ICSI Anti-Bribery Code is a voluntary code. What are the various clauses of this code ?

ICSI had recommended the 'Corporate Anti-Bribery Code to be adopted voluntarily by the private sector, tacking the supply side of bribery in this sector. The Code is a document with 9 clauses for implementation and guideline instructions including model policies on Gift, Hospitality and Expenses, Purchase Procurement Policy and Guidelines for whistle-blower mechanism. The Code, once adopted by the Company, shall be applicable to the company and its: Board of Directors, Employees (full time or part-time or employed through any third party contract) Agents, Associates, Consultants, Advisors, Representatives and Intermediaries, and Contractors, Sub-contractors and Suppliers of goods and/or services. The Code outlines a systematic approach for the corporate entity to prevent bribery and counter 'Facilitation Payments', including third party gratification. Clause 1 - Adherence to Anti-Corruption Laws: The Company shall follow all 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, agency, 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 officials acts or refrains from acting in relation to the performance of officials 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 awareness-cum-training program as approved by its Board for all its employees, agents, associates, advisors, representatives, intermediaries, consultants, contractors, sub-contractors and suppliers. Clause 8 - Monitoring Mechanism for Anti-Bribery Code: The Company shall set up a 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. The disciplinary mechanism shall include: Nature of offence Penalty of the offence Competent Authority