Anti-Bribery and Corruption Statement
It is VILХs policy and senior management commitment to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our relationships and business dealings and to implementing and enforcing effective systems to counter bribery.
Our policy is to set out a single anti-bribery and corruption standard that all employees must comply with, regardless of whether local law, customs or practices in some jurisdictions we operate in might permit something to the contrary.
VIL prohibits any member of staff and associated person from, directly or indirectly, offering, promising, soliciting, requesting, receiving or agreeing to receive bribes including facilitation payments, kickbacks, advantage or other inappropriate inducements in any form. It also prohibits the use of other routs or channels to provide or receive improper advantages to/from clients or other third parties.
This applies where the payment or other benefit amounts to a breach of reasonable expectation that a person involved, representing either public or private sector, will act in good faith, impartially, or in accordance with a position of trust. Importantly, both public and commercial bribery are covered.
Accordingly, where we engage third parties, including situations not associated with our professional activities as a financial institution, we have obligations to complete sufficient due diligence on such third parties to ensure that they are not acting corruptly, and to periodically monitor their performance to ensure ongoing compliance. In situations associated with higher risk of bribery and corruption, e.g. with respect to politically exposed persons and other officials, the enhanced due diligence is performed.
It is VIL’s policy not to engage any third party who we know or reasonably suspect of engaging in bribery or corruption practices.
We are determined to make all third parties we engage aware of the general terms of VIL Anti-Bribery and Corruption Policy and of their obligations to comply with it. VIL will strive to ensure all arrangements with third parties are subject to clear contractual terms including specific provisions requiring them to comply with minimum standards and procedures in relation to bribery and corruption.
It is VIL’s policy not to make donations or contributions to politicians, political parties or campaigns. Employees are not permitted to make any political contributions on VIL behalf. Any charitable donation is a subject of special scrutiny.
We realize that gifts, hospitality and entertainment may, in certain circumstances, represent a bribe. Therefore, all such payments and benefits must be made (received) in compliance with VIL’s gifts and entertainment policy.
VIL undertakes appropriate anti-bribery and corruption training and awareness-raising upon induction of new members of staff and on ad-hoc basis tailoring the respective programs to the specific risks associated with particular posts and functions.
A failure by an employee to comply with VIL’s Anti-bribery and Corruption Policy may lead to disciplinary action, up to and including termination of employment.
VIL is committed to ensure that employees can speak up with confidence if they have any concerns or need to ask for help. If they suspect or observe anything that they think might be in contravention of this Policy, they have an obligation to report it to the Compliance Officer. Alternatively, they can address their concerns directly to the respective non-executive director.
All reports raised will be taken seriously and, where appropriate, investigated in more depth. VIL will not tolerate retaliation in any form against anyone for raising concerns or reporting what they genuinely believe to be improper, unethical or inappropriate behaviour. All reports are treated confidentially.
VIL carries out regular, risk-based monitoring of its anti-bribery and corruption procedures.