This Policy of Gifts, Presents, Hospitality and Others, develops certain aspects of the Anti-Bribery and AntiCorruption Management System, the Transparency and Business Ethics Program, the Anti-Bribery and other forms of Corruption Policy and the statements made in the Code of Ethics, whose purpose is to continue with the commitment and strengthening of transparent and mutually beneficial relationships between Sophos Solutions and business partners and stakeholders.
Sophos Solutions is committed to complying with the rules aimed at the Prevention of national and transnational bribery, adopting policies, procedures and high standards of transparency, honesty, integrity, and legality in the fight against Acts of Corruption through the management of risks and the strengthening of the Government and our corporate principles.
No gift, present, detail, attention, object, benefit, advantage, hospitality, food, travel, accommodation, or form of entertainment should be given or accepted if it can, or if it creates the appearance of being able to unduly influence directly or indirectly in contractual or commercial relations, if it alters its independence, if it creates obligations, or causes potential discredit and/or violates the law or policies of Sophos Solutions.
The purpose of this policy is to establish a framework of action on the business position and acceptable limits against the attentions between the parties through gifts, social attentions, meals, entertainment, among others, for the Parent and subsidiaries of Sophos Solutions giving scope and clarity to all third parties with whom you have an interaction as collaborators, related parties, stakeholders, associates, and business partners 1
We seek to protect the good name of Sophos Solutions and each of the members of senior management and its collaborators when they are immersed in a real or potential conflict of interest, associated with gifts, presents, hospitality, attention, and others.
This Policy takes into consideration the interests of the Company, and the needs and expectations of its internal and external third parties.
1 Understood as customers, business alliance, contractors, consultants, subcontractors, national and international suppliers, among others and their analogy before the countries that operate the subsidiaries, in general to all those with whom directly or indirectly some commercial or contractual relationship is established.
Through this Policy Sophos solutions aims to ensure that all employees, as well as third parties with whom it maintains business relationships, comply with the provisions of the main existing anti-bribery standards, among the compliance is the standards set in the ISO 37001 standard, FCPA law, and Law 1778 of 2016, Transparency and Business Ethics Program, Anti-bribery Law, and any other applicable rules or policies
Any gift, detail, or other incentive, that is sent to any collaborator of the company in compliance with this policy, regardless of whether it arrives at the company’s facilities or the place of residence of the person, must be reported and as the case may be made available to the Compliance Officer/Function.
Collaborators, associates and administrators of Sophos shall refrain, directly or through their spouses, permanent partners and relatives in the second degree of consanguinity or affinity, or only civil, from offering, giving, soliciting and accepting from customers and in general from any natural or legal person, gifts, invitations or other incentives that give rise to a personal commitment or to the Company and that may detract from its objectivity in making decisions in matters related to that person or entity to which the incentive has been offered, given, requested or accepted.
It is NOT considered merchandising or corporate branding, objects valuable with corporate Brand such as watches, tablets, among others.
Sophos Solutions prohibits its employees’ officers and third parties acting on behalf of the company, (both parent and subsidiary) from making political contributions to political parties or candidates.
Sophos Solutions considers a SERIOUS MISCONDUCT the non-compliance of the Anti-Bribery and AntiCorruption Management System, the Transparency and Business Ethics Program, Anti-Bribery and other forms of corruption policy, the omission or breach of the Code of Ethics, the Internal Labor Regulations, the Labor Contract and any of the controls, information management or other guidelines defined herein for the prevention, detection and control of activities that contradict the fight against Acts of Corruption and Bribery, without prejudice to applicable legal sanctions. As a result of the serious infringement and breach of the employee’s duties towards the Company, the Company will undertake disciplinary and/or legal action as appropriate.
In the case of Sophos collaborators, the penalty procedure to be followed is that determined in the section “SCALE OF MISDEMEANORS AND DISCIPLINARY SANCTIONS” of the Internal Labor Regulations, without prejudice to the applicable legal sanctions. For those linked to the company, the penalties set out in the contracts and/or in the law as appropriate will be taken into consideration.
Legal sanctions against bribery and corruption are severe and may involve fines, administrative or criminal sanctions, such as, for example, imprisonment for the persons involved, as stipulated by international laws in which prison sentences of 7 to 10 years and/or unlimited fines are agreed.
In addition, Sophos Solutions could face serious fines or other criminal penalties for bribery and corrupt activities by third parties 2. However, Sophos will investigate any activity that violates this Policy and, where appropriate, will inform the competent authorities of any event of fraud or corruption and will initiate and accompany into the legal actions that are pertinent, in addition to taking the appropriate disciplinary measures and sanctions that may even involve the termination of the employment or commercial relationship.
Ignorance or inadequate understanding of this policy does not entitle its recipients to breach it.
“Sophos Solutions S.A.S reserves the right to modify this document according to the changes that arise within the company”.
2 Article 2 (Law 1778/2016) Administrative liability of legal persons who, through one or more employees, contractors, administrators, associates, or any subordinate legal person.