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SUMMARY
TM LC
Summary of main principles:
Tm lc nhng nguyn tc chnh:
Securitas believes in a free market for the provision of our services, in a free
and fair competitive environment. Consequently, within the Securitas business,
there is zero tolerance for any type of bribes, facilitation payments or other
improper benefits contrary to the Code, this policy, local laws and regulations,
industry standards or ethical codes in the countries in which we operate.
Securitas tin vo mt th trng t do i vic vic cung cp dch v ca mnh,
trong mt mi trng cnh tranh t do v cng bng. Do trong ton b h
thng doanh nghip thuc Securitas, s khng c bt k s khoan nhng no
i vi bt k hnh vi hi l, mua chuc hay nhng khon li ch khng chnh
ng khc nu n i ngc vi cc quy nh php lut, chnh sch ny, lut v
quy nh ca a phng, tiu chun cng nghip hay quy tc o c ti
nhng quc gia m chng ti hot ng.
Summary of main changes since last revision:
Tm lc nhng thay i chnh t s sa i sau cng:
This is the first Anti-corruption Policy in the new Policy Template. This version
of the Policy is based on GPG chapter 5.9 version date 2014-05-05.
y l bn chnh sch chng tham nhng u tin trong B mu chnh sch
mi. Phin bn ca chnh sch ny da trn GPG chng 5.9 phin bn ngy
05-05-2014.
1. BACKGROUND AND PURPOSE
NN TNG V MC CH
Securitas Values and Ethics (the Code) sets out principles for business ethics
that all Securitas entities, employees and directors (for the purpose of this
policy jointly referred to as Securitas Companies and Professionals) are
required to follow. The Code sets out main principles for, among other things,
fair competition and anti-trust, anti-bribery and anti-corruption (including
principles for entertainment and acceptable gifts), money laundering and
conflicts of interest.
1
Non-compliance with this policy and local laws and regulations may have very
serious consequences for Securitas as a Group as well as for all Securitas
Companies and Professionals themselves. Violations of this policy and the Code
are therefore never in the interest of Securitas and reporting all such practices as
well as offers or requests to provide any improper benefits will always serve the
Securitas Groups best interest.
Khng tun th chnh sch ny hay php lut v quy nh ca a phng c
th dn n hu qu rt nghim trng cho Tp on hay cho chnh tt c cc
cng ty v chuyn gia ca Securitas. V vy, vic vi phm chnh sch ny v
chnh sch Php lut, s khng bao gi c Securitas hng ng v vic bo
co v tt c cc hnh ng cng nh nhng ngh hoc nhng yu cu
nhm p ng bt k khon li ch khng chnh ng no u phi lun lun
phc v v li ch tt nht ca tp on Securitas.
In order to avoid even the suggestions of unlawful or unethical behaviour,
Securitas Companies and Professionals shall, at all times, exercise good
judgment and make every effort to avoid situations which may lead to an
impression or even a suspicion of corrupt behaviour.
trnh nhng ngh tri php lut hoc vi phm o c, cc cng ty v
chuyn gia ca Securitas nn, vo mi thi im phi c phn on tt v n
lc ht sc trnh nhng tnh hung c th dn n mt cm gic hoc thm
ch l mt s nghi ng v hnh vi tham nhng.
Anti-corruption legislation in certain countries has extra-territorial reach,
meaning that it also applies to acts performed outside of the country that
enacted the rules. Examples of such legislation are the US Foreign Corrupt
Practices Act (the FCPA) and the UK Bribery Act. As Securitas conducts
business within and from both the USA and the United Kingdom, the scope of
these acts applies also to Securitas Companies and Professionals in other
countries. This policy also seeks to ensure compliance with the principles of
these Acts and to preserve the spirit and intent of these Acts.
