Anti-Corruption Policy for Scandic Diesel Representatives
This Anti-Corruption Policy for Scandic Diesel Services Inc. Representatives (“Policy”) prohibits corruption of all officials (clients, vendors, partners, all Scandic Diesel business relations.), which means paying money or giving something of value to a official to obtain an improper benefit. This Policy similarly prohibits the payment of bribes or kickbacks in commercial transactions that do not involve officials. Corruption is prohibited by the laws in almost every jurisdiction of the world. This Policy also prohibits money laundering, which is the process of concealing funds that have been illegally obtained.
Scandic Diesel Services, and all of its subsidiaries and joint ventures worldwide (“Scandic Diesel”), requires its channel partners (for example, resellers, advisors, original equipment manufacturers, and distributors), consultants, lobbyists, and other third-party representatives (collectively, “Scandic Diesel Representatives”) to comply with this Policy. Scandic Diesel Representatives acting on behalf of Scandic Diesel can expose Scandic Diesel to liability under anti-corruption and anti–money-laundering laws, including the United States Foreign Corrupt Practices Act (“FCPA”). Further, corruption promotes poverty, hunger, disease, and crime, and it keeps societies and individuals from reaching their full potential. Corruption is one of the leading obstacles to economic and social development. Scandic Diesel is committed to observing the standards of conduct set forth in the FCPA and the anti-corruption and anti–money-laundering laws of the countries/regions in which it operates. Scandic Diesel is also committed to taking reasonable steps to ensure that Scandic Diesel Representatives comply with these standards of conduct and laws in its dealings with or on behalf of Scandic Diesel.
1. Compliance with Anti-Corruption Laws
Each Scandic Diesel Representative will comply with all applicable anti-corruption laws, including the FCPA. No Scandic Diesel Representative shall, directly or indirectly, offer or pay anything of value (including gifts, travel, entertainment expenses, and charitable donations) to any official or employee of any government, government agency, political party, or public international organization, or any candidate for political office, to (i) improperly influence any act or decision of such official, employee, or candidate for the purpose of promoting the business interests of Scandic Diesel in any respect, or (ii) otherwise improperly promote the business interests of Scandic Diesel in any respect.
2. Vetting of Scandic Diesel Representatives
Scandic Diesel will conduct a due diligence or “vetting” of each Scandic Diesel Representative to determine that its relationship with the representative does not pose a risk to Scandic Diesel of noncompliance with this Policy. As part of this process, Scandic Diesel will ask the Scandic Diesel Representative to respond to a questionnaire and, if appropriate, provide additional information that may be necessary in the reasonable judgment of Scandic Diesel. Scandic Diesel appreciates the understanding and cooperation of each Scandic Diesel Representative in this regard.
3. Anti–Money Laundering
No Scandic Diesel Representative shall use its relationship with Scandic Diesel to attempt to disguise the sources of illegally obtained funds.
4. No Retaliation
Scandic Diesel Representatives will not retaliate against anyone who has, in good faith, reported a possible violation of this Policy, or refused to participate in activities that violate this Policy.
5. Enforcement
Scandic Diesel will enforce this Policy in accordance with the terms of its contracts with Scandic Diesel Representatives.
Please do not hesitate to contact us for additional information
Montreal April 7th 2010,
Mikkel Elsborg
(SDS Anti-corruption policy)
Reporting
Scandic Diesel Representatives may report concerns with conduct covered by this Policy to the Scandic Diesel Office of Legal Compliance through the following alternatives:
By the Scandic Diesel Diesel direct contact
Managing Director Mikkel Elsborg
Phone +1 514 566 1553
By Scandic Diesel e-mail
Managing Director Mikkel Elsborg
E-mail mie@scandiserv.com
By mail or fax:
Send a letter to the Managing Director at Scandic Diesel Corporation at the following address:
Scandic Diesel
Services Inc.
6360 Notre Dame Est
Montreal, Quebec,
H1N 2E1, Canada

