5. Major Risk Areas Of Corruption
In WEglobal Group Companies, in order to ensure efficient fight against bribery and corruption, possible risks are identified beforehand by related units, services and operations, separated into categories and necessary analyses are carried out. According to the results of the analysis studies and within a risk-based approach, necessary measures are taken by considering the possible risks. The measures taken at this stage are determined taking into account the risk-exposure level of the positions of the existing employees and their level of access within their roles.
A gift is a product generally given by customers or persons being in a business relationship with any WEglobal Group Company as a means of appreciation or commercial courtesy and which does not require a financial payment.
All kinds of gifts given to third parties by the WEglobal Group Companies are offered publicly and with goodwill. The same principles are applied for accepting a gift and under no circumstances may a gift is accepted unless it is a low priced symbolic one given not to the person but his/her company in accordance with these principles.
Even if it complies with the Policy, no gift must be offered or accepted in situations which could cause any conflict of interest or perceived as such.
b) Political Donations
It is essential that WEglobal Group Companies do not make any corporate or individual payment, give any gift, provide financial aid or donation to any government official or political party candidate in order to influence any decision at the service procurement or rendering stage likely to be related to the continuity of thier operations or for their benefit.
Hospitality may be offered to third parties for developing commercial relationships and for establishing a normal commercial communication network. Among such third parties, customers, consultants, lawyers, auditors and other companies who have business relationship with the WEglobal Group Companies can be mentioned. Hospitality offered by WEglobal Group Companies shall be publicly, unconditionally and with good will.
Even if it complies with the Policy, hospitality must not be offered or accepted in situations which could cause any conflict of interest or perceived as such.
d) Outsourcing Companies and Business Partners
Outsourcing companies and business partners including those from which support services are obtained must comply with the principles of the Policy and other relevant regulations. For this reason, in all agreements and contracts with the outsourcing companies and business partners, the requirement of compliance with the WEglobal Group Companies policies and understanding and implementing of these issues by the company’s and its business partners’ employees is included. With these principles, potential risks are eliminated. WEglobal Group Companies terminate their relations with the persons or institutions failing to comply with the Anti-Bribery and Corruption Policy.
Under no circumstances WEglobal Group Companies work with any company or its business partners having a negative intelligence and which is included in a monitoring list in this field. Due diligence is conducted beforehand. In the selection of outsourcing companies and their business partners, besides usual technical criteria, having a positive background and policies equivalent to WEglobal Group Companies’ policies and ethical principles are paid regard to. In addition, it is verified if the payments are appropriate and legitimate for the purchased service.
All related units involved in the purchase of an outsourced service are subjected to the WEglobal Group Companies’ internal audit and compliance with the abovementioned principles is evaluated during audits.
e) Facilitation Payments
WEglobal Group Companies do not allow the persons and institutions within the context of this Policy to offer facilitation payments in order to guarantee or accelerate a routine transaction or process with government agencies.