Effective: 20 January 2020
Principles
Facilitation Payments with Anti-bribery
- Skylink abides by all applicable international as well as local laws in the countries we operate.
- We forbid bribery to anybody, including unjustified payments or kickbacks in any form, whether direct or indirect. This includes a prohibition on all bribes or facilitation of payments to speed up routine governmental transactions or secure business.
- Skylink recognizes that, in some cases, demands for bribes may be accompanied by a form of extortion, including possible loss of business, physical violence, etc. If Skylink employees or agents deem they are exposed to such demands, they must report the details to the Skylink’s management at earliest.
Gifts and Hospitality
- Skylink, in general, restricts receiving gifts or any benefits that might affect a business course, cause the inappropriate performance of an official duty, or compromise party’s fairness. It applies to our relationships with everyone, we deal in our work - suppliers, officials, etc.
- Skylink employees may agree to exchange a prudent hospitality during a business. It must, however, be warranted that any involved benefit is as a mere goodwill gesture and not in any way reciprocatory.
- Employees must never do a transaction in which the total value of gifts, entertainment, gratuities, etc., exceeds USD 50, as set by their general or country supervisors, unless a written approval is consented beforehand.
Note: Administration is required to maintain a local log all transactions above the pre-determined limits and keep them readily available for audit.
Vendors Selection
- Skylink engages a broad range of World Cargo Alliance - WCA network companies including full-service global transportation and logistics providers, and ISO-certified business partners to work on its behalf. These include agents, representatives, consultants, subcontractors, and suppliers. Skylink network is committed to openness and transparency in our businesses and assumes the same in response.
- We want all partners to apply principles and ethics, consistent with ours, including those related to anti-bribery and commitment to fair labor conditions. In case of a difference, we will in the first instance use our influence to seek remedial action. If this proves unviable, we reserve the right to withdraw from a business relationship.
- All fees, commissions, and terms of business relationships must represent appropriate and justifiable payment for legitimate goods and services rendered.
Fair Competition
- We compete fairly and honestly, observing all applicable anti-trust and competition laws. We are truthful in every detail concerning services when we advertise or solicit for business.
Personal Conflicts of Interest
- Skylink employees must avoid any real and perceived conflicts of interest. This includes, but is not limited to, involving in a direct or indirect competition with the company or helping anybody compete with Skylink using knowledge gained while working for it similarly, doing business on behalf of Skylink with a company from which we or a family member or another connected person may directly benefit without prior written approval of the relevant divisional management. Our employees also must not to have any self-interests (individually or through family) in companies that compete with or do business with
- Skylink except when an advance agreement is made with the manager. Any conflict of interest that does arise should be raised with your HR or Compliance Representative. It is acceptable for employees to possess shares in publicly traded companies.
Records and Books
- We maintain appropriate books and records that track our business transactions and activities for as long as required by the law.
Charitable Donations
- We will only donate to organizations that serve a legitimate public purpose and documented our donations transparently. We do not make donations to political parties and government officials.
Seeking Guidance and Reporting Problems
- Employees must consult HR or Compliance representative for guidance on this Code.
Compliance and Implementation
The principles laid in this policy are applicable to all Group member companies
including, associates, agents, and joint ventures involving Skylink Group and are endorsed
by the Skylink network Board of Directors.
It is the responsibility of senior management to ensure that they are disseminated and
fully understood at every level throughout the Group.
The violations of this policy will be taken seriously. Further, employees will not be
criticized or penalized by Skylink for any loss of business as a result of either
adherence to these principles or reporting any concerns thereof in good faith, even if the
reports are not supported after the investigation.
Responsibility
The Global Code of Ethics shall be implemented by the Human Resources Department or Compliance Administrator to maintain the ethics measurements set out within the Skylink Network.
Compliance and Review
The Administration is responsible for establishing, overseeing and assessing the
achievements against measurable objectives in relation to goals set out in this
policy.
The Group’s Human Resources Department is responsible for all other objectives and
initiatives set out in this policy.
Infringement of this Policy
Skylink network has a long-standing commitment to conduct our business in compliance with all applicable local and international laws and regulations and in accordance with the highest ethical business principles and any violations of the policy will lead to disciplinary action up to and including dismissal of personnel/contract cancellation.
Further Information
For further information, contact with the Human Resources Department or Compliance Administrator.