ACCESSING, BROWSING OR OTHERWISE USING THIS WEBSITE INDICATES YOUR AGREEMENT TO ALL THE TERMS AND CONDITIONS SPECIFIED UNDER THESE “TERMS OF USE”, SO PLEASE READ THESE “TERMS OF USE” CAREFULLY BEFORE PROCEEDING.
This Website (peoplemattersglobal.com) is owned, operated and maintained by People Matters Pte. Ltd. (“the Company”), a company incorporated under the Companies Act, 2013 and having its registered office at Office No. 38 Beach Road, #29-11, South Beach Tower, Singapore - 189767
Reference to the term “Website” in these Terms of Use shall include the mobile application “PeopleMattersGlobal”, and / or any other software / application, as the case may be, through which the User (a) accesses the Website, or (b) avails online services from the Company under “People Matters” brand.
This “Terms of Use” document constitutes an “electronic contract” between the Company and the User of the Website under the laws applicable to the User. This electronic record is generated by a computer system and does not require any physical or digital signatures.
IF YOU DO NOT AGREE WITH THESE “TERMS OF USE” PLEASE DO NOT USE THE WEBSITE. BY VISITING OR ACCESSING THE WEBSITE, YOU UNCONDITIONALLY ACCEPT, AND AGREE TO BE LEGALLY BOUND BY THE “TERMS OF USE”, READ WITH THE PRIVACY POLICY AND / OR ANY OTHER APPLICABLE POLICY GOVERNING THE USE OF THE WEBSITE OR CONDUCT OF TRANSACTIONS ON THE WEBSITE.
This “Terms of Use” document includes and shall always be deemed to include (a) the Privacy Policy; and (b) any other policy governing the use of the Website or conduct of transactions on the Website. Further, when You use any specific service provided by Us through the Website, You will be subject to the terms and conditions applicable to such service, and they shall be deemed to have been incorporated into these Terms of Use by reference, and shall be considered to be part and parcel of these Terms of Use.
We reserve the right, at Our sole discretion, to change, modify, add or remove portions of these Terms of Use, at any time without any prior written notice to You. It is Your responsibility to review these Terms of Use periodically for updates / changes. For certain changes, We may be required under Applicable Law to give You advance notice of any change(s) to the Terms of Use. Your continued use of the Website following the posting of changes will mean that You accept and agree to the revisions. As long as You comply with these Terms of Use, We grant You a personal, non-exclusive, non-transferable, limited privilege to enter and use the Website.
People Matters provides this Website as a service to those people seeking news and information in the areas of Leadership and People Management. The information / services provided on this Website may include without limitation (a) news, articles, write ups, analysis, discussion, reports etc. on different matters; (b) subscription to journals, magazines, updates, news reports, studies etc.; (c) provision of consultancy, advice, suggestions, information, tips, analytical tools, software facilities etc.; (d) any other services deemed fit by the Company (collectively referred to as “Services”).
The provision of any or all the Services is subject to Applicable Laws in each territory. One or more of our services may not be available in any territory, if the provision of such service is barred by Applicable Law in the territory. Further, the provision of any or all of the Services is subject to the sole discretion of the Company and its availability on the Website. Please check our Website to confirm if any particular Services is available on our Website.
Competence to contract: Use of the Website is available only to those individuals and who can form legally binding contracts under Applicable Law in their respective jurisdictions. Persons who are “incompetent to contract” as per Applicable Law in their jurisdictions are not eligible to use the Website. If you are a minor i.e. under the age of 18 years, you shall not register as a User of the Website and shall not use the Website. As a minor if you wish to use the Website, such use may be made by your legal guardian or parents on the Website. The Company reserves the right to terminate your membership and / or refuse to provide you with access to the Website if it is brought to the Company’s notice or if it is discovered that you are under the age of 18 years.
Authorization: In case You are registering as a business or a corporate entity, you represent that You are duly authorized by the business / corporate entity as applicable to accept this Agreement and You have the authority to bind that business / corporate entity to this Agreement.
The Company may require Users to fill an online form and register themselves on the Website to avail all or any of the services rendered on the Website. The Company may require Users to provide all information, and submit all documents as may be required for registration of the User on Website or for availing any Service on the Website (“Registration Information”).
