “Personnel”).

3. Prohibitions

  • Bribery: Calima prohibits offering, promising, giving, requesting, or accepting any bribe, kickback, or other improper payment, directly or indirectly, to or from any person or entity, including government officials, to obtain or retain business or any improper advantage.
  • Gifts and Hospitality: Gifts, entertainment, or hospitality provided in the course of business dealings must be modest, reasonable, and in compliance with applicable laws and regulations. They should not be offered or accepted with the intention to influence business decisions or gain improper advantage.
  • Facilitation Payments: Calima strictly prohibits facilitation payments, which are small payments or gifts made to expedite routine governmental actions.

4. Compliance Obligations

  • Legal Compliance: Personnel must comply with all applicable laws and regulations regarding bribery and corruption, including but not limited to the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
  • Reporting: Personnel are encouraged to report any suspected violations of this policy to [Designated Compliance Officer or Department]. Calima prohibits retaliation against individuals who report concerns in good faith.

5. Training and Awareness

Calima provides regular training and resources to ensure Personnel understand their obligations under this policy and can identify and address bribery and corruption risks effectively.

6. Responsibilities

  • Management: Senior management is responsible for setting the tone from the top and promoting a culture of integrity and compliance throughout the organization.
  • Compliance Officer: The Compliance Officer is responsible for overseeing the implementation and enforcement of this policy, conducting risk assessments, and providing guidance to Personnel.

7. Consequences of Non-Compliance

Violations of this policy may result in disciplinary action, up to and including termination of employment or contract, and may also lead to civil or criminal liability for individuals and Calima.

8. Policy Review

This policy is reviewed periodically to ensure it remains current and effective in addressing bribery and corruption risks.

9. Adoption

All Personnel are required to acknowledge receipt, understanding, and compliance with this policy upon commencement of employment or engagement with Calima.