ANTI-CORRUPTION POLICY
Lakshmi Green Ship Recyclers LLP is committed to the prevention, deterrence, and detection of fraud, bribery, and all other corrupt business practices. It is Lakshmi Green Ship Recyclers' policy to conduct all of its business activities with honesty, integrity, and the highest possible ethical standards and vigorously enforce its business practice, wherever it operates throughout the world, of not engaging in bribery or corruption.
APPLICABLE ANTI-CORRUPTION LAWS AND KEY PROVISIONS
The applicable Anti-Corruption Laws under the Indian Statutory Framework are as follows:
RESTRICTED PRACTICES
List of acts /practices which are restricted/prohibited under the policy framework is given below:
Dishonest Misappropriation of Property/Money
Criminal Breach of Trust
Cheating
Receiving or Giving Bribe
(I) Gifts and representative expenses including the hospitality business expenses which the employee may provide on behalf of the Company to the individuals or organizations, or which the employees may receive in connection with their work in the Company from other persons and organizations, must meet a set of five criteria mentioned below:
(a) to be directly related to the legitimate activity of the Company, for example, a presentation or completion of the business project(s), or the successful execution of contracts, or either with common holidays such as the Christmas, Diwali, New Year, anniversaries, birthdays;
(b) to be reasonable, proportionate and not be a luxury;
(c) to be not a hidden fee for the service, act, omission, conniving, protection, provision of rights making of certain decision on transaction, agreement, license, permit, etc. or attempt to influence the recipient to indulge in any illegal or unethical activity;
(d) not to create reputational risk for the Company, employees, and other persons, in case of disclosure of information on gifts or representative expenses.
PROCEDURE FOR REPORTING OF VIOLATIONS
I. Reporting against Employees /Officials/ Other Persons (including Partners/Representatives) When any employee or other persons doubt the legality or ethics of their actions or the action, inaction, violation, deficiencies or proposals of other employees, contractors or other persons, who act on behalf of Lakshmi Green Ship recyclers LLP, they may report it by the following mode(s):
(a) E-Mail: aniljain8040@hotmail.com
(b) Telephone: +91 9825208040
(C) Direct Reporting: to Head of the Department of respective employee and/or to the Managing Director.
RECORD-KEEPING
Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to Third Parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts will be kept “off-book” to facilitate or conceal improper payments and the same is ensured through effective monitoring and auditing mechanisms in place.
No retaliation or protection of privacy will be insured to any employee reporting such acts.
WAIVER AND AMENDMENT OF THE POLICY
We are committed to continuously reviewing and updating our policies and procedures based on learning. This is so even when Lakshmi Green Ship Recyclers LLP enters new market/ sector/ country which may pose a risk under this Policy. The team will monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.