Purpose
Wade Macdonald is committed to conducting its business ethically and in compliance with all applicable laws. This Anti-Bribery Policy outlines the principles and guidelines that all employees, agents, contractors, and representatives must adhere to in order to prevent bribery and corruption.

 

Scope
This policy applies to all individuals associated with Wade Macdonald, including employees, directors, consultants, contractors, agents, and representatives (collectively referred to as "Associates").

 

Prohibited Conduct
The Company prohibits the offering, giving, solicitation or acceptance of any bribe (whether cash or other inducement) to or from any person or company (wherever they are situated and whether they are a public official or body or private person or company), by any individual employee, agent or other person or body acting on behalf of the company, in order to gain any commercial, contractual or regulatory advantage for the company in a way that is unethical, or in order to gain any personal advantage (financial or otherwise) for the individual or anyone connected with the individual.

This policy prohibits any inducement that results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action that may not be solely in the interests of the company or of the person or body employing them or whom they represent.


Gifts, Hospitality, and Entertainment
All gifts, hospitality, or entertainment given or received must be reasonable, transparent, and in compliance with applicable laws. Associates must not offer or accept gifts, hospitality, or entertainment with the intention of influencing business decisions.

This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift on a festival or at another special time, providing they are customary in a particular market, are proportionate and are properly recorded.


Facilitation Payments
Facilitation payments are strictly prohibited. Associates must not make or receive payments to expedite routine actions or secure preferential treatment.