You agree to:
provide true, accurate, correct and complete Registration Information; and
Maintain and promptly update the Registration Information to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or if the Company has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, the Company has the right to suspend or terminate any and all of your current or future use of the Services.
Upon successful registration to use the Services and payment of Service Fee, your Account would be activated. You agree and understand that you will be solely responsible for maintaining the confidentiality of your password which, together with your login ID, allows you to access the Services.
By providing us with your email address and mobile number, you agree to receive all required notices and information electronically, on that email address or mobile number. It is your responsibility to update any changes to your email address and mobile number. If you become aware of any unauthorized use of your Registration Information, you agree to notify the Company immediately at the customer service helpdesk, the details of which are available on the Website. The Company shall not be liable for any unauthorized use or access, unless it is proved that the unauthorized use or access occurred solely due to reasons directly attributable to the Company.
Payment of Fees: the Company does not levy any fees for browsing the Website. The Company may charge Users certain fees for the use of the Website and Services as a whole, or certain features of the Website/ Services. You agree to pay any such fees, as may be applicable to the Services that You use. The Company will try to ensure that You are made aware of the applicability of any fees for a particular use of the Website/ Services, as well as the amount of fees payable by You for any such use of the Website / Services. You agree that the Company may, at any time, charge, modify or waive fees required to use the Website. Your continued use of the Website/ Services after such change in the fees will be considered to be your acceptance of such changes, and applicability of these Terms of Use to such change.
Payment and cancellation: It is assumed that Users who buy or pay for these services are fully aware of what they are buying/purchasing and that they have read all documentation (product descriptions, advertising, etc.) regarding the product, service, membership, etcetera, to have made that choice. There are no refunds for subscription or other payments once activity on the site has been established after the purchase of that service. Products that have been determined to be defective or damaged can be returned to us for a full refund within a reasonable amount of time deemed by one of our sales representatives (via email or documented phone call). The cancellation policy of other products, services, etcetera that appear on Company but are offered by other companies or individuals, are the sole responsibility of those companies or individuals. Company does not assume any liability or any sort resulting in the purchase of those particular products, services, etcetera and does not endorse the purchase of the same.
Provision of payment information: You agree to provide correct and accurate financial information, such as credit/debit card details to the approved payment gateway or pre-paid payment instrument account details for availing Services on the Website. You shall not use the credit/debit card or pre-paid payment instrument which is not lawfully owned by You i.e. in any transaction, You must use Your own credit/debit card or pre-paid instrument account. The information provided by you will not be utilized or shared with any third- party unless required in relation to fraud verifications or by law, regulation or court order or in accordance with the terms of the Privacy Policy. You will be solely responsible for the security and confidentiality of Your credit/debit card details or pre-paid instrument account. The Company expressly disclaims all liabilities that may arise as a consequence of any unauthorized use of Your credit/debit card or pre-paid instrument account.
You agree, undertake and confirm that Your use of the Website shall be strictly governed by the following binding principles:
You shall not host, display, upload, modify, publish, transmit, update or share any information which:
belongs to another person and to which You do not have any right;
is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libellous, invasive of another’s privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever; or unlawfully threatening or unlawfully harassing including but not limited to “indecent representation of women” within the meaning of the Indecent Representation of Women (Prohibition) Act, 1986;
is misleading in any way;
is patently offensive to the online community, such as sexually explicit content, or content that promotes obscenity, paedophilia, racism, bigotry, hatred or physical harm of any kind against any group or individual;
harasses or advocates harassment of another person;
involves the transmission of “junk mail”, “chain letters”, or unsolicited mass mailing or “spamming”;
promotes illegal activities or conduct that is abusive, threatening, obscene, defamatory or libelous;
infringes upon or violates any third-party’s rights [including, but not limited to, intellectual property rights, rights of privacy (including without limitation unauthorized disclosure of a person’s name, email address, physical address or phone number) or rights of publicity];
promotes an illegal or unauthorized copy of another person’s copyrighted work (see “Copyright complaint” below for instructions on how to lodge a complaint about uploaded copyrighted material), such as providing pirated computer programs or links to them, providing information to circumvent manufacture-installed copy-protect devices, or providing pirated music or links to pirated music files;
