ANTI-BRIBERY STATEMENT

ANTI BRIBERY STATEMENT

 

ZERO TOLERANCE STATEMENT ON ANTI-BRIBERY PRINCIPLES

Our values guide the way we behave as individuals and the way we do business. At the

heart of our values is Ellomeh Human Resource Services s’ Anti-Bribery & Corruption policy (“ABC Policy”).

Our ABC Policy states that we act with integrity, behaving honestly, prudently and responsibly, so

that we can continue to earn the trust of all our stakeholders.

Ellomeh Human Resource Services has a zero tolerance towards bribery and corruption,

regardless of the identity or position of the originator or recipient of the bribe.

Our Management expects all our employees to always do business in accordance

with the highest standards of ethical behavior and honesty.

This also means we are committed to the prevention, deterrence and

detection of bribery and corruption. Bribery and corruption are criminal offences and are

clear violation of our  ABC Policy. Engaging in behavior or activities contrary to

Ellomeh Human Resource Services ABC Policy, as well as all other applicable laws and regulations, violates our

promise to our stakeholders. We do not and will not pay bribes or offer improper

inducements to anyone for any purpose, nor do we or will we accept bribes or improper

inducements or anything that could be perceived as such and we have similar expectations

of our third parties and clients.

Our  zero tolerance principles towards bribery and corruption also apply to third

parties with whom Ellomeh Human Resource Services does business with or who are retained by

Ellomeh Human Resource Services to perform

services or deliver business for and on behalf of Ellomeh Human Resource Services. The Ellomeh Human Resource Services ABC Policy is  summarized below:

 

Bribery and facilitation payments

All forms of bribery and all actions that in our opinion give the appearance of offering or

accepting a bribe, including facilitation payments are prohibited.

 

Gifts and Entertainment

No Ellomeh Human Resource Services employee may offer or receive a Gift or an Entertainment,

regardless of its value, which in our opinion might create or give the appearance of creating

a conflict of interest, constitute an inducement or bribe, or violate applicable laws, regulations and/or

Ellomeh Human Resource Services ABC Policy. Any form of gifts, entertainment or other advantage offered and

received must be subject to an assessment on its acceptability and appropriateness

regardless of the amount or value.

 

Public Officials

Whilst our policies do not prohibit legitimate business interactions with Public Officials or

State-owned enterprises, these are subject to heightened attention and stricter conditions,

such as pre-approvals and lower limits.

 

Travel and Accommodation

Ellomeh Human Resource Services employees should generally not accept or offer travel and

accommodation related to corporate hospitality packages.

Political contributions/donations

Ellomeh Recruitment Services employees are not permitted to make gifts or political donations or to offer

entertainment to political parties or candidates for political office.

 

Charitable contributions

Ellomeh Recruitment Services employees should ensure that charitable contributions are made to bona fide

charities and are not used to conceal a bribe.

 

Recording and registration

Ellomeh Human Resource Services employees should ensure that expenses and payments related to third parties are

registered and accurately recorded in the financial books.

 

Violations

Ellomeh Human Resource Servicesemployees are encouraged to report violations via the internal reporting lines or

using Ellomeh Human Resource Services ABC Policy to compliance@ellomehhrs.com.

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