Global Finance Media Inc.
Anti-Bribery and Corruption Policy
Purpose
Global Finance Media Inc. (“GFM”) is committed to conducting its business with integrity and in full compliance with the laws and regulations of the jurisdictions in which we operate, including the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act 2010. This policy sets forth GFM’s standards for preventing bribery and corruption in all business dealings.
Scope
This policy applies to all GFM employees, officers, directors, contractors, and third-party representatives worldwide (collectively, “GFM personnel”). Compliance with this policy is mandatory and forms part of the terms of employment or engagement with GFM.
Policy Statements
- Prohibition of Bribery
- GFM prohibits the offering, giving, soliciting, or receiving of bribes or other improper payments, including:
- Cash, gifts, hospitality, or anything of value intended to influence a decision or gain an improper advantage.
- Facilitation payments (small payments to expedite routine government actions) unless legally required and approved by GFM.
- Bribery of foreign officials, private individuals, or entities is strictly prohibited, regardless of local practices.
- GFM prohibits the offering, giving, soliciting, or receiving of bribes or other improper payments, including:
- Third-Party Due Diligence
- GFM personnel shall endeavor to conduct due diligence on agents, contractors, suppliers, and business partners to ensure they comply with anti-bribery laws and GFM’s standards.
- Gifts, Hospitality, and Entertainment
- Gifts, hospitality, or entertainment must:
- Be reasonable, proportionate, and lawful.
- Not create an appearance of impropriety or influence decisions.
- Prior approval from management is required for any gifts or entertainment exceeding a specified value threshold.
- Gifts, hospitality, or entertainment must:
- Reporting and Whistleblowing
- GFM personnel must promptly report any suspected bribery, corruption, or policy violations to their manager, compliance officer, or via the confidential whistleblowing hotline.
- GFM prohibits retaliation against individuals who report concerns in good faith.
Compliance Monitoring and Review
GFM will:
- Monitor adherence to this policy.
- Periodically review and update the policy to reflect legal and regulatory changes.
- Conduct audits to identify and mitigate risks of bribery and corruption.
Certification and Acknowledgment
All GFM personnel must certify regularly that they have read, understood, and will comply with this policy. Failure to comply may result in disciplinary action, up to and including termination of employment or engagement.
Contact
For questions or concerns about this policy, please contact GFM at jdg@gfmag.com.
Effective Date
This policy is effective as of January 2024 and supersedes all previous anti-bribery policies.
Global Finance Media Inc.
Anti-Human-Trafficking Policy
Purpose
Global Finance Media Inc. (“GFM”) is committed to ensuring that modern slavery and human trafficking are not present in our operations or supply chains. This policy outlines our commitment to compliance with applicable laws, including US 48 CFR § 52.222-50 and the U.K. Modern Slavery Act 2015.
Scope
This policy applies to all GFM employees, officers, directors, contractors, and third-party representatives worldwide (collectively, “GFM personnel”). Compliance with this policy is mandatory and forms part of the terms of employment or engagement with GFM.
Policy Statements
- Prohibition of Modern Slavery
- GFM does not tolerate the use of modern slavery, child labor, forced labor, or human trafficking in any form in our organization. We support the principles established under the United Nations Declaration of Human Rights and are committed to conducting business in a way that respects the rights and the dignity of people and prevent adverse human rights impacts. We prohibit the employment of underage children or forced labor, including slave labor, prison labor, indentured servitude, or bonded labor, as well as any form of physical punishment or abuse including use of force, coercion, or other means for the purpose of exploiting them.
- Supply Chain
- We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our supply chains. GFM personnel shall endeavor to conduct reasonable due diligence on agents, contractors, suppliers, and business partners to ensure they comply with anti-bribery laws and this policy.
- Reporting and Whistleblowing
- GFM personnel must report any conduct that you believe to be a violation of this policy to GFM’s legal or human resources department. GFM personnel who fail to report actual or suspected misconduct may be deemed in violation of this policy.
- GFM prohibits retaliation against individuals who report concerns in good faith.
Compliance Monitoring and Review
GFM will:
- Monitor adherence to this policy.
- Periodically review and update the policy to reflect legal and regulatory changes.
- Conduct audits to identify and mitigate risks of modern slavery.
Contact
For questions or concerns about this policy, please contact GFM at jdg@gfmag.com.
Effective Date
This policy is effective as of January 2024 and supersedes all previous anti-slavery policies.