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 Working with Customers and Suppliers |
No matter how high the stakes, no matter how great the "stretch", Jacques de Nissi (EXIM) will do business only by lawful and ethical means. When working with customers and suppliers in every aspect of our business, we will not compromise our commitment to integrity.
- Improper Payments Policy Overview
Jacques de Nissi (EXIM) employees should not offer anything of value to obtain any improper advantage in selling goods and services, conducting financial transactions or representing the Jacques de Nissi (EXIM) interests to governmental authorities. This policy sets forth Jacques de Nissi (EXIM) standards of conduct and practices for certain kinds of payments, entertainment and political contributions. Jacques de Nissi (EXIM) must not authorize, involve itself in or tolerate any business practice that does not follow this policy.
A violation of this policy can result in severe civil and criminal penalties. All countries prohibit the bribery of their own public officials, and many also prohibit the bribery of officials of other countries. Jacques de Nissi (EXIM) policy goes beyond these laws and prohibits improper payments in all of our activities, both with governments and in the private sector.
Core Requirements
- Never give, offer, or authorize the offer, directly or indirectly, of anything of value (such as money, goods or a service) to a customer or government official to obtain any improper advantage. A business courtesy, such as a gift, contribution or entertainment, should never be offered under circumstances that might create the appearance of an impropriety.
- This policy does not prohibit lawful reimbursement for reasonable and bona fide expenditures - for example, travel and living expenses incurred by customers and directly related to the promotion of products or services, or to the execution of a contract.
- Never give a gratuity or other payment to government officials or employees to expedite a routine administrative action without consulting with the Jacques de Nissi (EXIM) Business Legal Counsel. If such a "facilitating payment" is made, make sure it is clearly and accurately reflected in financial reports.
- Require any person or firm who represents Jacques de Nissi (EXIM) (such as a consultant, agent, sales representative, distributor or contractor) to comply with this policy and related laws.
- Exercise due diligence when selecting persons or firms to represent Jacques de Nissi (EXIM).
What Jacques de Nissi (EXIM) Employees Are Urged To Watch For
Any person or firm representing Jacques de Nissi (EXIM) or being considered to represent Jacques de Nissi (EXIM) who:
- Has been accused of improper business practices.
- Has a family or other relationship that could improperly influence the decision of a customer or government official.
- Approaches you near an award decision and explains that he or she has a special arrangement with a government official or the customer.
- Insists on receiving a commission payment before the announcement of the award decision.
- Any person who suggests that a Jacques de Nissi (EXIM) bid be made through a specific representative or partner
- Any request that a commission or other payment be made in a third country or to another name
- International Trade Controls Policy Overview
Many countries regulate international trade transactions, such as imports, exports and international financial transactions, for a variety of reasons, including national security and foreign policy.
Core Requirements
- Follow relevant international trade control regulations, including licensing, shipping documentation, import documentation, reporting and record retention requirements of all countries in which you conduct business or in which your business is located. In some cases, these restrictions will apply to international trade in goods, technology, software and services as well as to financial transactions. Learn and follow your business own procedures regarding international transactions.
- Make sure all international transactions are screened against all applicable laws and regulations that restrict transactions with certain countries and persons.
- Make sure all international transactions are screened against all applicable laws and regulations that restrict transactions with certain countries and persons.
- Consult with company Business Legal Counsel or your manager in any transaction in which a conflict arises with the law of another country or region.
- Understand which party to the import transaction bears legal responsibility for the accuracy of import documentation. Where Jacques de Nissi (EXIM) bears legal responsibility, establish procedures to monitor and verify the accuracy and completeness of information presented to government authorities by Jacques de Nissi (EXIM) or by Jacques de Nissi (EXIM) agents. Where an agent or customer is the responsible party, ensure that Jacques de Nissi (EXIM) provides the full and accurate information the other party needs to complete import documents.
What Jacques de Nissi (EXIM) Employees Are Urged To Watch For
All transactions:
- Unfamiliar customer without convincing references.
