Anti-bribery and Corruption Policy
Policy Statement:
NPLH Drilling is committed to conducting its business ethically and in compliance with all laws and regulations pertaining to bribery and corruption. This Anti-Bribery and Corruption Policy outlines our zero-tolerance stance towards bribery and corruption in any form, both in our domestic and international operations.
Scope:
This policy applies to all employees, officers, directors, agents, consultants, contractors, and any other persons or entities acting for or on behalf of NPLH Drilling.
Prohibition of Bribery and Corruption:
- Strictly prohibit offering, giving, soliciting, or accepting any form of bribe or corrupt payment, either directly or indirectly.
- Ban facilitation payments made to expedite or secure performance of routine governmental actions.
Compliance with Laws:
- Comply with all applicable anti-bribery and anti-corruption laws, including but not limited to the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
Due Diligence:
- Conduct due diligence on third parties, agents, and partners to ensure compliance with this policy.
- Maintain accurate records of all business transactions.
Gifts and Hospitality:
- Regulate the offering and acceptance of gifts and hospitality to ensure they are not used as a disguise for bribery.
- Gifts and hospitality must be reasonable, transparent, and justifiable under the circumstances.
Reporting and Whistleblower Protection:
- Encourage employees to report any suspected bribery or corruption incidents.
- Protect whistleblowers from retaliation or adverse consequences for reporting in good faith.
Training and Awareness:
- Provide regular training to all relevant employees on anti-bribery and anti-corruption laws and practices.
- Promote a culture of integrity and ethical behavior.
Monitoring and Review:
- Regularly monitor and review the effectiveness of anti-bribery and anti-corruption measures.
- Implement improvements as necessary.
Disciplinary Actions:
- Take strict disciplinary action, up to and including termination of employment, against any employee who violates this policy.
- Terminate business relationships with any third-party violating this policy.
Record Keeping and Audit:
- Maintain accurate financial records and have internal controls in place to evidence the business reason for making payments to third parties.
- Regular audits to ensure compliance with this policy and the law.
Policy Review and Compliance:
- Review and update this policy annually to ensure its continued relevance and effectiveness.
- Ensure that all employees and relevant third parties are aware of and understand this policy.
This Anti-Bribery and Corruption Policy reflects NPLH Drilling’s unwavering commitment to integrity and transparency in all its business dealings. Our stance on corruption and bribery is clear: we do not tolerate it in any form, and we are dedicated to upholding the highest ethical standards.