Anti-Corruption Policy

All GE3S members are committed to ethical business conduct in their global marketplaces and oppose corruption in all forms. Adhering to rules and guidance to uphold that commitment helps us prevent and reduce our exposure to incidents such as corruption, bribery, and other activity which conflict with the standards to which we are committed.  

Before client acceptance or engaging in a business relationship, various factors are considered in order to determine if there is risk related to non-compliance with anti-corruption policies or with other related ethical policies.  

Such risk may exist in situations where a client is involved in activities inconsistent with anti-corruption principles, whether or not connected to the subject matter of the specific service or business relationship our firm has entered. Such activities by clients or others may have implications for us as service providers or as a party to a business relationship.  

Whenever an indication of a potential infraction of these principles is encountered, immediate contact with the Quality and Risk Leader, Function Leader, or Risk Ambassador should be initiated for consultation and analysis of the case and the implications on engagement/relationship continuance and on our risk response.  

We strive to compete on the basis of the quality and value of our services. Personnel of the Firm should not offer or accept gifts or payments, or undertake inappropriate activities, to facilitate any engagements. Entertainment of our personnel or clients that is lavish or inappropriate in nature is also not permitted. In addition, you have an obligation to comply with our clients’ policies regarding gifts and entertainment. Gifts or entertainment should not be accepted or extended by our Firm’s personnel if they could be reasonably considered to:

• Improperly influence any business relationship with, or create an obligation to, a client, supplier,contractor, or alliance partner.
• Violate laws, professional standards and regulations, or this Code of Ethics and Professional Conduct.
• Constitute an unfair business inducement.
• Cause embarrassment to or negative impact upon our Firm.

Neither you nor any member of your immediate family should use your position with the Firm to solicit any cash, gifts, or free services from any client, supplier, contractor, or alliance partner for your or anyone else’s personal benefit.

• Nominal gifts that are usual and customary for the profession (e.g., pens, calendars, and mugs).
• Reasonable invitations (may be either extended or accepted) to business-related meetings, conventions, or conferences (e.g., a product-training seminar, a business luncheon or dinner).
• Invitations to social, sporting, or other events (may be either extended or accepted) if the cost is reasonable and attendance serves a customary business purpose (e.g., networking).

In all cases, you have a responsibility to know and understand our Firm’s detailed guidance on acceptable client entertainment, as well as the client’s own policies related to allowable gifts and entertainment involving their personnel.