- Unusual transaction or application for this consignee, customer, end use or location.
- Evasive, reluctant or otherwise unsatisfactory answers by a customer to questions about end use, end user, delivery dates or delivery locations.
- Unusually favorable payment terms.
- Lack of concern for normal training and warranty service.
- Freight forwarder listed as ultimate consignee.
- Abnormal packing, marking or routing of goods.
- Unusual security or safety measures.
- Links to the military that seem inappropriate to the stated business or to the transaction.
- Involvement of parties related to countries engaged in the development of biological, chemical or nuclear weapons, or ballistic missiles.
- Transactions involving an embargoed country, a citizen or representative of an embargoed country or an individual or entity subject to government sanction.
Imports:
- An invoice price that does not reflect the full value of the imported goods.
- Any payment to the exporter or benefiting the exporter that is not included in the invoice price or otherwise reported to customs authorities.
- Transfer prices between related parties that fail to cover all costs and profits.
- Inaccurate or incomplete invoice description of the imported goods.
- Inaccurate identification of country of origin of the imported goods.
- Use of an import tariff classification that does not appear to be an accurate description of the imported goods.
- Any time Jacques de Nissi (EXIM) is designated as the importer of record in a country that does not have an established Jacques de Nissi (EXIM) import process.
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- Money Laundering Prevention Policy Overview
People who are involved in criminal activity (for example, narcotics trafficking, bribery and fraud) may try to "launder" the proceeds of their crimes to hide them or to make those proceeds appear legitimate. More than 100 countries now have laws against money laundering which prohibit the acceptance or processing of the proceeds of criminal activities.
Jacques de Nissi (EXIM) is committed to complying fully with all applicable anti-money laundering laws throughout the world. Jacques de Nissi (EXIM) will conduct business only with reputable customers who are involved in legitimate business activities and whose funds are derived from legitimate sources. Each Jacques de Nissi (EXIM) business is required to implement a "Know Your Customer" procedure and to take reasonable steps to ensure that the company does not accept forms of payment that have been identified as means of laundering money. Jacques de Nissi (EXIM)’s integrity and reputation can be severely damaged by failing to detect those customer relationships and transactions that place us at risk.
Core Requirements
- Comply with all applicable laws that prohibit money laundering and that require the reporting of cash or other suspicious transactions. Understand how both types of laws apply to your business.
- Follow your business' "Know Your Customer" procedure. Each business has a due diligence process, tailored to its particular business environment, to obtain enough information and documentation about prospective customers, joint venture partners and affiliates to ensure that they are involved in legitimate business activities and that their funds come from legitimate sources.
- Follow your business' rules concerning acceptable forms of payment. Learn how to identify the types of payments that have become associated with money laundering activity (for example, multiple money orders or travelers checks, large amounts of cash, or checks on behalf of a customer from an unknown third party) and follow the rules that restrict or prohibit acceptance of them.
- Learn to identify and carefully watch for warning signs that may indicate money laundering or other illegal activities or violations of Jacques de Nissi (EXIM) policies.
- If you encounter a warning sign, raise your concern with company Business Legal Counsel and be sure to resolve your concern promptly before proceeding further with the transaction. Resolution should include management review and should be well documented.
What Jacques de Nissi (EXIM) Employees Are Urged To Watch For
A customer, agent or proposed joint venture partner who is reluctant to provide complete information, provides insufficient, false or suspicious information, or is anxious to avoid reporting or record-keeping requirements
- Payments by use of monetary instruments that are not consistent with the business activities of the client, appear to have no identifiable link to the customer, or have been identified as money laundering mechanisms
- Requests by a customer, agent or proposed joint venture partner to pay in cash
- Early repayment of a loan in cash or cash equivalents
- Orders or purchases that are unusual or inconsistent with the customer's trade or business
- Unusually complex deal structures, payment patterns that reflect no real business purpose, or unusually favorable payment terms
- Unusual fund transfers to or from foreign countries unrelated to the transaction
- Transactions involving locations that have been identified as tax havens or areas of known money laundering activity
- Structuring of transactions to evade record-keeping or reporting requirements (for example, multiple transactions below the reportable threshold amounts)
- Wire transfer activity that is not consistent with the business activities of the customer or that originates or terminates with unrelated parties to the transaction
- Requests to transfer money or return deposits to a third party or to an unknown or unrecognized account.
