Privé Aero ("Privé Aero", "we", "us" or "our") is committed to conducting business ethically and with integrity. We have zero tolerance for bribery and corruption in any form. This policy sets out our standards and applies to all directors, employees, agents, consultants, contractors and any third party acting for or on our behalf.
1. Purpose and Scope
The purpose of this policy is to set out our responsibilities, and those of everyone working with us, in observing and upholding our position on bribery and corruption, and to provide guidance on how to recognise and deal with these risks. It applies to all of our activities in Turkey and internationally.
2. Legal Framework
We comply with all anti-bribery and anti-corruption laws that apply to our business. Because we trade across borders, this includes the relevant provisions of Turkish law, and, where applicable to a transaction, international legislation with extraterritorial reach such as the UK Bribery Act 2010 and the United States Foreign Corrupt Practices Act. Breaches of these laws can lead to serious consequences for individuals and for the company, including fines and imprisonment.
3. What Is Bribery
A bribe is an inducement or reward offered, promised, given, requested or accepted to gain a commercial, contractual, regulatory or personal advantage improperly, or to reward the improper performance of a function or activity. Corruption is the abuse of entrusted power or position for private gain. Both are prohibited, whether they involve a public official or a private party, and whether they are direct or arranged through a third party.
4. Our Position
- You must not offer, promise, give, request, agree to receive or accept a bribe.
- You must not offer or accept any payment or benefit that is intended, or could reasonably be understood, to influence a decision improperly.
- You must not engage a third party to do anything that this policy prohibits.
- You must not threaten or retaliate against anyone who has refused to take part in bribery or who has raised a concern in good faith.
5. Gifts and Hospitality
This policy does not prohibit normal and appropriate business gifts and hospitality that are reasonable and proportionate, given openly and not intended to influence a decision improperly. Any gift or hospitality must be modest, infrequent, transparent, permitted under the recipient's own rules and properly recorded. Gifts or hospitality of more than nominal value require prior approval from management. Cash or cash equivalents must never be given or accepted.
6. Facilitation Payments and Kickbacks
We do not make and do not accept facilitation payments, that is small payments made to secure or speed up a routine action. We also prohibit kickbacks, that is payments made in return for a business favour or advantage. If you are asked to make such a payment, you must decline and report it.
7. Donations
We do not make political donations. Charitable donations are permitted only where they are lawful, ethical, made to a legitimate organisation, approved in advance and properly recorded, and never as a way of improperly influencing a decision.
8. Third Parties
Third parties acting for us can expose us to bribery risk. We carry out proportionate due diligence before engaging agents, intermediaries and suppliers, make our standards clear to them, and expect them to comply with this policy and with applicable law.
9. Record Keeping
We keep accurate and complete records of payments, gifts, hospitality and expenses so that they are transparent and can be reviewed. False, misleading or incomplete records are not permitted.
10. Raising a Concern
Everyone is encouraged to raise concerns about any suspected bribery or corruption at the earliest opportunity. Concerns can be reported to management or to sales@priveaero.com. We treat reports made in good faith seriously and confidentially, and we will not tolerate retaliation against anyone who raises a genuine concern, even if it turns out to be mistaken.
11. Consequences of Breach
Any employee who breaches this policy may face disciplinary action, up to and including dismissal. We may end our relationship with any third party that acts in a way inconsistent with this policy. Breaches may also result in criminal and civil liability for the individuals and organisations involved.
12. Review
We review this policy regularly and update it as needed to keep it effective and aligned with applicable law. Questions can be sent to sales@priveaero.com.