Qnity is committed to conducting its business activities in accordance with all applicable laws and regulations that prohibit bribery or corruption. This prohibition against bribery and corruption is a cornerstone of Qnity’s commitment to conducting business in an ethical manner. In support of its commitment to integrity, Qnity expects all of its employees and business partners to abide by the anti-bribery and anti-corruption standards that Qnity has established as part of its ethics and compliance program.
Laws and Regulations
Qnity is committed to complying with all applicable anti-bribery and anti-corruption laws that apply to its business activities around the world, including but not limited to, the U.S. Foreign Corrupt Practices Act (“FCPA”), and U.K. Bribery Act and other anti-bribery and anti-corruption laws which may apply in relevant jurisdictions.
Code of Conduct
Qnity’s Code of Conduct, which defines the ethical principles which guide our business activities, contains a specific prohibition on bribes, kickbacks and other transfers of value that are illegal or improper. The Code of Conduct also contains a prohibition on using gifts or entertainment to improperly influence any business decision and sets forth specific guidelines on the types of business courtesies which are consistent with Qnity’s compliance expectations.
Business Partner Expectations
Qnity expects its business partners to abide by the same ethical standards with respect to bribery and corruption that apply to its employees. In order to make its business partners aware of these standards, Qnity has developed anti-bribery and anti-corruption compliance language for its written contracts with business partners and also requires certain business partners to sign compliance certifications. Qnity’s business partners must commit to conducting business in an ethical and responsible manner.
Compliance Reporting and Monitoring
Qnity makes various mechanisms available for its employees and business partners to report any concerns they may have about ethical business practices (including practices which may be suspected of violating anti-bribery and anti-corruption laws). These mechanisms include a confidential hotline for reporting concerns, which are reviewed by Qnity’s legal and compliance team. Qnity has a non-retaliation policy against anyone who makes a good faith report about an ethical concern. To the extent that Qnity determines that any employee has violated its anti-bribery and anti-corruption policies and procedures, that employee is subject to disciplinary action (including termination of employment). Qnity also conducts periodic audit and monitoring procedures to ensure that its business activities are being conducted in accordance with the anti-bribery and anti-corruption policies and procedures that it has established as part of its compliance program.
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