contains restricted or password-only access pages, or hidden pages or images (those not linked to or from another accessible page);
provides material that exploits people in a sexual, violent or otherwise inappropriate manner or solicits personal information from anyone;
provides instructional information about illegal activities such as making or buying illegal weapons, violating someone’s privacy, or providing or creating computer viruses;
contains video, photographs, or images of another person (with a minor or an adult);
tries to gain unauthorized access or exceeds the scope of authorized access to the Website or to profiles, blogs, communities, account information, bulletins, friend request, or other areas of the Website or solicits passwords or personal identifying information for commercial or unlawful purposes from other users;
engages in commercial activities and/or sales without Our prior written consent such as contests, sweepstakes, barter, advertising and pyramid schemes, or the buying or selling of “virtual” products related to the Website;
solicits gambling or engages in any gambling activity which We, in Our sole discretion, believes is or could be construed as being illegal;
interferes with another User’s use and enjoyment of the Website or any other individual’s User and enjoyment of similar services;
refers to any website or URL that, in Our sole discretion, contains material that is inappropriate for the Website or any other website, contains content that would be prohibited or violates the letter or spirit of these Terms of Use;
harms minors in any way;
infringes any patent, trademark, copyright or other proprietary rights or third-party’s trade secrets or rights of publicity or privacy or shall not be fraudulent or involve the sale of counterfeit or stolen products;
violates any law for the time being in force;
deceives or misleads the addressee/ Users about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
impersonate another person;
contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; or contains any trojan horses, worms, time bombs, cancelbots, easter eggs or other computer programming routines that may damage, detrimentally interfere with, diminish value of, surreptitiously intercept or expropriate any system, data or personal information;
threatens the unity, integrity, defence, security or sovereignty of any nation, friendly relations between nation states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation;
is false, inaccurate or misleading;
creates liability for Us or cause Us to lose (in whole or in part) the services of Our internet service provider (“ISPs”) or other suppliers.
You shall not use any “deep-link”, “page-scrape”, “robot”, “spider” or other automatic device, program, algorithm or methodology, or any similar or equivalent manual process, to access, acquire, copy or monitor any portion of the Website or any content, or in any way reproduce or circumvent the navigational structure or presentation of the Website or any Content, to obtain or attempt to obtain any materials, documents or information through any means not purposely made available through the Website. We reserve Our right to bar any such activity.
You shall not attempt to gain unauthorized access to any portion or feature of the Website, or any other systems or networks connected to the Website or to any server, computer, network, or to any of the services offered on or through the Website, by hacking, password “mining” or any other illegitimate means.
You shall not probe, scan or test the vulnerability of the Website or any network connected to the Website nor breach the security or authentication measures on the Website or any network connected to the Website. You may not reverse look-up, trace or seek to trace any information on any other User of or visitor to Website, or any other customer, including any account on the Website not owned by You, to its source, or exploit the Website or any service or information made available or offered by or through the Website, in any way where the purpose is to reveal any information, including but not limited to personal identification or information, other than Your own information, as provided for by the Website.
You shall not make any negative, denigrating or defamatory statement(s) or comment(s) about Us or the brand name or domain name used by Us including the terms the Company, or otherwise engage in any conduct or action that might tarnish the image or reputation, of the Company or sellers on platform or otherwise tarnish or dilute any the Company’s trade or service marks, trade name and/or goodwill associated with such trade or service marks, trade name as may be owned or used by us. You agree that You will not take any action that imposes an unreasonable or disproportionately large load on the infrastructure of the Website or the Company’s systems or networks, or any systems or networks connected to the Company.
You agree not to use any device, software or routine to interfere or attempt to interfere with the proper working of the Website or any transaction being conducted on the Website, or with any other person’s use of the Website.
You shall not forge headers or otherwise manipulate identifiers in order to disguise the origin of any message or transmittal You send to Us on or through the Website or any service offered on or through the Website. You may not pretend that You are, or that You represent, someone else, or impersonate any other individual or entity.
You shall not use the Website or any content for any purpose that is unlawful or prohibited by these Terms of Use, or to solicit the performance of any illegal activity or other activity which infringes the rights of the Company and / or others.