Lut chng tham nhng ca mt s quc gia c phm vi p dng vt ra ngoi
lnh th, ngha l n cng c p dng cho nhng hnh vi xy ra bn ngoi
t nc ban hnh o lut . V d nh lut chng tham nhng nc ngoi
ca Hoa K v o lut hi l ca Vng Quc Anh. V Securitas thc hin
hot ng kinh doanh trong phm c hai quc gia Hoa K, Vng Quc Anh v
nhng quc gia khc, nn phm vi ca nhng hot ng ny cng c p
dng cho nhng cng ty v chuyn gia Securitas nhng quc gia khc. Chnh
sch ny cng nhm m bo tun theo nhng nguyn tc, tinh thn v mc
ch ca nhng o lut ny.
Definition of Corruption/Bribery
nh ngha v tham nhng/Hi l
For the purpose of this Policy, corruption is defined as any act which is intended
to grant, offer or promise improper benefits or anything of value to induce the
abuse of someones entrusted power for illegitimate individual or group benefit
or advantage. Corruption includes a wide variety of behavior including bribery,
conflicts of interest and misuse of company assets.
Theo chnh sch ny, tham nhng c nh ngha l bt k hnh vi no nhm
mc ch chp nhn, ngh hoc ha hn nhng li ch khng chnh ng
hoc bt c th g c gi tr xui khin vic lm dng quyn c giao ph
cho c nhn bt hp php hay li ch hoc li th ca tp on. Tham nhng
bao gm mt lot cc hnh vi k c hi l, xung t li ch v lm dng ti sn
cng ty.
Bribery is generally defined as promising, offering or giving, receiving or
soliciting an undue advantage to a person or entity, either directly or through an
intermediary, in order that the person or entity should perform, or refrain from
performing, an act in breach of their business, public or lawful duties, but the
exact definition varies from country to country.
Hi l thng c nh ngha l vic ha hn, cung cp hoc cho i, tip
nhn hay ni xin mt li th qu mc cho mt ngi hoc mt t chc no,
hoc trc tip hoc thng qua trung gian, ngi hoc t chc thc hin,
hoc t chi khng thc hin, mt hnh vi vi phm hot ng kinh doanh, cng
ng hoc nhim v hp php ca h, nhng nh ngha chnh xc s ty theo
s thay i khc nhau gia cc quc gia.
The concept of a bribe or a corrupt behavior shall include the provision or
receipt of, as well as the facilitation of, for example:
Khi nim v mt hi l hay mt hnh vi tham nhng bao gm vic cung cp
hoc vic nhn, cng nh to thun li, v d:
Gifts or entertainment intended to influence the recipient to act in specific
way
.
Cc qu tng hoc s gii tr c nh gy nh hng n ngi nhn
hnh ng theo cch c th
It is not necessary that the benefit be given or offered to the person exercising
the power. It may also be given or offered to someone that can influence the
decision maker in different ways. Particular care should be taken when dealing
with government or public entity officials.
Khng cn thit phi cung cp hoc biu tng cho gii chc hu trch nhng
khon li ch no c. N cng khng cn thit phi cung cp hoc biu tng
cho mt ai m h c sc nh hng n vic ra quyt nh di bt k hnh
thc no. Cn c bit thn trng khi giao dch vi chnh quyn hoc cng
chc.
The definition of corruptive practices or bribery varies from country to country.
This policy is not in any way meant to allow procedures that are not legal
and/or not in line with business ethics in a Securitas country, but may
supplement and strengthen the requirements for a specific country with less
developed anti-corruption legislation.
nh ngha v nhng hnh vi tham nhng hoc hi l s thay i ty theo quc
gia. Chnh sch ny trong bt k trng hp no, u khng c ngha l cho
php cc th tc khng hp php v / hoc khng ph hp vi o c kinh
doanh ti quc gia m Securitas hot ng, nhng c th b sung v cng c
thm cc yu cu i vi mt quc gia c th c php lut chng tham nhng
km pht trin.
Allowed gifts and entertainment
Qu tng v s gii tr c cho php
Certain forms of business related gifts and entertainment may be necessary and
acceptable under local customs, provided that they are within the limits of this
policy and local laws and regulations and made in good faith. The standards for
what is appropriate will vary from country to country, but will always need to
be in compliance with local law, the Code and this policy.
