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    • CamCo Global
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  • Projects
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    • #CCCLAB-PDX
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Anti-Corruption Compliance Plan


1. Introduction


  • Purpose: This Anti-Corruption Compliance Plan establishes the organization's commitment to conducting business ethically and in compliance with all applicable anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any relevant local laws.
  • Scope: This plan applies to all employees, officers, directors, agents, contractors, and any other individuals or entities acting on behalf of the organization (collectively, "Personnel").
  • Zero Tolerance: The organization has a strict zero-tolerance policy towards bribery and corruption in any form.


2. Core Principles

  • Integrity: We conduct business with honesty, transparency, and integrity.
  • Compliance: We comply with all applicable anti-corruption laws and regulations.
  • Accountability: We are accountable for our actions and adhere to the principles outlined in this plan.


3. Roles and Responsibilities

  • Board of Directors:
    • Oversees the implementation and effectiveness of the compliance program.
    • Sets the tone at the top by demonstrating a commitment to ethical conduct.


  • Senior Management:
    • Implements and enforces the compliance program.
    • Provides necessary resources and support for compliance efforts.
    • Ensures that business objectives are achieved ethically and in compliance with this plan.


  • Compliance Officer/Department:
    • Develops, implements, and maintains the compliance program.
    • Provides guidance and training to Personnel on compliance matters.
    • Monitors compliance activities and investigates potential violations.
    • Reports directly to senior management and the Board of Directors.


  • All Personnel:
    • Adhere to this plan and all applicable anti-corruption laws.
    • Report any suspected violations of this plan.
    • Cooperate fully with any internal or external investigations.


4. Risk Assessment


  • Process: The organization will conduct regular risk assessments to identify and evaluate potential corruption risks. This process will include:
    • Identifying high-risk countries, industries, transactions, and business relationships.
    • Evaluating the likelihood and potential impact of identified risks.
    • Documenting the risk assessment process and findings.

  • Factors to Consider:
    • Geographic locations with high levels of corruption.
    • Interactions with government officials.
    • Use of third-party intermediaries.
    • Political contributions and lobbying activities.
    • Gifts, hospitality, and entertainment expenses.
    • Charitable donations and sponsorships.
  • Frequency: Risk assessments will be conducted [Annually/Bi-annually/As needed].


5. Policies and Procedures

  • Code of Conduct: The organization's Code of Conduct outlines ethical principles and standards of behavior for all Personnel. It explicitly prohibits bribery, corruption, and other unethical practices.
  • Anti-Corruption Policy: This policy provides detailed guidance on complying with anti-corruption laws and outlines specific prohibitions, including:
    • Prohibition of offering, promising, or giving anything of value to a government official to obtain an improper business advantage.
    • Prohibition of accepting anything of value from any party in exchange for preferential treatment.
    • Restrictions on gifts, hospitality, and entertainment expenses.
    • Guidelines for political contributions and lobbying activities.
    • Procedures for due diligence on third-party intermediaries.
    • Requirements for accurate and transparent record-keeping.


  • Third-Party Due Diligence: The organization will conduct thorough due diligence on all third-party intermediaries, including agents, consultants, distributors, and joint venture partners. This process will include:
    • Assessing the third party's qualifications, reputation, and experience.
    • Verifying the third party's ownership and control.
    • Obtaining representations and warranties regarding compliance with anti-corruption laws.
    • Monitoring the third party's activities and performance.


  • Gifts, Hospitality, and Entertainment: The organization has established clear guidelines regarding the provision and acceptance of gifts, hospitality, and entertainment. These guidelines:
    • Require that all such expenses be reasonable, proportionate, and made in good faith.
    • Prohibit the provision or acceptance of anything of value that could be perceived as a bribe or kickback.
    • Require pre-approval for certain expenses, particularly those involving government officials.
    • Mandate accurate and detailed record-keeping of all expenses.


  • Facilitation Payments: The organization prohibits facilitation payments, which are small payments made to government officials to expedite routine administrative actions.
  • Donations and Sponsorships: All charitable donations and sponsorships must be reviewed and approved in advance to ensure they are made for legitimate purposes and do not violate any anti-corruption laws.


6. Training and Communication

  • Training Programs: The organization will provide regular anti-corruption training to all Personnel, particularly those in high-risk roles. Training programs will:
    • Explain the requirements of applicable anti-corruption laws.
    • Outline the organization's anti-corruption policies and procedures.
    • Provide guidance on identifying and reporting potential violations.
    • Be tailored to specific job functions and responsibilities.
    • Be conducted in person or online.


  • Communication: The organization will foster a culture of open communication and encourage Personnel to report any concerns or suspected violations. This will be achieved through:
    • Regular communication from senior management on the importance of ethical conduct.
    • Making the Anti-Corruption Compliance Plan and related policies readily available to all Personnel.
    • Establishing a confidential and anonymous reporting mechanism (e.g., a hotline).


7. Monitoring and Enforcement


  • Monitoring: The organization will monitor the effectiveness of its compliance program through:
    • Regular audits of financial transactions and business activities.
    • Reviews of compliance with policies and procedures.
    • Tracking of training completion rates.
    • Analysis of reports received through the reporting mechanism.

  • Reporting Mechanism: The organization has established a confidential and anonymous reporting mechanism (e.g., a hotline, email address, or web-based portal) for Personnel to report suspected violations of this plan.
  • Investigation: The organization will promptly and thoroughly investigate any reported violations. Investigations will be conducted by qualified personnel and in accordance with established procedures.
  • Disciplinary Action: Any Personnel who violate this plan will be subject to appropriate disciplinary action, up to and including termination of employment or business relationship.
  • Non-Retaliation: The organization prohibits retaliation against any Personnel who report suspected violations in good faith.


8. Record Keeping

  • The Organization shall maintain accurate and complete records of all financial transactions, interactions with government officials and third-parties, training programs, internal investigations, and other matters related to this Anti-Corruption Compliance Plan.


9. Review and Updates

  • This plan will be reviewed and updated [Annually/Bi-annually/As needed] to ensure its continued effectiveness and compliance with evolving legal requirements.
  • Updates will be communicated to all Personnel as necessary.


10. Certification

  • All Personnel will be required to certify their understanding of and compliance with this Anti-Corruption Compliance Plan [Annually/Upon hire].

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