At Infinite Sum, the way we do things is just as important as what we do. Of course, we want to be the best in our industry and deliver the best value to our clients… but not at any price. We want to create a workplace where each employee, associate and contractor achieves the highest business and personal standards, and where everyone feels proud of our company and the job they do. Due to the nature of our business and the services we provide to our clients, combined with the significant level of responsibilities that our clients entrust in us, Infinite Sum work extremely hard to apply deep principles, ethics and anti-corruption practices throughout our company.
Infinite Sum is a team with core values:
- Customer-Focused, and
- Team Driven
These values guide how we work every day. We bring these values to life in the way we perform, giving our best effort every day, being accountable for what we do, delivering on our commitments to each other and to our customers, setting objectives, meeting our goals, and working together to achieve business results. A core objective of our Company is creating a winning and inclusive culture that drives results.
By working as an employee, associate or contractor at Infinite Sum, our team are representing the Infinite Sum to our customers and everyone else they come into contact with. As laid out in our Code of Conduct Guidelines (COCG) our team are expected to adopt the highest standards of professional and personal behaviour, and demonstrate Respect, Integrity, Good Judgment, Honesty and Trust, the RIGHT Way, in all their actions, no matter what the circumstances.
One of the guiding principles of the COCG is complying with anti-corruptions laws. The Anti-Corruption Policy extends on this principle, and is applicable to all of our employees and everyone we do business with, including agents, representatives, consultants, independent contractors and anyone acting on behalf of Infinite Sum.
If you have any questions regarding Infinite Sum’s Anti-corruption Policy, please contact our internal legal department or the Ethics and Compliance Office.
Purpose of the Anti-Corruption Policy
This policy outlines acceptable and non-acceptable behavior, to ensure compliance with anti-corruption laws, such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. This includes compliance with all laws, domestic and foreign, prohibiting improper payments, gifts or inducements of any kind to and received from any person, including officials in the private or public sector, customers and suppliers.
Bribe: Anything of value given in an attempt to affect a person’s actions or decisions in order or to gain or retain a business advantage. Anything of value includes cash, entertainment or other gifts or courtesies.
Corruption: The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.
Facilitation payments: Small sums paid to government officials to facilitate or expedite routing. Non-discretionary government actions are considered facilitation payment.
Kickbacks: The return of a sum already paid or due as a reward for awarding of furthering business.
What Does ‘Anti-Corruption’ Mean to You?
Corruption can take place in many types of activities. It usually is designed to obtain financial benefits or other personal gain. For example, bribes are intended to influence behavior – they could be in the form of money, a privilege, an object of value, an advantage, or merely a promise to influence a person in an official or public capacity. Usually, two people are involved and both will benefit. Examples of a bribe include:
- Offer or receipt of cash in the form of a kickback, loan, fee or reward
- Giving of aid, donations or voting designed to exert improper influence
The areas of business where corruption, including bribery, can most often occur include:
- Gifts, Entertainment and Hospitality
- Facilitation Payments
- Procurement Process
- Political, Community and Charitable Contributions
1. Gifts, Entertainment and Hospitality
Gifts, entertainment and hospitality are acceptable if they are reasonable, proportionate and made in good faith and in compliance with our company policies. These activities must be in compliance with our Code of Conduct Guidelines (guiding principle: ‘avoiding conflicts of interest’), Infinite Sum’s Customer Entertainment Policy and Corporate Hospitality Guidelines. Although no two situations are the same, the Corporate Hospitality Guidelines define what is usually acceptable and what is never acceptable.
Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and occurrence.
How do you know if an offered gift, entertainment or hospitality by Infinite Sum or to Infinite Sum is acceptable? First, take a step back and ask yourself the following:
- What is the intent – is it to build relationship or is it something else ?
- How would it look if these details were on the front of a newspaper?
- What if the situation were reversed—would there be a double standard?
If you find it difficult to provide a comfortable answer to one of the above questions, ASK a manager, Infinite Sum Legal Department or the Ethics and Compliance Office.