You agree to comply all Applicable Laws while using the Services. You agree not to use the Services for any illegal purpose or for the transmission of material that is unlawful, harassing, libelous (untrue and damaging to others), invasive of another's privacy, abusive, threatening, or obscene, or that infringes the rights of others. You shall also ensure that you are not prohibited whether contractually or otherwise from availing of the Services. Please do check whether the terms and conditions of the financial services which you may seek to aggregate pursuant to the Services offered, prohibit the use of the Services in any manner whatsoever. In the event there exists any prohibition, please do not avail of the Services for aggregation of information in respect of such financial services.
The contents of the Website, including its "look and feel” (e.g. text, graphics, images, logos and button icons), photographs, editorial content, notices, software (including html-based computer programmes) and other material are the owned/licensed by/to the Company and/or its Third-Party Service Providers/their licensors and are duly protected by them under applicable copyright, trademark and other laws. You acknowledge and agree that the Company and/or its licensors or suppliers own all rights to this Website, the content displayed on the Website and any intellectual or proprietary property and/or technology (in any form) made available to you as a part of or in conjunction with the Services.
You are only permitted to use any of the foregoing as expressly authorized by these Terms of Use, and otherwise, by the Services. You may download or print a copy of the information provided on this Website for your personal, internal and non-commercial use only. You shall not copy, re-print, reproduce (electronically or otherwise), distribute, or create derivative works from any content on the Website, in whole or in part, for any other purpose without our prior written consent. Further, you agree not to reverse engineer or reverse compile any technology associated with the Services, including but not limited to any software applications or Java applets associated with the Services Content, from the Website, in whole or in part.
You expressly understand and agree that your use of the Services is at your sole risk. The Services are provided on an "as is" and "as available" basis. We expressly disclaim all warranties of any kind, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement.
We make no warranty that:
The Company assumes no responsibility for consequences resulting from the use of information on the site or information obtained through links. The Company will not be liable for any damages of any kind arising out of use, reference to, or reliance on any information contained in the site. The Company is not responsible for the accuracy or content information contained in the site or in the links provided on its site. Links to and from the Company do not constitute an endorsement by the Company of the parties or their products and services.
ANY MATERIAL DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICES IS DONE AT YOUR OWN DISCRETION AND RISK AND WE ARE NOT RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF ANY SUCH MATERIAL. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM US OR THROUGH OR FROM THE SERVICES WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS. TO THE EXTENT THAT ANY PART OF THIS SECTION IS NOT CONSISTENT WITH ANY OTHER PART OF THESE TERMS, THEN THIS SECTION WILL PREVAIL.
You agree that we will not be liable for any damage or loss either direct, indirect, incidental, special, consequential or exemplary, including, but not limited to, damages for loss of profits, goodwill, use, data or other intangible losses, even if we have been advised of the possibility of such damages, resulting from:
Without prejudice to the generality of the foregoing, in case the Company is held to be liable to for any damages under Applicable Law, then the liability of the Company will be limited to fees or other consideration paid by the User for availing the Services from the Company.
You agree to indemnify and hold harmless the Company, its owners, licensees, affiliates, subsidiaries, group companies (as applicable) and their respective officers, directors, agents, and employees, from and against, any and all suits, actions and proceedings, claims, liabilities, losses, damages, costs and expenses, including reasonable outside attorneys’ fees, arising directly or indirectly in connection with:
Your violation of any law, regulation or order of any government or judicial authority; or
any act, omission, fraud, negligence or default or the breach of any of Your obligations or representations under these Terms of Use or any other agreement / policy between You and the Company;
any infringement of any intellectual property rights of the Company or any third-party.
any infringement of any intellectual property right of the Other Party or any third-party.
In case of any non-compliance or violation of these Terms of Use, the Company has the right to immediately terminate the access or usage rights of the Users of the Website and remove any and all non-compliant information from the Website.
Any complaint / grievance with respect to the Services or the Website may be submitted to the Grievance Officer of the Company as per details provided below:
Please refer Clause 20 below.
The Company may provide You with notices and communications by e-mail, SMS, push notifications, regular mail or postings on the Website or by any other reasonable means. Except as otherwise set forth herein, any notice to the Company must be sent by courier or registered mail and addressed to the Grievance Officer as per details specified above.
