At Joseph W. Hendrickson, LLC. we are committed to conducting our business with the highest standards of integrity, transparency, and accountability. We have a zero-tolerance policy towards bribery and corruption in any form.

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Purpose

This policy aims to:

• Prevent bribery and corruption in all our business operations.

• Promote a culture of honesty and compliance with all relevant anti-corruption laws and regulations.

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Scope

This policy applies to:

• All employees, officers, and directors of Joseph W. Hendrickson, LLC.

• Contractors, consultants, intermediaries, and any third parties acting on behalf of the company

 

What is Bribery and Corruption?

Bribery involves offering, giving, receiving, or soliciting something of value (such as gifts, money, favors, or services) to influence a business or government decision.

Corruption is the abuse of entrusted power for private gain, and it can include fraud, embezzlement, extortion, and nepotism.

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Prohibited Conduct

• Offering, giving, or receiving bribes, kickbacks, or facilitation payments

• Making illegal payments to government officials or business partners

• Using third parties to make improper payments on the company’s behalf

• Falsifying records to conceal corrupt activity

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Gifts and Hospitality

While modest gifts and hospitality may be acceptable as part of normal business etiquette, they must:

• Be of nominal value

• Not be intended to gain unfair advantage

• Be transparently reported and approved when required

 

When in doubt, employees must seek guidance from the Compliance Officer.

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Reporting and Whistleblowing

Employees and third parties are encouraged to report any suspected bribery or corruption concerns without fear of retaliation. Reports can be made confidentially to:

Dfhllc@josephwhendricksonllc.com

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All reports will be investigated thoroughly, and appropriate disciplinary or legal action will be taken if necessary.

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Training and Compliance

Joseph W. Hendrickson, LLC. will provide regular training and guidance to employees to ensure understanding and adherence to this policy.

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Policy Enforcement

Violations of this policy may result in disciplinary action, including termination of employment or contract, and may lead to criminal prosecution under applicable laws.