What to do when you doubt if you can accept? If you are unsure if you should accept something of value, ask. Ask your manager. If your manager is participating, seek a higher-level manager. If you prefer, ask Infinite Sum Legal Department or contact the Ethics and Compliance Office.
As a general rule, Infinite Sum employees and business partners should not provide gifts or hospitality to, or receive them from, a government or other public official (or their close families and business associates). Infinite Sum advises its employees, contractors and associates that they may give a modest gift to these parties when appropriate and allowed by local law provided they have discussed it with and received written approval in advance from the legal department. Please refer to our Code of Conduct Guidelines, “Engaging in Government and Political Activities” which allows political contributions as permitted by law and only when approved in advance by our senior public affairs officer and legal counsel.
2. Facilitation Payments
Facilitation payments are not allowed. If any of our team are unsure whether certain payments represent facilitation payments, they are advised to contact Infinite Sum Legal Department, or the Ethics and Compliance Office.
3. Procurement Process
Infinite Sum team must follow CCE processes and adhere to the system of internal controls around supplier selection. Supplier selection should never be based on receipt of a gift, hospitality or payment. When supplier selection is a formal, structured invitation for the supply of products or services (often called a ‘tender’), it is most important we maintain documentation supporting our internal controls. In the public sector, such a tender process may be required and determined in detail by law to ensure that such competition for the use of public money is open, fair and free from corruption.
A tender process includes an invitation for other parties to make a proposal, on the understanding that any competition for the relevant contract must be conducted in response to the tender, no parties having the unfair advantage of separate, prior, closed-door negotiations for the contract where a bidding process is open to all qualified bidders and where the sealed bids are in the open for scrutiny and are chosen on the basis of price and quality.
4. Political Community and Charitable Contributions
Infinite Sum employees, contractors and associates are not allowed to make political contributions from Infinite Sum Company funds without specific company authorisation. Political contributions, as permitted by law, must be approved in advance by our legal counsel.
Contributions made by Infinite Sum to community projects or charities need to be made in good faith and in compliance with our Code of Conduct Guidelines, this Anti-Corruption Policy and all relevant Infinite Sum policies and procedures.
Books, Records and Internal Control Requirements
Expenses must never be hidden or purposefully misclassified. Many serious global bribery and corruption scenarios are found to involve inaccurate record-keeping. To prevent this, international anti-corruption laws generally require detailed and accurate accounting records for transactions, including cash and bank accounts. Infinite Sum team must ensure they always maintain accurate books, records and financial reporting.
All business units of Infinite Sum must maintain an effective system of internal control and monitoring of our transactions. Certain monitoring controls are identified in our policies, specifically regarding approval of travel and entertainment expenses. It is Infinite Sum employee, contractors and associates responsibility to be knowledgeable of control procedures and ensure compliance.
You Are Responsible
Infinite Sum takes corruption and bribery very seriously. Any violation of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with local law.
Bribery is a criminal offence. As an employee, contractor or associate of Infinite Sum our team will be accountable whether they pay a bribe themselves or whether they authorize, assist, or conspire with someone else to violate an anti-corruption or anti-bribery law. Punishment for violating the law are against the employee, contractor and associate as an individual and may include imprisonment, probation, mandated community service and significant monetary fines which will not be paid by Infinite Sum.
Questions or How to Raise a Concern
If you want to ask a question about the requirements in this policy or are concerned that an anti-corruption violation is occurring or has occurred, report it immediately to one of the following:
- Your manager
- Infinite Sum Legal Department
- Infinite Sum Ethics and Compliance Office.
In the US and the Netherlands, you are required by law to report any suspected violation and failing to do so is itself a breach of our COCG.
This Policy is owned by Infinite Sum’s legal department. Please contact the legal department of Infinite Sum or the Ethics & Compliance Office for any questions.
The policies on this site apply to all employees of Infinite Sum, its subsidiaries, associates, contractors and consultants unless otherwise specified or as required by Federal, National, Country, State or Local law or Collective Bargaining Agreement.