Mt s hnh thc qu tng lin quan n hot ng kinh doanh v vui chi gii
tr c th l cn thit v c chp nhn theo phong tc a phng, min l n
1.GRP 08.4.3 Anti-corruption Policy 150121-002 Page 5
1.GRP 08.4.3 Chnh sch chng tham nhng 150121-002
The value of the benefit - great care should be taken with any benefits that
have more than an insignificant value
The position of the recipient - any type of gifts to public officials should
be considered with the utmost care
The group of recipients and how the benefit is offered - any benefits that
are not offered openly are normally not appropriate and benefits to
selected individuals should be considered with more care than benefits
offered to a whole group or category of people. Repeated invitations to or
from the same person(s) within a short period of time should be avoided.
Risk assessment
nh gi ri ro
Some of the jurisdictions in which Securitas operates face difficulties with
regard to corrupt practices and bribery. It is the responsibility of each
divisional/regional president and country president to continuously assess the
risk for any Securitas Companies or Professionals becoming involved in any
type of corrupt behavior, flag such risks in the organization (for example
through the annual Enterprise Risk Management Business Plan or through other
channels) and to adopt appropriate measures to ensure that this is avoided.
Mt s quyn ti phn ti nhng quc gia m Securitas hot ng c th s gp
mt vi kh khn lin quan n hnh vi tham nhng v hi l. y l trch
nhim ca mi ch tch khu vc v Ch tch cp quc gia nhm lin tc nh
gi ri ro ang n i vi bt k cng ty hoc chuyn gia no ca Securitas
bao gm bt k loi hnh vi tham nhng, nh l ri ro trong t chc (v d
thng qua k hoch Qun l Ri ro kinh doanh hng nm hoc thng qua cc
knh khc) v p dng cc bin php thch hp m bo rng iu ny
c trnh.
When entering new jurisdictions, committing to different types of cooperative
relationships or being involved in mergers or acquisitions of entities, all
Securitas Companies and Entities must ensure that a full assessment of the risks
for corruption, bribes and other improper benefits in the country or relationship
in question has been conducted. Due diligence procedures shall include
appropriate investigations of past and present anti-corruptive measures and the
overall risk exposure with regard to corruption and bribes for each acquisition
target or prospective partner. It shall be the responsibility of each project
manager or divisional/regional manager to ensure that such processes are
carried out routinely when commencing new relationships and continuously
throughout the relationship if and when warranted.
Khi gia nhp vo nhng ni p dng quyn ti phn mi, phi dung ha cc
hnh thc khc nhau v quan h hp tc hoc khi gii quyt cc thng v sp
nhp hay mua li doanh nghip chng hn, lm sao mi cng ty v cc n
v thuc Securitas phi m bo rng nh gi y v cc ri ro pht
sinh lin quan n tham nhng, hi l v li ch khng chnh ng khc trong
nc hoc mi quan h trong vn c tin hnh. Th tc thm nh bao
gm iu tra thch hp cc bin php chng tham nhng hin ti v qu kh v
cc nguy c ri ro tng th lin quan n tham nhng v hi l cho mi mc
tiu mua li hoc i tc tim nng. l trch nhim ca mi ngi qun l
d n hoc qun l khu vc/phng ban nhm m bo rng qu trnh c
1.GRP 08.4.3 Anti-corruption Policy 150121-002 Page 7
1.GRP 08.4.3 Chnh sch chng tham nhng 150121-002
Compliance with this policy by all Securitas Companies and Professionals will
be monitored and followed-up as part of the Securitas Enterprise Risk
Management process, which includes self-assessments, internal and external
audits and routine follow-up of all reported matters. This policy will be
reviewed regularly by Securitas.
Vic cc n v v nhn vin ca Securitas tun th theo chnh sch ny phi
c theo di nh mt phn ca qu trnh qun tr ri ro doanh nghip
Securitas, trong bao gm vic t nh gi, kim sot ni b v kim ton
c lp, cng nh vic theo di thng k cc vn c bo co. Chnh
sch ny s c xem xt thng xuyn bi Securitas.
8. REFERENCE TO A GUIDELINE
THAM KHO MT HNG DN
There are no specific guidelines separately issued related to this policy.
Khng c hng dn c th no c ban hnh ring bit lin quan n chnh
sch ny.
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