This page states Azari Holdings’ public policy position. Applicable law, contracts, regulatory requirements and more specific subsidiary procedures may impose additional or stricter requirements.
Prohibited conduct
Do not offer, promise, give, request or accept money, gifts, hospitality, employment, favours or another benefit intended to improperly influence a decision or reward improper conduct.
The prohibition applies even where the amount is small or an improper payment is described as customary practice.
Public officials and sensitive interactions
Interactions involving public officials, licences, permits, customs, procurement or regulatory decisions can create heightened corruption risk. Appropriate diligence, approvals and accurate records are required where the circumstances warrant them.
Facilitation payments should not be made merely to speed a routine official action. Genuine threats to health or safety should be handled as exceptional incidents and documented promptly.
Gifts and hospitality
Reasonable hospitality can support legitimate business relationships, but it must not be extravagant, secret, frequent or timed to influence a pending decision.
Cash and cash-equivalent gifts are particularly inappropriate. Local rules or operating-company procedures may set stricter limits.
Agents, advisers and other third parties
Azari must not use an intermediary to make a payment or provide a benefit that would be improper if Azari did it directly. Higher-risk intermediaries should receive proportionate diligence and clear contractual expectations.
Unusual commissions, vague services, offshore payment instructions, refusal to identify owners or pressure for undocumented payments are warning signs that require review.
Books, records and approvals
Payments and expenses must be recorded accurately enough to show their real purpose, recipient and authorisation. False descriptions, off-book funds and fabricated invoices are prohibited.
Documentation should be proportionate to the transaction but sufficient to support later review.
Concerns and response
Suspected bribery, solicitation of an improper payment or pressure to conceal a benefit should be raised promptly. Retaliation for good-faith reporting is inconsistent with Azari policy.
A credible concern should be assessed independently enough for the facts, preservation of evidence and any required legal or disciplinary response to be handled properly.