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.
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.
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.
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.
Ellomeh Human Resource Servicesemployees are encouraged to report violations via the internal reporting lines or
using Ellomeh Human Resource Services ABC Policy to firstname.lastname@example.org.