Ameya, has recently joined as a Regional Sales Manager of a pharmaceutical company. He has been given a sales target for the year, which is unusually high as per his assessment. On surveying the market, however, he obser

ICSI Anti-Bribery Code To ensure that neither the company nor any of its employees, directors or authorized representatives indulge in bribery in any of their actions taken for and on behalf of the company in the course of economic, financial or commercial activities of any kind. Clause 1: Adherence to Anti-Corruption Laws The company shall follow all applicable anti-corruption laws applicable in India. Clause 2: Bribery in Private Sector The company or its employees, directors, agents, associates, consultants, advisors, representatives or intermediaries shall not involve in bribery. Clause 3: Facilitation Payments No facilitation payment shall be made by the company either directly or through its employees, directors, agents, associates, consultants, advisors, representatives or intermediaries. Clause 4: Bribery to Foreign Public Officials The company, either directly or through its employees, directors, agents, associates, consultants, advisors, representatives or intermediaries in the conduct of international business shall not offer, promise or give any undue pecuniary or other advantage, to a foreign public official, for that official or for a third party, in order that the official acts or refrains from acting in relation to the performance of official duties, in order to obtain or retain business or other improper advantage. Clause 5: Policy for Gifts, Hospitality & Expenses The company shall follow a policy for gifts, hospitality and expenses as approved by its Board. Clause 6: Whistle Blower Mechanism The company shall set up a Whistle Blower Mechanism as approved by its Board to enable its employees or others to raise concerns and report violation(s) of the Code. Clause 7: Anti- Bribery Training and Awareness Programmes The company shall put in place an annual Corporate Anti-Bribery Code awareness-cum training program as approved by its Board for all its employees, agent, associates, advisors, representatives, intermediaries, consultants, contractors, sub-contractors and suppliers. Clause 8: Monitoring Mechanism for Anti-Bribery Code The company shall set up mechanism as approved by its Board for regular monitoring of its Anti-Bribery Code. Clause 9: Sanctions for Non-compliance Any non-compliance of the Code is subject to disciplinary mechanism. The company shall set up disciplinary mechanism as approved by its Board, for non-compliance of any part of the Corporate Anti- Bribery Code.