- Privacy Policy Overview
In our increasingly information-based society, individual consumer, medical, financial and other sensitive personal information must be adequately protected. Jacques de Nissi (EXIM) is committed to protecting personal information that we collect from or maintain about individual consumers. Each employee must take care to protect individually identifiable consumer information and other sensitive personal information from inappropriate or unauthorized use or disclosure, and each Jacques de Nissi (EXIM) business must implement fair and responsible privacy and information protection procedures and take reasonable steps to ensure compliance with such procedures.
Core Requirements
- Comply with all applicable privacy and data protection laws, regulations and treaties.
- Provide individual consumers, as required by law or by your business' privacy policies, with: and by your business' privacy policies, with:
- notice of relevant privacy policies practices.
- descriptions of the types of information being collected and the uses to be made of the information.
- choices regarding certain uses of the information by your business.
- access to the information for verification and correction.
- security for the information.
- Learn and follow your business' implementing procedures for privacy and data protection. Pay particular attention to the protection of individual consumer information, medical and financial records, and other sensitive personal information, such as information from or about children.
- Do not acquire, use, or disclose individual consumer information in ways that are inconsistent with your business' privacy policies or with applicable laws or regulations. If you have access to individual consumer information, use that information only for authorized business purposes.
- Keep secure your business' records of individual consumer information, including computer-based information.
- Consult with Business Legal Counsel before establishing or updating any system, process, or procedure to collect, use, disclose, or transmit individual consumer information, medical or financial records, or other sensitive personal information
What Jacques de Nissi (EXIM) Employees Are Urged To Watch For
Business or marketing plans that involve the inappropriate or unauthorized collection, use or disclosure of individual consumer information
- Privacy policies or notices that are inaccurate or out-of-date
- Disclosures of (or requests to disclose) individual consumer information, particularly sensitive personal information, to unaffiliated third parties who are not properly authorized to receive the information
- Transfers of individual consumer information to third parties, such as vendors or suppliers, who lack appropriate security safeguards or appropriate restrictions regarding their use of the information
- Transfers of individual consumer information between countries
- Inadequate information security controls, such as those that could permit unauthorized access to individual consumer information.
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- Supplier Relationships Policy Overview
Jacques de Nissi (EXIM) bases its relationships with suppliers on lawful, efficient and fair practices. We also expect our suppliers to adhere to applicable legal requirements in their business relationships, including those with their employees, their local communities and Jacques de Nissi (EXIM). The quality of our supplier relationships often has a direct bearing on the quality of our customer relationships. Likewise, the quality of our suppliers' products and services affects the quality of our own products and services.
Core Requirements
Provide a competitive opportunity for suppliers to earn a share of Jacques de Nissi (EXIM)’s purchasing volume, including small businesses and businesses owned by the disadvantaged, minorities and women.
- Enlist supplier support in ensuring that Jacques de Nissi (EXIM) consistently meets and exceeds customer expectations of quality, cost and delivery.
- Do business only with suppliers who comply with local and other applicable legal requirements and any additional Jacques de Nissi (EXIM) standards relating to labor, environment, health and safety, intellectual property rights and improper payments.
What Jacques de Nissi (EXIM) Employees Are Urged To Watch For
Selection of suppliers on any basis other than open, competitive bidding
- Potential conflicts of interest in supplier selection, including the acceptance of gifts or other items of value except in strict compliance with business guidelines
- Directing business to a supplier owned or managed by a relative or close friend
- Unsafe conditions in supplier facilities, or workers who appear to be underage or subject to coercion
- Apparent disregard of environmental standards in supplier facilities
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