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Group Policy Document Date: 20111101 Policy ID: GP30.01 Policy Title: ASIA ALLOY AntiBribery Policy Group Function: Group Legal ASIA ALLOY ANTIBRIBERY POLICY Page: 1(11) Group Policy Document Date:
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How to fill out Assa Abloy anti-corruption program:

01
Start by familiarizing yourself with the Assa Abloy anti-corruption program guidelines and policies. These can usually be found on the company's website or obtained from the relevant department.
02
Carefully review the requirements and expectations outlined in the program. Understand what constitutes corrupt behavior and the consequences for non-compliance.
03
Begin by completing any required training or educational materials related to the anti-corruption program. This is crucial in ensuring that all employees are aware of the program's principles and how to apply them in their daily work.
04
Next, identify the potential areas of corruption or bribery risks within your specific role or department. Consider factors such as procurement, sales, vendor relationships, or interactions with government officials.
05
Evaluate and document any existing internal controls or procedures that are in place to mitigate corruption risks. If there are any gaps or weaknesses, develop and implement additional measures to strengthen these controls.
06
Create a plan to monitor and enforce the anti-corruption program. This may involve regular reviews, audits, or spot checks to ensure compliance. Assign responsibility for oversight to a specific individual or team.
07
Communicate the details of the anti-corruption program to all employees within the organization. This can be done through training sessions, workshops, or internal memos.
08
Provide a mechanism for employees to report any suspected or observed corrupt behavior confidentially. This can include a hotline, online form, or designated person to whom concerns can be raised.
09
Review the program periodically to ensure it remains effective and up-to-date with any changes in regulations or best practices.
10
Lastly, ensure that all employees are aware of their responsibilities under the anti-corruption program and the consequences for non-compliance. Encourage a culture of integrity, transparency, and ethical behavior throughout the organization.

Who needs Assa Abloy anti-corruption program:

01
All employees of Assa Abloy, regardless of their position or role within the company, need to adhere to the anti-corruption program. This includes executives, managers, supervisors, and individual contributors.
02
Any individual or department that interacts with external parties, such as suppliers, contractors, customers, or government officials, should be aware of and follow the anti-corruption program.
03
The program is especially important for employees working in roles that involve procurement, sales, finance, legal, compliance, or those who handle sensitive financial or commercial information.
04
Furthermore, Assa Abloy anti-corruption program is essential for employees operating in countries or regions known for higher corruption risks, as they need to be particularly vigilant in avoiding any corrupt activities.
05
It is not only incumbent upon employees to adhere to the program, but it is also the responsibility of company leadership and management to ensure its effective implementation and enforcement.
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