Octo considers corruption to be an intolerable obstacle to business efficiency and fair competition. To this end, Octo considers ethical integrity, full respect of the law and regulations and fairness to be constant commitments of all of its personnel.
In accordance with Octo’s Code of Ethics, Octo is committed to conducting our business fairly, honestly, and lawfully. As part of this commitment, Octo has a zero-tolerance policy towards bribery and corruption of any kind. This means Octo must comply with all applicable anti-bribery and corruption (“ABC”) laws that govern both our domestic and international operations, including:
– the Italian Decree 231/2001, and,
– the UK Bribery Act 2010 (“UKBA”), and
– the U.S. Foreign Corrupt Practices Act (“FCPA”.
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No questionable or illegal practice can ever be justified or tolerated, and no performance goal should be imposed or accepted if it can be achieved only by compromising ethical standards.
Octo Personnel who violate the ABC Policy and/or anti-corruption applicable laws will be subject to discipline, up to and including termination and to any other legal action to the extent necessary to protect Octo’s interests. No Octo Personnel will be subjected to demotion, penalty, or any other adverse consequence for refusing to make a prohibited payment, even if such refusal results in a loss of business or other adverse consequence to the business.
In compliance with the provisions of Octo’s Whistleblowing Policy (see below), Octo Personnel will not be discharged, demoted, suspended, threatened, harassed, or discriminated against, in any manner based upon any lawful and made in good faith reporting activity of such employee with respect to reporting of concerns regarding compliance with the current ABC Policy and/or the Anti-Corruption Laws.