If any provision of these Terms of Use is invalid, unenforceable or prohibited by law, then, these Terms of Use shall be considered divisible as to such provision and such provision shall be inoperative, and the remainder of these Terms of Use shall be valid, binding and of like effect as though such provision was not included herein. The Company will substitute for the invalid or unenforceable provision a valid and legally enforceable provision, which achieves to the greatest extent possible the economic, legal and commercial objectives of the provision, which is invalid or unenforceable.
No failure or delay by a party in exercising any right, power or remedy shall operate as a waiver thereof, nor shall any single or partial exercise of the same preclude any further exercise thereof or the exercise of any other right, power or remedy.
Data and information retrieved through the Services is for informational purposes only and is not intended for trading or transactional purposes. The Company shall not be liable for any errors or delays in the content or information obtained through the Services, or for any actions taken in reliance thereon.
Specific countries
In any case where the law of any of the jurisdictions cited below applies, the following country specific provisions will replace or supplement the equivalent provisions above:
INDIA
Supplementary terms and conditions
GOVERNING LAW AND JURISDICTION
These Terms of Use, the Services and the relationship between You and the Company shall be governed in accordance with the laws of India. You agree that all claims, differences and disputes arising under or in connection with or in relation hereto the Website, these Terms of Use, the Agreement(s) entered into on or through the Website or the relationship between You and the Company shall be subject to the exclusive jurisdiction of the courts at Gurgaon, Haryana.
Supplementary terms and conditions
The following provisions shall apply in every country in which the Services are being offered and which is not specifically mentioned above:
GOVERNING LAW AND JURISDICTION
These Terms of Use, the Services and the relationship between You and the Company shall be governed in accordance with the laws of India. You agree that all claims, differences and disputes arising under or in connection with or in relation hereto the Website, these Terms of Use, the Agreement(s) entered into on or through the Website or the relationship between You and the Company shall be subject to the exclusive jurisdiction of the courts at Gurgaon, Haryana.
Chapter 1 General Rules
Article 1 (Purpose)
The purpose of these regulations (hereafter called the “Regulations”) is to establish rules for use when contacting Third Parties (as defined in Article 3, the same shall apply hereafter) in the course of business, to ensure our Employees’ (as defined in Article 3, the same shall apply hereafter) compliance with domestic and foreign anti-bribery laws, and to prevent the bribery of Third Parties or Employees in accordance with the “Anti-bribery Guideline” in Schedule 1.
Article 2 (Scope)
These Regulations are applicable to corporate activities of the company (hereafter called the “Company”) which involve direct or indirect contact with the Third Parties in any place.
Article 3 (Definitions)
The following definitions apply to these Regulations:
Chapter 2 Prohibition of Bribery
Article 4 (Prohibition of Bribery)
Employees shall not be involved in any Bribery, whether or not performed at the Company’s expense; however, in cases where an Employee is forced to concede to the demand of a Third Party, and otherwise such Employee or his/her family member(s) may be exposed to life-threatening danger, satisfying such a demand is not deemed Bribery. In such cases, post-incident reports must be filed immediately in accordance with the established internal approval standards.
Chapter 3 Entertainment and Gifts to Third Parties
Article 5 (Entertainment and Gifts to or from Third Party)
1. In offering or receiving entertainment and gifts to or from Third Parties, Employees shall check and ensure, with reasonable grounds, that the entertainment or gifts will not be deemed or suspected to be Bribery in accordance with paragraph 2 below and the established procedures provided in Article 6, upon which determination, (1) in respect of entertainment and gifts offered to Third Parties, only when it is necessary to incur such expenses, the Company will offer entertainment or gifts in accordance with paragraph 2 below and the established procedures provided in Article 6, or (2) in respect of entertainment and gifts received by Employees from Third Parties, [only when it is deemed appropriate by the Company will] the Company allow the Employees to receive these entertainment and gifts from Third Parties. Such entertainment and gifts must be reported to the person authorized to approve them to ensure that the entertainment and gifts have been offered or received as permitted pursuant to the relevant internal approval(s); however, this article does not apply to entertainment or gifts offered for purposes other than for a corrupt purpose by way of causing a Third Party or Employee to perform or refrain from his or her occupational duties or in relation to any act relating to any matter or transaction (whether actual or proposed) and/or as Facilitation Payments, and based on the same terms and conditions as those applied to persons other than a Third Party or an Employee.
2. In offering or receiving entertainment or gifts to or from the Third Parties, Employees shall ensure the following:
that no money shall be offered or received as a Gift.
