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Our Approach to the Code of Ethics
We follow a series of policies and procedures that serve as the framework for the anti-corruption compliance program, including: (i) a comprehensive anti-corruption policy; (ii) a policy for the giving and receipt of gifts to ensure that such transactions are not subterfuge for bribery; (iii) a policy on gifts and gratuities; and (iv) a policy on potential conflicts of interest.
Where necessary, these policies are strengthened with procedures and work instructions so that our employees have a clear understanding of their responsibilities. To ensure that these policies and procedures are widely understood and followed, we formally train our entire workforce annually on the Code of Ethics. Specific at risk groups are given training on anti-corruption and other risks. Our training program is designed to ensure that employees in sensitive positions receive targeted training to meet the risks inherent in their duties.
Suppliers
Our commitment to compliance is such that we demand an equal commitment from the companies with which we conduct business. UPI’s procedures require that, prior to engaging any business partners, we perform diligence to ensure that our business partners share our commitment to ethical business practices. Our due diligence is a strict requirements apply to all Companies, regardless of location and scope.
We believe a commitment to ethical business practices is key to our continued to success as a company and will continue to enhance our compliance program as needed to meet the evolving risks and challenges facing our Company. For more information about our compliance program, please contact: Fermeen Fazal, UPI’s head of compliance.