As a result of globalisation, companies often face frequent churns in workforce. This sometimes precludes optimum operational efficiency and to offset this challenge, MitKat can provide a wide range of managed services.
Commitment to Anti-Corruption+
MitKat Advisory Services Pvt Ltd does not pay nor does it allow paying bribes to anyone. Company employees are prohibited from giving or offering bribes, kickbacks, or similar payment or consideration of any kind, whether at home or abroad, to any person or entity (including but not limited to any customers or potential customers, government official, political party, candidate for political office or any intermediaries, such as agents, attorneys or consultants) in order to: influence official acts or decisions of that person or entity; obtain or retain business or a business advantage for, or direct business to, the company; and/ or secure any improper advantage.
MitKat Advisory Services Pvt Ltd also does not accept nor does it allow the acceptance or receipt of bribes from anyone. Company personnel are prohibited from accepting or receiving bribes, kickbacks, or similar payment or consideration of any kind, whether at home or abroad, from any person or entity which is intended to, or which may be perceived as being intended to: Influence one’s official acts or decisions; obtain or retain business or a business advantage for, or direct business to, the offer or of the bribe and/or any entity that he/she represents; and/ or secure any improper advantage for the offer or of the bribe and/or and entity that he/she represents.
Applicability of Foreign and Local Laws+
Besides the local laws on corruption and bribery, the United States Foreign Corrupt Practices Act (‘FCPA’) and the United Kingdom Bribery Act (‘UKBA’) may apply to MitKat Advisory Services Pvt Ltd and its employees. MitKat Advisory Services Pvt Ltd being an ethical company shall take all measures to comply with these laws and report any violation through the channels prescribed. Companies may conduct comprehensive research on the different laws and regulations of the countries in which they operate. Companies may also assign legal experts to review the design of the program with respect to its consistency with national and international laws. Special attention should be given to the extraterritorial requirements of some national laws.
Tone from the Top on Corruption: +
The management of MitKat Advisory Services Pvt Ltd appreciates the socio–economic environment in which it is functioning. The compliance of the anti-corruption law (including the FCPA and UKBA) needs to be followed in letter and spirit by all the stakeholders. Senior management at MitKat Advisory Services Pvt Ltd is committed to prevent corruption by instituting the following measures
- Zero-tolerance to corruption
- Development and implementation of an anti-corruption program.
- Trust based culture where ethical reporting by any employee is not seen with vindication.
- The rules and regulations are applicable to everyone, irrespective of his/her stature in the organization.
Applicability of the Anti-Corruption Programme+
At MitKat Advisory Services Pvt Ltd we invite our stakeholders to comment on our anti-corruption programme. Company members are prohibited from providing or receiving money, gifts, meals, entertainment or anything of value to any person or entity in connection with business unless it is provided or received in accordance with the following,
- The MitKat Advisory Services Pvt Ltd code of conduct,
- The MitKat Advisory Services Pvt Ltd policy on gifts, entertainment and other benefits, and its travel hosting policy.
Applicability and Expectations from Third-parties and Subsidiaries+
MitKat Advisory Services Pvt Ltd understands the significance of its relationships with third parties such as consultants, agents and referral partners. Notwithstanding, the Company and its management does not make any dispensations on the issue of improper payments made by these while performing services on the Company’s behalf, regardless of whether the company had any knowledge of the improper payments.
As a policy, MitKat Advisory Services Pvt Ltd and its subsidiaries shall only deal with third-party intermediaries who are prepared to apply the same standards of business conduct as MitKat Advisory Services Pvt Ltd does itself, in accordance to all the applicable laws (locally and globally).
Where third-party relationships are required, MitKat Advisory Services Pvt Ltd shall choose its agents, consultants, referral partners, resellers and other representatives after due diligence. Prior to entering into an agreement with any such third-party, appropriate due diligence must be performed in accordance with the Legal policies and procedures with regard to the due diligence and retention of third-party intermediaries by the company. Only those third parties who fit the criteria for an ethical relationship should be engaged.
Any third party found to be involved in unethical practices under the local and global laws shall be enquired and if found liable shall be terminated.
Anti-Corruption Training Programmes+
MitKat Advisory Services Pvt Ltd policy on training requires certain company personnel and third parties, depending on their job scope and risk exposure, to be trained on company’s anti-corruption training courses, which will be conducted by the management of MitKat Advisory Services Pvt Ltd or made available from an experienced compliance trainer from time to time.
Those required to take such course/s must do so within the notified timeframe and repeat the course as and when required.
MitKat Advisory Services Pvt Ltd shall devote appropriate resources for providing its employees with guidance and advice on how to comply with their own compliance program on an ongoing basis.
Policy on Gifting, Travel and Entertainment+
The company does not allow any kind of gifting or expenditures on employees and partners (including third parties) to be out of the approved policy.
All expenditures that are incurred on gifting, travel and entertainment must be recorded in account books and audited.
The company acknowledges that the giving and receiving of nominal benefits (such as small gifts, meals and entertainment) is a common business practice and is intended to strengthen and build long term business relationships. However, before a benefit (whether given or received) can be considered proper and legitimate under this Policy, certain criteria must be met.
In general, the benefit in question must:
- Be bona fide; moderate and reasonable;
- Not embarrass the organization by its nature;
- Be legal under the applicable Anti-corruption Laws;
- Be fully documented accurately in books and records.
Company’s Policy on Facilitation Payments+
The company has a clear stand on not providing or taking ‘Facilitating or grease payments’.
All such payments are illegal and not acceptable.
Company’s Policy for Non– Retaliation+
The company will not take any adverse action against anyone for providing truthful information relating to a violation of law or policy, and the Company will not tolerate any retaliation against persons asking questions or making good faith reports of possible violations of this Policy.
Anyone who retaliates or attempts to retaliate will be disciplined. Any person who believes he or she has been retaliated against should immediately follow the instructions in the company’s Whistleblower Policy.
Company’s Policy on Internal Reporting /Whistle-Blowing+
Company Personnel who are or become aware of or suspect a violation of this policy and/or the anti-corruption laws are under an obligation to report the same to the company. Under certain anti-corruption laws not reporting a known violation can result in criminal penalties and civil liability both for the company and for individuals. Violations or suspected violations should be reported by any of the following means.
In Person – Any employee or partner (including third party) who wishes to report a violation may choose to inform his superiors at work place irrespective of the chain of reporting. At MitKat Advisory Services Pvt Ltd, alternatively the Chief Executive Officer is nominated to deal with any complaints.
By phone – Any employee or partner (including third party) may connect to a specially established ‘Ethics-Line’ and report the violation either by disclosing their identity or anonymously. The number to be contacted is +91 22 28391243.
By Web/email – A special mail account (under the aegis of the Chief Executive Officer) has been created to report violations on matter of bribery and corruption. The mail id is firstname.lastname@example.org
Compliance Monitoring Mechanism+
The Chief Executive Officer is responsible for monitoring and reviewing benefits received and given on behalf of the company by company personnel.
Policy Pertaining to Political Contributions and Disclosures+
It is the organization’s policy that under no circumstances shall organizational funds be used to make political contributions to political parties or candidates in any country, even if such contributions are permitted by a country’s written laws or regulations. It must be clearly understood that no personnel from the organization can therefore make any sort of political contribution from organization funds under any circumstances whatsoever.
MitKat Advisory Services Pvt Ltd however does not discourage or prohibit personnel from voluntarily making personal political contributions or from participating in the political process in their own time and at their own expense or from expressing their personal views on legislative or political matters, or from otherwise personally engaging in political activities.
The organization shall carry out due-diligence in official dealing with politically exposed persons.