Article 6 (Approval Procedures, Preparation of Accounting Records)
Chapter 4 Invitations to Third Parties or Employees
Article 7 (Invitations to or from Third Parties)
In extending or receiving Invitations to or from any Third Parties, the Employees shall check and ensure, upon reasonable grounds, that Invitations or expenses associated therewith will not be deemed or suspected to be Bribery in accordance with established internal approval procedures and in accordance with the “Invitation Criteria” provided in the separate Anti-bribery Manual, upon which confirmation, (1) in respect of Invitations extended to Third Parties, only when necessary to incur such expenses, will the Company proceed with the Invitation in accordance with established internal approval procedures and in accordance with the “Invitation Criteria” provided in the separate Anti-bribery Manual, or (2) in respect of Invitations extended from Third Parties to Employees, [only when deemed appropriate by the Company] will the Company allow the Employees to receive the Invitations. Such Invitations must be reported to the person authorized to approve them, to ensure that Invitations have been made or received as permitted by the relevant internal approval(s).
Chapter 5 Donations
Article 8 (Donations)
In offering or receiving Donations, Employees shall check and ensure, upon reasonable grounds, that Donations will not be deemed or suspected to be Bribery in accordance with established internal approval procedures and in accordance with the “Donation Criteria” provided in the separate Anti-bribery Manual, upon which confirmation, and only when necessary will the Company offer or accept Donations in accordance with established internal approval procedures and in accordance with the “Donation Criteria” provided in the separate Anti-bribery Manual. Such Donations must be reported to the person authorized to approve them, to ensure that donations have been offered as permitted by the relevant internal approval(s).
Chapter 6 Appointment of Agents
Article 9 (Appointment of Agents)
In appointing an Agent, the Company shall, in accordance with the “Benchmark for Appraisal of Agents” provided in the separate Anti-bribery Manual, check and ensure, upon reasonable grounds, that remuneration to such Agent will not be deemed or suspected to be Bribery, upon which confirmation and only when necessary, the Company will appoint an Agent in accordance with established internal approval procedures. The Employees shall not make any payment to an Agent if such payment is suspected of misuse, or of being unlawful or illegal solicitation of the Third Parties.
Chapter 7 Other Matters
Article 10 (Whistleblowing)
Article 11 (Disciplinary Actions)
The Company is entitled to take disciplinary actions against and/or seek compensatory damages from Employees who violate the Laws or these Regulations.
Article 12 (Internal Audit)
The Internal Audit Department shall conduct audits in accordance with the internal audit regulations to ensure compliance with and prevent Violations of these Regulations by any departments, sections, or branches.
Supplementary Rules
Amendment Record
Enacted on: 26th April 2023.
Anti-bribery Guideline
1. Prohibition of Bribery
The Company will not tolerate any bribery or solicitation/promise of bribery,
whether directly or indirectly, in the form of money or other tangible/intangible
benefits, offered to or received from (1) a domestic or foreign public official
or a similar person appointed under the Relevant Laws (as defined below)
(hereafter, “Public Officials”), and/or (2) all other persons (excluding
Public Officials) who the Employees (as defined below) would contact in
the course of business in relation to any matter or transaction (whether
such matter or transaction is actual or proposed) (hereafter, “Other Persons”)
(the Other Persons and the Public Officials collectively, the “Third Parties”)
in an attempt to raise illicit business profits.
2. Compliance with Relevant Laws
The Company will ensure that our corporate activities are carried out in
compliance with the relevant laws of each country (hereafter, “Relevant Laws”)
to prevent bribery of the Third Parties.
3. Awareness
The Company will raise the awareness of its employees (hereafter, “
Employees”) through training and guidance, to ensure their
compliance with this Guideline in the course of our corporate activities.
4. Management of Payment Records
The Company will comply with Relevant Laws and internal regulations and
keep proper records on economic benefits offered or received by Employees
to or from any Third Parties, including without limitation entertainment
and gifts.
5. Measures against Violations
The Company will take strict measures, in accordance with internal regulations,
against any Employees who violate Relevant Laws and this Guideline.
6. Revision
The Company will revise this Guideline as soon as it becomes necessary to
comply with the Relevant Laws.
Enacted on: 26th April 2023
