Anti-bribery Policy


The purpose of the Anti-Bribery Policy is to prevent violation of any and all national and international anti-bribery and anti-corruption laws and to extend the Best Practices of business ethics into all of our commercial dealings.


All employees, agents of the Company, joint-venture partners, or anyone else doing business in Aaron Thomas Company, Inc’s name, are required to comply strictly with all applicable anti-bribery and anti-corruption laws, and ethics. In essence, no employee shall make or promise to make, directly or indirectly, any payment of money or provide anything of significant value to any business or commercial entity which is for the purpose of inducing or influencing such person to act in any way to assist Aaron Thomas Company, Inc. or any Aaron Thomas employee in obtaining, facilitating, or retaining business, or securing any improper business advantage in the marketplace.


The corporate policy is to abide by all laws applicable to the jurisdictions in which it operates, and it expects anyone doing business on its behalf to also comply with those laws. This policy applies to all individuals working at all levels and grades, including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, and any other person providing services to us.

The components of the Anti Bribery Policy are set-forth in detail below.

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must comply strictly with sound judgment and reason in respect of gifts and hospitality. We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a business decision, judgment of public officials, or third party auditors in the performance of their duties.

Facilitation Payments and Kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.

Record Keeping

We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

All expense claims relating to hospitality, gifts or expenses incurred to third parties must be 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, must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Raising Concerns

Employees will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, kickbacks, or fraudulent business practices even if they turn out to be mistaken.


The effectiveness of this policy will be regularly reviewed by the Board. Internal control systems and procedures will be subject to audit under the internal audit process.