Anti-Corruption Compliance Program
The company is subject to Israeli anti-bribery laws and to the Organization of Economic Co-operation and Development’s Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
As such, the Board of Directors of the Company adopted a Compliance Program which applies a zero tolerance policy for acts of corruption and bribery. This policy applies to all of the Company’s actions and deals, in all countries, both independently and with business partners.
The object of the compliance program is to ensure the fulfillment of the applicable legal guidelines which prohibit, among other things, corruption in the Company and bribery of local and foreign civil servants. The Company’s acceptance of the compliance program expresses its commitment to conduct itself honestly and fairly on business matters and creates a foundation of norms for corruption prevention. By adopting these codes of conduct, and by establishing clear policies and control and supervision mechanisms, the Company aims to enter into competition for all business opportunities ethically and fairly, with meticulous attention to prevention of corruption and of bribery of foreign civil servants.
The program emphasizes, among other issues, prohibition on any payment which may be construed to be and/or form a basis for corruption, including bribery by the Company and its employees or anyone acting on their behalf (including business partners), gifts or hospitality the Company and its representatives are authorized to give and/or receive under various circumstances, as well as other benefits. In addition, the Compliance Program specifies which gifts and other benefits may be received or given, as well as a detailed donation policy.
Finally, the Compliance Program explains the failures and violations detection mechanism and disciplinary measures taken thereupon.
In light of the above, the Company’s Compliance Officer is on the level of a Vice President and reports to the CEO. It is his responsibility to supervise, integrate and monitor the execution of the compliance programs within the Company.